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News
Necessity,
who is the mother of invention - Plato's promulgations on
effective Internal Audit
As
the economic recession reaches its bottom and we can start
looking forward to a slow upswing, it is a good time to take
stock of a key issue which has contributed to the current
malaise. After the introduction of the Sarbanes Oxley Act
2002 provisions the past 7 years has seen an increasing emphasis
on internal auditors to assist in meeting the financial reporting
requirements contained in the Act.
During
this period, in line with greater organizational independence,
internal audit executives increasingly reported to Audit Committees
and the CEO, for functional and administrative purposes, respectively,
as evidenced by surveys conducted by the Institute of Internal
Auditors Inc (USA). However, a substantial number of Chief
Audit Executives (CAE) continue to report directly to the
CFO or senior Finance and Accounting executives in organizations,
a situation I am quite familiar with. Due to the administrative
reporting lines, many Internal Audit functions continue to
be directed predominantly to finance and accounting issues,
which has been exacerbated by the Sarbanes Oxley requirements
which have increased the personal responsibilities of the
CFO and the CEO of any compliant organizations. Even where
strong reporting lines were established with the Board Audit
Committee, the desire to ensure timely compliance with Sarbanes
Oxley Act reporting requirements drove many organizations
to emphasize the responsibilities of Internal Audit in this
direction, rather than establishing a full time dedicated
Internal Controls function.
The
past period of exuberance, which normally precedes an adjustment
as we are currently experiencing, also allowed senior executives
to see the world through rose coloured spectacles and created
a greater appetite for risk throughout organizations. Any
internal audit functions reporting operational risks and issues
were therefore often subject to the common retort that "if
it ain't broke, why fix it", a response not dissimilar
to the issues raised by many Risk Management Committees, which
in hindsight have also been found to have often gone unheeded
during those heady days.
I
would even dare to suggest that we have experienced a period
not dissimilar to the Barings Bank case, where internal audit
reporting, recommendations and risk management committee proceedings
were subject to override by senior executives bent on reaching
their operational performance indicators and annual bonuses.
The
heavy emphasis on legal compliance and ensuring a clean bill
of health for financial reports, driven by Finance executives,
Chief Executive Officers and Boards of organizations has therefore,
in my opinion, contributed to the current crisis and has been
a detrimental reversal in enlightened progress which commenced
in the 1940's when Internal Audit functions were finally recognized
as being able to contribute in a much wider arena, including
operational and internal management consulting capacity, due
to certain economic and developmental pressures then prevailing.
I recall a CFO at a NYSE listed organization who was so adamant
that he would not be the "fall guy" that he directed
the CAE to stage coach the senior executives to provide the
"right" answers to the external auditor's end of
year risk based questionnaire, an infraction of Sarbanes Oxley
section 303 (c), (Improper Influence on Conduct of Audits)
but obviously a risk well worth taking in comparison with
the likelihood of personal culpability for financial misreporting,
as noted in my case studies on www.balfoort.com.my
The
current crop of fraud cases which is seeing the light of day
is no surprise to seasoned internal audit professionals, as
evidenced by articles in the Financial Times, as it is well
known that reported fraud cases increase during any recessions,
as evidenced by previous economic downturns. Clearly little
has been learnt from those experiences, which is why we are
largely back to square one.
When
I wrote a professional services brochure on forensic and fraud
investigations services for a major US listed professional
firm in early 2008, executives at my firm were scratching
their heads about my writing and logic, as at that time there
was little evidence of any recession, let alone any signs
of increase in the incidence of fraud.
How
do internal auditors now re invent themselves to regain their
position as corporate risk advisory consultants/ management
consultants, thereby widening their scope in line with standards
and guidelines promulgated by the Institute of Internal Auditors?
Although it may seem a major challenge, the current crisis
does provide a major opportunity for professionals to present
their skills to Boards to allow them to create a platform
and track record inside organizations, away from the compliance
focus in finance and accounting.
I
would even suggest that this is an opportune moment for internal
audit executives to present their case for even greater independence,
allowing them to drive the risk based audit planning, gain
greater and more professional support from competent Audit
Committees and thereby create a much more holistic and relevant
audit plan and service to their client organizations. While
external consultants and professional services firms have
already seen the light, as evidenced by the comments from
the partner at E & Y quoted in the article referred to,
it is not too late for internal audit functions and Chief
Audit Executives to identify the same opportunity to re invent
themselves anew as an internal service centre of excellence
to meet the new challenges. Necessity, who is the mother of
inventions, as Plato so profoundly stated in his book The
Republic, as we know it in English.
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