IIA

There is a common joke among physicists that fusion energy is 30 years away … and always will be. You could say something similar about artificial intelligence (AI) and robots taking all our jobs. The risks of AI and robotics have been expressed vividly in science fiction by the likes of Isaac Asimov as far back as 1942 and in news articles and industry reports pretty much every year since. “The machines are coming to take your jobs!” they proclaim. And yet, all of us here at Audit International still head to the office or log in from home each weekday morning.

The reality is less striking but potentially just as worrying. Most people expect that one day some sort of machine will be built that will instantly know how to do a certain job—including internal auditing—and then those jobs will be gone forever. More likely, is that AI and smart systems start to permeate into everyday tasks that we perform at work and become critical parts of the business processes our units and companies conduct. (Indeed, many professions and industries have already been greatly disrupted by AI and robotics.)

Technology companies have been so successful over the last 30 years because of the common mantra of “move fast and break things.” And that was maybe just about acceptable when it meant you could connect online to your friend from high school and find out what they had for breakfast or search through the World Wide Web for exactly the right cat meme with a well-crafted string of words.

When the consequences now might mean entrenching biases in Human Resources processes, or mass automated biometric surveillance, not to mention simply not even understanding what a system is doing (so called ‘black boxes’), the levels of oversight and risk management need to be much higher.

The Regulatory Environment :
There is some existing regulation which covers aspects of this brave new world. For example, in the European Union, article 22 of the General Data Protection Regulation (GDPR) on automated individual decision-making, provides protection against an algorithm being solely responsible for something like deciding whether a customer is eligible for a loan or mortgage. However, the next big thing coming to a company near EU is the AI Act.

The proposal aims to make the rules governing the use of AI consistent across the EU. The current wording is written in the style of the GDPR with prescriptive requirements, extraterritorial reach, a risk-based approach, and heavy penalties for infringements. With the objective of bringing about a “Brussels effect,” where regulation in the EU influences the rest of the world.

Other western jurisdictions are taking a lighter touch than the EU, with the United Kingdom working on a “pro-innovation approach to regulating AI,” and the United States’ recent “Blueprint for an AI Bill of Rights” moving towards a non-binding framework. Both have principles which closely match the proposed legal obligations within the AI Act, hinting at the impact the regulation is already having.

Much of the draft regulation is still being discussed, with a final wording soon to be agreed. There are disagreements across industries and countries on whether some of the text goes far enough or goes too far. For example, whether the definition of “AI” should be narrowed, as the current wording could encompass simple rules-based decision-making tools (or even potentially Excel macros) or even expanded to greater capture so-called “general purpose AI.” These are large models which can be used for various different tasks and therefore, applying the prescriptive requirements and risk-based approach of the AI Act can become complex and laborious.

The uncertainty over the final wording has given companies an excuse to not make first moves to prepare for the changes. Anyone who remembers the mad rush to become compliant with the GDPR will remember the pain of leaving these things to the last minute. The potential fines, which may be as high as 6 percent of annual revenue depending on the final wording, could be crippling and have a cascade effect on a company’s going-concern.

What Can Internal Auditors Do?
As internal audit professionals we can start the conversation with the business and other risk and compliance departments to shine the light on the risks and upcoming regulations which they may be unaware of. It is our objective to provide assurance but also add value to the company and this can be done through our unique ability to understand risks, the business, and provide horizon scanning activities.

Performing internal audit advisory or assurance work, depending on the AI risk maturity level at the organization, can highlight the good practice risk management steps that can be taken early to help when the regulation is finalized. These steps could include:

1) Identify AI in Use: To be able to appropriately manage AI risks throughout their lifecycle stakeholders need to be able to identify systems and processes which make use of them. Agreeing on a definition of AI and developing a process to identify where it is in use is the first step. This would include whether it is being developed in-house, is already in use through existing tools or services, or acquired through the procurement process.

2) Inventory: Developing an inventory which includes information such as the intended purpose, data sources used, design specifications, and assumptions on how and what monitoring will be performed is a good starting point and can be added to, based on your company’s unique characteristics and any specific legal requirements that are implemented in the future.
3) Risk Assessments: Since a key aspect of the AI Act is it being “risk-based,” it is important to have a risk assessment process to ensure you take the necessary steps as required in the regulation, based on the type of AI used. For example, what level of robustness, explainability, and user documentation is necessary based on the risk tier provided. It is also important to consider the business and technology risks of using the AI. For example, machine learning using neural networks requires large training datasets, which can raise issues of data protection and security, but may also perpetuate biases that are contained in the datasets. Suitable experts and stakeholders should be involved in the development and assessment of the risk assessment process.

4) Communications: One area that is often forgotten is communication. It is all well and good having a policy or a framework written down but if it isn’t known and understood by the relevant stakeholders it’s worth less than the paper it’s printed on. Involving key stakeholders during the development of your AI risk management processes can help develop a diverse platform of champions throughout the business who can act as enablers as the requirements are communicated and regulation finalized.

5) On-going monitoring: Risk management is not a one-off exercise and this is no exception. Use cases, technology, and the threat landscape change over time and it is important to include a process for on-going monitoring of AI and the associated risks.

The machines may not be coming to take our jobs just yet, but the risks are already here and so are the opportunities to get ahead. There may be a long and winding road in front, as we all prepare for a world where AI is commonplace and new regulations and standards try to shape its use, but each journey starts with a step and it’s never too early to get going.

“Audit International are specialists in the recruitment of Auditors and various Corporate Governance Professionals including Internal Audit, Cyber Security, Compliance, IT Audit, Data Analytics etc across Europe and the US.

If you would like to reach out to discuss your current requirements, please feel free to reach us via any of the following:
Calling
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E-mail:
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Amidst issues like supply chain complexity, economic uncertainty, and increased digitalization, Audit International are finding many organizations are adding vendors or changing their existing relationships with those they currently conduct business with.

Working remotely has prompted many companies to add cloud vendors. Supply chain backlogs might have prompted your business to switch to local vendors. Or maybe you’ve added marketing agencies or other types of consultants that have flexible capacity, rather than increasing headcount.

These decisions can help businesses adapt to changing conditions and build resilience, but working with vendors may also introduce new risks. While you might feel like you have a handle on issues like in-house data security processes, you need to be sure that vendors also align with your needs in these areas.

Internal audit teams can play an important oversight role when it comes to vendor risk management. While they might not be making specific vendor management decisions, they can still be involved in making sure proper due diligence is followed when selecting vendors. And once vendor relationships are in place, internal audit teams can monitor these arrangements to ensure organizations aren’t opening themselves up to new risks.

What are the top vendor risk management issues?
Working with third parties like software vendors, managed service providers, cleaning companies, etc. can help businesses fill gaps in current capabilities, increase efficiency, and more. Yet, internal audit teams also need to make sure that their organizations are accounting for any and all potential risks:

Cybersecurity: Internal audit teams should review vendors’ cybersecurity practices to assess whether these meet your organization’s expectations, for example, data security controls and remediation capabilities.

Compliance: Third-party vendors can also create compliance risks, such as improperly storing customer data or engaging in illegal business practices. Even if these vendor issues do not lead to legal action against your organization, internal auditors should aim to get ahead of these issues to avoid reputational damage.

ESG: Environmental, social, and governance (ESG) scrutiny is increasingly extending into supply chains and can also create reputational risk. Internal auditors will want to assess how vendors align with their own ESG goals. This may in turn lead to implementing additional controls, for example, around data sharing practices so that your organization will be able to verify issues like vendor emissions.

Quality: Don’t automatically assume that vendors will provide the quality you’re expecting, even if they come recommended or are widely known. Internal auditors need to ensure that their organizations still conduct proper due diligence to see whether working with that vendor will provide the quality of work you’re expecting. Managing risk can also include looking at vendor performance controls to see if existing third-party vendors maintain appropriate quality standards.
These are just some of the many critical risks that can come from working with third parties. Keep in mind that vendors may also have their own networks of third parties, which could ultimately affect your organization.

While it might not be possible to know every connection point that your vendors have with other third parties, you would likely want to assess what their own third-party risk management practices look like.

How can internal auditors improve third-party risk management?
Internal auditors shouldn’t be the only ones responsible for vendor risk assessments, but they should be mindful of the aforementioned vendor risk management issues and collaborate with other departments to stay on top of these risks.

For example, internal auditors can collaborate with IT leaders to create a vendor security due diligence checklist. From there, internal audit controls can make sure that this checklist is used across all vendor reviews.

Internal audit leaders can also integrate analytics into audit processes, such as collecting performance metrics on third-party vendors, to assess whether they meet your organization’s quality expectations on an ongoing basis.

Too often, however, adding analytics to audit reports is a manual, labor-intensive process that can create its own risks, like data errors. TeamMate Audit Benchmark found 79% of internal audit teams manually leverage data from other applications.

Audit tools like TeamMate+ can help internal auditors get the third-party data they need through automated API exchanges with other platforms, which makes continuous monitoring of risk more feasible. They can then create automated reports to share insights with other departments to stay on top of third-party risk.

By aligning with these steps and staying on top of evolving vendor management risks, internal audit teams can help their organizations stay safe while getting the most out of their third-party partnerships.

“Audit International are specialists in the recruitment of Auditors and various Corporate Governance Professionals including Internal Audit, Cyber Security, Compliance, IT Audit, Data Analytics etc across Europe and the US.

If you would like to reach out to discuss your current requirements, please feel free to reach us via any of the following:
Calling
– Switzerland 0041 4350 830 59 or
– US 001 917 508 5615
E-mail:
– info@audit-international.com”

Having considered how internal audit can address environmental risks in the first article in this Audit International series, this article turns to the second element of ESG, social risk. This can be a sensitive area, and many risks are hard to quantify. But over the last decade, expectations of organizations have evolved significantly, and internal audit has a key role in providing assurance over the risks that this presents.

Social risks :
Social risk can be viewed from several perspectives. While we traditionally look at business activities, here it can also be helpful to look through the lens of different stakeholders to ensure all risks are captured and completely understood. For example, consider impacts on the organization itself, staff, customers, suppliers, investors, other third parties, and the wider communities in which you operate. Below are some of the key risks – not an exhaustive list — but those that outline the main risk areas you will want to capture:

– Health and safety – consider both workplace and customer safety.
– Labor standards – your own and those throughout your supply chain. This goes beyond compliance with legislation and international protocols to include issues such as well-being, benefits, and employee engagement.
– Equality, diversity, and inclusion (EDI) – very important to staff, customers, and the community, this is a significant topic in and of itself
– Sales practices – important to your customer base and the wider community, poor practices can quickly damage a reputation.
– Data privacy – sometimes considered a social risk, given its impact on staff, customers, and other partners.
– Community engagement – how effective is your organization in working with local (and broader) stakeholders to maximize the positive and minimize the negative impacts on the community. This started with CSR (Corporate Social Responsibility) but often goes much deeper.
– Other broad, but important, issues such as human rights and the rights of indigenous peoples.
– Typical impacts for the organization will be the same as for many other ESG risks – reputational, legal and regulatory, financial, operational, and ultimately strategic. Other than potentially using different stakeholder perspectives when considering risks, this fits well into your risk assessment process.

Getting started – Determining the key risks :
Your risk assessment should always be the starting point. In order to do this, you will first need to go through several steps to get sufficient background context:

Understand your organization’s approach to social risk. Given the variety of risks and the number of stakeholders, it is likely that it will sit across the organization with many different risk owners. For example, staff-related risks and issues will be owned by Human Resources, whereas supply chain risks will be owned by the relevant business unit or a procurement function. Are there anywhere these risks are also considered and assessed together or across the organization, such as part of a risk function?
Consider who the key stakeholders are. Some will be common to all organizations – staff and customers for instance. Others will be specific to your business – such as a community close to a quarry.
As always, consider key sector and industry risks, drawing on industry guidance, frameworks, and other resources, and on standards such as GRI (Global Reporting Initiative).
Pay attention to your supply chain, particularly if sourcing (directly or indirectly) from jurisdictions where labor or safety standards may not reflect those in your home country.
Understand legal and regulatory requirements in all jurisdictions in which you operate.
With this background information, you can start to include social risks into your risk assessment, leveraging work done by the first and second lines, and begin to provide assurance over these key risks.

How internal audit can make an impact :
Clearly, we should be focusing on the biggest risks for the organization. However, we often need to consider the impact on stakeholder groups in aggregate, rather than just for each risk. Staff is a good example. We should certainly consider risks around compliance with labor laws but understanding the impacts on staff also requires the inclusion of wellbeing, health and safety, benefits, employee engagement, and EDI to assess the potential risk around staff as a group. Internal audit can add value by looking at risk in this way and provide more holistic assurance over risks relating to specific stakeholders.

Internal audit can also take a broader look at the organization’s approach to social risk. As I suggested earlier, it is often a distributed responsibility, but the risks do not exist in isolation. Some questions you can ask:

What is the organization’s attitude towards social risks? Are social factors (collectively or specific issues) considered in strategic planning or discussed at the Board level?
Have key stakeholders been identified? Do these make sense given what you know?
Is social impact considered in decision-making, particularly investment decisions and project evaluation? For government and social-purpose organizations, this will often be a core part of the decision-making process. But even in commercial organizations, evaluation of social risks and impacts will often be built in.
Are there targets and performance metrics in place? For key risks there often are metrics, but they may not be evaluated as a whole – which could be acceptable if they have sufficient prominence. As for other ESG risks, the availability and quality of the data may be a challenge as standards, systems, and processes are evolving. This provides an opportunity for internal audit to make an impact by evaluating systems and processes and by validating the data.
Some examples
Labor standards
The subject of labor standards is broad, but if we consider it in two parts, it may help. First there are fundamental rights at a global level which most countries are adhering to as members of the International Labour Organization. These cover issues such as forced labor, child labor, maternity, working hours, discrimination, health and safety, and unionization rights. Second, there are expectations beyond this, which often vary by country and include benefits, well-being, and employee engagement. There are many ways for internal audit to make an impact here. I will address two very different audit examples:

An organization’s own employment activities have always been part of an audit universe. There is an opportunity to take this further, providing insight and assurance into, for example, employee wellbeing and engagement. Most large organizations conduct surveys covering one or both, but how effectively do they select, track, and use metrics? Also, how effective are follow-up plans? These are sensitive areas, but this is largely about how data is collected and used, and how effectively plans are defined and implemented. All are very well aligned to core internal audit skill sets.
The broader issue of labor standards risk incorporates many parts of a business. As well as an organization’s own employees, we need to consider those in the supply chain, service companies, and any other partners. The focus of an audit is likely to be on procurement and contract management processes. Do contracts stipulate appropriate measures (which vary on the size and nature of the organization)? What independent verification is available that standards are complied with? What monitoring is in place within the organization to highlight emerging issues? All questions internal audit is well-positioned to consider and provide assurance over.

Sales practices :
Sales practices have been under the microscope at various points over the last century. Often it relates to providing dishonest or misleading information, or selling products or services are known not to be in the best interest of the buyer. The banking crisis of 2008 highlighted unethical practices which led to a significant shift to providing services based on the customer. Earlier examples are tobacco and baby formula, the health impacts of which were not accurately portrayed. In both cases, poor practices continued in parts of the developing world long after they were prohibited in the West.

Risks are primarily reputational, but often there are legal and regulatory considerations that can be substantial. Let’s look at two ways in which internal audit can make an impact in this area:

The first is not about the sales process itself, but about whether organizations are considering the customer in the products and services they sell. All jurisdictions have regulations about product quality or the types of services that can be sold to different groups of consumers. Examples range from food standards to complex financial products. In addition, there are overarching responsibilities to ensure customer health and safety (whether on-site or through the products or services they are using) that should be considered. This could be as obvious as ensuring products don’t cause a choking hazard or more complex such as the danger posed when providing social media platforms to young people. Internal auditors should understand the relevant regulations, and any voluntary codes, to provide assurance that there are appropriate controls over these risks, often as part of an existing audit. But you can also go further by considering the more complex aspects of risk and raising concerns if these have not been appropriately considered as customer needs and welfare are an integral part of product/service design and production.
Internal audit can provide assurance over the sales process itself. In any setting and for any customer group, there should be defined processes for marketing, customer communications, and best practices and guidelines a salesperson should consider when making the sale. For complex products such as insurance, this may be very structured, whereas a very light touch would be expected for simple products. Controls may include guidelines, review, and approval for marketing materials, standard templates for communications, and certifications and training for sales. When auditing, we need to be mindful of having realistic expectations for the type of products and services being sold but also be prepared to challenge when processes are insufficient or not well-evidenced. Additional considerations include data privacy, avoidance of discrimination, and the need to look at practices in all relevant jurisdictions.
To summarize, we have shown the variety of social risks within ESG and how internal audit can use their skill set to make an impact by providing assurance over some of these key risks. There are good sources of information freely available to understand different issues in more detail to help assess how social risks may impact your organization and your audit response.

The third and final article in this series will focus on the “G” (Governance) in ESG which covers a broad range of corporate activities. It is important to understand these risks as they provide the foundation for effective ESG program management.

Internal audit—connecting the dots

The world of business is constantly changing and globalization has proved to be of paramount importance for this changing world. This globalization has produced widespread dots or operations as the challenge for management to govern in an efficient manner.

Proper establishment and operations of internal audit generate reliance which connects the dots and builds trust and confidence over the widespread operations of an organization.
For an internal audit to be comprehensive and target oriented, it must be planed systematically with a documentary approach.

Analytical procedures as the tool of internal audit further helps in assessment of dot’s position in the galaxy to ascertain fluctuation and smoothness of operations.

This further clarifies the relative performance of a specific operation in financial and operational terms.
This is the key concept for the ascertainment of figures in specific heads of financials and numbers from different departments. This tool is also used to obtain an evidence or assurance during fieldwork. This is thought to have an essential ability to identify potential errors, potential fraud and unusual transactions or events that affect the organization in an adverse manner. Timely identification of potential errors and fraud helps an organization in the eradication of control weaknesses and loopholes from a system.

Global expansion of Multinationals further brings some additional challenges as topics such as local regulation, economies of scale by integration of different regional economies, currency risk, consistency in financial and other reporting across organization and understanding of local norms of stock exchange for listed companies is an additional management challenge.

Internal audit procedures specifically designed for specific risk produces remarkable results to address the vulnerability of risks.
Widespread dots or operations of organizations produce additional risks which can be controlled to bring things in risk appetite of the organization.

In addition to analytical procedures, Corporate Governance is another tool that can be used by internal auditors to control the operations of a company.

The economy of the world is constantly changing which brings new challenges every day to the organization. The governance’s control over an organization’s hierarchy at the strategic level offers the ability to believe segregation of duties and qualified personnel at the top in a hierarchy.

Corporate governance further ensures proper reporting hierarchies with the distribution of related work to equip an organization with strong controls. Another great challenge created by globalization is communication and e-commerce which are key to manage and control the organization in all aspects including normal operations of company and growth perspective. Another trend observed in the current market is decentralization with a large span of control to minimize the cost.

Decentralization exposes an entity to a greater vulnerability for control deficiency and increased risk.
Current trends and in-built risks produced by the globalization of multinationals create enhanced demand for the application of certain control techniques; especially, analytical procedures and Corporate Governance.

In addition to this, designing specific audit procedures for specific risk brings risk to the risk appetite of an entity.

As a matter of fact, control techniques equipped with strong governance structure connects the dots of widespread organizational operations and helps an organization to grow in a safe and sound control environment.

What are your thoughts on this?

Feel free to reach out to us to discuss!

Audit International are specialists in the recruitment of Internal Auditors and Corporate Governance professionals across Europe and the US.

Audit International are privileged to share some recent insights from Dr Rainer Lenz- Head of Corporate Audit at Villeroy & Boch on his thoughts about internal audit and its Independence.

“Recently, I was invited to share some thoughts about independence of internal auditors. I am basically challenging that concept:

The IIA definition positions internal auditing as an …

“ independent , objective assurance and consulting activity designed to add value and improve an organization’s operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control and governance processes.”
To be blunt, in my view, independence is largely theory. It is overrated, I think. So is objectivity. But let’s stay with the subject matter of independence. There is nothing wrong with aspiring independence. But, who cuts the hand feeding him? There are inconsistencies among talk and action. Consequently, academic authors refer to the internal auditor’s “role dilemma” and “role confusion”, acknowledging for example the difficulties of internal auditors to strike the balance between being independent from operations and, at the same time, providing added value and benefit to operations. Being both watchdog and consultant is challenging.

Some authors view internal audit as a schizophrenic management function. On one hand, it needs to be completely integrated and knowledgeable. On the other hand, it needs a measure of independence required of all auditors. Thus, internal audit may have a built in cognitive disconnect. Organizations and Chief Audit Executives (CAEs) may cope at different levels of proficiency with such inconsistent demands. Those who can do that well may live longer. Thus, “organizational hypocrisy” may serve a useful purpose.

When you ask non-executive directors and audit committee chairmen what they think, how independent internal auditors are, what will they say? I recall surveys where those members of oversight bodies state that (some) heads of internal audit are not up to the job, internal audit lacks adequate independence, and internal audit has not properly defined the role that they wish internal audit to fulfill.

That points to the “who’s your boss” question. There is no congruence between what the board wants, what the audit committee wants, and what senior management wants. Aiming at satisfying all customer groups is likely to disappoint one or the other customer in some dimension, as all may expect something different from internal audit, such that no one is fully satisfied. In other words, internal audit may face tension from its attempt to serve – let’s say – its two prime customers: managers and the audit committee. The IIA acknowledges that there may be conflicts when internal audit tries to “serve two masters”. Thus, the “who’s your boss?” issue can present problems in terms of allegiances, independence, and effectiveness.

Academic studies confirm that role ambiguity and role conflict can negatively affect the independence of internal auditors. At the same time, CEOs (often) want the CAE to have no fear or favor. It is crucial that the CAE is able to work with other stakeholders in the organization and is not afraid to voice his or her opinion even in controversial situations. That draws particular attention to the importance of the CAE’s characteristics, possibly more important than the debate around independence.

There are authors who suggest that internal auditors must be independent of senior management, so that the board is to rely on internal audit to provide the assurance it needs; otherwise, the risk is that internal audit’s reports to the board/audit committee will be filtered by senior management in such a way that only what is palatable to senior management is communicated. Investing in these relationships and having a steady and robust dialogue is critical to the internal audit function’s success, given its organizational context.

My 2 cents about independence of internal auditors in a nutshell.”

Guest Article Writer- Dr. Rainer Lenz-Head of Corporate Audit at Villeroy & Boch

Source: Lenz, R. (2016), Insights into the effectiveness of internal audit: a multi-method and multi-perspective study, LAP LAMBERT Academic Publishing, Saarbrücken, ISBN 978-3-659-85241-1