Ethics investigations can be challenging for just about any organization. If done right, an ethics investigation can help you identify wrongdoing and unethical behavior and put a stop to it before your organization pays the price for not maintaining a conducive and compliant work environment.

A poorly executed ethics investigation, however, can become a full-blown legal case, with the organization risking reputational and financial damages.

Customers and Shareholders prefer engaging with a business that’s known to be highly ethical. This means your business has proper systems for reporting, investigating, and implementing recommendations to improve ethics within the company and its workforce.

But how can you conduct a successful ethics investigation to ensure the least possible legal and reputational trouble for your business? Here’s a look into the process.

What Would Warrant an Ethics Investigation?

A workplace ethics investigation is typically conducted when there’s credible information about significant misconduct, wrongdoing, or ethical lapses within the organization. These include office theft or fraud, health and safety violations, misconduct such as harassment and workplace violence, and time theft, such as altering time sheets for greater earnings.

An ethics investigation can also be warranted if there have been allegations against other employees to exclude the possibility of wrongdoing within the company. For instance, employee whistleblowers expose fraud in an organization 43 percent of the time compared to professional internal auditors, who only successfully uncover it 19 percent of the time,.

An ethics investigation aims to protect the company’s and its shareholders’ interests. It detects and prevents violations and misconduct, identifies areas where the business can improve its internal operations, and ensures the company’s activities comply with applicable laws and regulations.

An ethics investigation will unearth whether suspected misconduct did or did not take place, the circumstances leading to the misconduct, the involved parties, and whether the law or company policy was violated. An ethics investigation must be perceived to be independent, thorough, and analytical.

Whom Should Be First Informed of an Ethical Issue?

Typically, employees should be able to report potential ethical issues to their manager or supervisor. If this option is impractical or the manager or supervisor can’t resolve the issue, they should be able to speak up to people in higher positions and get the audience they need. This may include making a complaint through the company’s compliance hotline or corporate ethics office, where their reports can be heard and determined impartially and with maximum confidentiality.

Ensuring employees have a clear channel for making complaints and addressing them is crucial to avoiding lawsuits related to ethical issues and compliance and saving your organization expensive legal fees.89% of employees who sue their employers do not receive a satisfactory resolution to their issues internally.

What is the Process of an Ethics Investigation?

An ethics investigation can take various stages depending on the industry or organization and its ethics investigation process. However, most investigations take the following steps.

1. Taking the Initial Complaint
An ethics investigation begins when you’re alerted of unethical behavior by someone within the company. The employee will file the complaint through the necessary channel or people. They will be responsible for documenting as much information as possible about the alleged misconduct.

The information filed from the complaint should include who is being accused of misconduct, what information has been given about their behavior, where the misconduct allegedly happened, how it happened, and when it occurred.

This information should be forwarded to your HR team and the department most affected by the ethical incident.

2. Ensure Confidentiality
Every aspect of an ethics investigation must be kept confidential. Maintaining confidentiality is crucial to the investigation’s integrity. If the investigation is not kept confidential, you risk consequences such as:

• Undermining the success of the investigation since others know of it
• Reputational damage to the accused if others learn about the allegations
• A compromised ability of the company to defend against any legal action associated with the investigation
• Liability and negative publicity for the company
• Retaliatory action from the accused
• Attempts to cover up the misconduct by the accused

Confidentiality begins immediately after the complaint is received. No other party should know that an investigation is underway, who is the subject matter, the evidence and materials gathered, the processes followed, and the investigation’s results until the final report is ready.

3. Give Interim Protection
Protecting the accuser or alleged victim should be one of the top considerations immediately after receiving the complaint. Separating the accused from the alleged victim may be necessary to avoid continued harassment or retaliation.

Some protective measures include providing a leave of absence, transfer, or schedule change. However, the complainant must be willing to take these measures. Otherwise, they can view your actions as retaliatory and file a retaliation suit.

4. Select an Investigator
A competent investigator must handle an ethics investigation. Typically, the investigator should possess the following traits:

• Investigate objectively without bias
• Have no stake in the outcome, a personal relationship with the parties involved, or have their position in the organization affected by the outcome
• Possess previous investigative knowledge and working knowledge of labour and employment laws
• Strong interpersonal skills to build a positive rapport with the involved parties and appear neutral and fair
• Right temperament to conduct interviews
• Attention to detail

5. Conduct Investigations
Once you’ve selected the investigator, you should start the investigations immediately, working quickly to identify and stop the unethical behavior before it spirals into bigger organizational issues.

While conducting investigations, the investigator should be thorough in finding the truth and reassuring employees that their submissions are confidential and non-retaliatory. This will ensure they’re more honest, contributing positively to the process.

6. Provide Guidance and Recommendations and Document the Report
Once you’ve completed the investigations, the investigator should present all gathered information and provide a recommendation for the company moving forward. This may involve recommending disciplinary action against the accused employee and effecting policy changes to ensure such incidents don’t reoccur.

After completing this process, you should write a detailed and comprehensive investigation report to provide a reference for future investigations and clear evidence that the investigation was conducted according to procedure.

Having a written investigation report will also help your legal team make a defense in court if the accused employee disputes the disciplinary action in court.

7. Talk to a Compliance Expert
An ethics investigation is a crucial process that your organization must handle properly. An effective ethics investigation process will help your organization remain compliant and avoid damaging lawsuits that can hurt its reputation and finances.

We can hope that we will never have to conduct an ethics investigation, but at most organizations of any size, the time will likely come at some point where we must. Following these steps should ensure a sound and productive ethics investigation. Done right, a proper investigation can get to the bottom of wrongdoing, put an end to the bad behavior, and hold those responsible to account.

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

Audit International realise that for many internal auditors, the audit committee is a bit of an enigma. Most of you help the chief audit executive (CAE) or other internal audit leader with materials and content to provide to this subgroup of the board of directors. Much of your work, in summary fashion, ends up there. But, for the most part, we only know what happens behind the closed doors of the boardroom if your CAE conducts a post-meeting debrief. Yes, we know that the audit committee is important. We know that they take our work seriously. But what do they really want from us?

For internal audit leaders themselves, the meetings can be intimidating. The majority of audit committee members are experienced executives from other companies and often serve on other boards. They are generally savvy, informed individuals, who spend a part-time role executing governance duties for the organization where we work. So, while they might, at times, be proactive—meaning, they raise questions or lines of inquiry based on something they initiate—mostly they are reactive, responding to what is presented to them. That means the onus is often on internal audit leaders to help them in their role by carefully choosing what to share with them.

Yet walking the fine line between providing too much detail and maximizing the little time we have with the audit committee can be tricky. Internal audit leaders often express anxiety about meeting with the committee. It can be difficult to anticipate what they may find important versus what they would consider a waste of time. Indeed, internal auditors can be forgiven if they just want to shout the famous Spice Girls refrain: “Tell me what you want, what you really, really want!” So, let’s give that a try: What does the audit committee really, really want?

First, What the Audit Committee Doesn’t Want

During an Internal Auditors career, you report functionally to an audit committee on separate occasions, with different companies. You might foolishly think that you would give them lots of information and let them decide what was important. It’s a trap that is easy to fall into. It takes time, experience, and some good mentors to gain the wisdom to realize that is absolutely the wrong tactic.

It is an evolutionary process to slowly realize that reporting to the audit committee is not about what you want to tell them. It’s only about what they need to know. To cite an often-used phrase: “be brief, be insightful, and be gone.” Keep it short, share the needed knowledge, and let others take their place on the agenda. It’s not about you; it’s about your audit committee members.

What the Audit Committee Does Want

Here are ten things that Audit International have learned that the audit committee of the board wants from internal audit. We hope they work for you when it is your turn to directly interact with the audit committee.

1) The essence of the quintessence: This phrase, “the essence of the quintessence,” was shared by a chief operating officer of a bank once, and it stuck with us. Basically, he was expressing that he and the other execs were busy folks and they want to get right to the bottom line. Don’t just tell me what you are telling me, but tell me why you are telling me. Get to the essence of the quintessence! And that’s what the audit committee wants too! So, if you feel you really must share something with the audit committee, ask yourself why it is so important that they know it. If you can start your phrase with, “this is important because …,” then they probably need to know it. They want the bottom line and the why. The rest is superfluous.

2) Not how you did something, but what you concluded: Have you ever asked someone how their vacation went and they start by telling you about the car ride to the airport? You are being polite, but all the while you wish they’d just answer the question. You want to know about the experience at the destination, not how they got there. Well, the same is true with the audit committee. All the work we did to arrive at our conclusions is important to us, but not to them. They only want to know the conclusion. So, cut to the chase. They trust you did all the right work to get there.

3) Your opinion, not just the facts: Internal auditors follow standards, confirm everything, and don’t spout wild, unsupported views on subjects. We are methodological in our pursuit of facts and the truth. So, when we have made a conclusion, we are usually armed with supporting facts. If not, we tend to refrain from going out on a limb with an opinion. Resist the urge, however, to stick only to the facts. You are not a robot; you are a person with a brain. You have a range of experiences to draw upon and see more of the organization than most anyone else. So, does the audit committee want a Joe Friday, “just the facts ma’am,” approach? Not really. They trust you have done the work and want to hear your views on various topics. If they ask your opinion, trust your instincts and give it to them. If you don’t, you really aren’t adding as much value as you can.

4) Your concerns, audited or not: Whether you are new to an organization or have been there for many years, your well-honed internal audit skills will leave you with an innate ability to have concerns about certain things, whether you have actually done internal audit work on the topic or not. If you had unlimited time and resources, you’d go check out all those nagging worries, and confirm or deny them. But you don’t. The audit plan may not have prioritized it, but that doesn’t mean the concern isn’t valid.

Now, the audit committee has no desire to hear lots of speculation or theories, nor are they interested in trivial things. But, believe me, if you have a good relationship with the audit committee, they want to hear your top concerns, even if you don’t yet have all the facts. You just need to be extra careful in how you position what you say, and you do so rather infrequently. But they do want to know. As they say, that’s why you get paid the big bucks.

5) Something of substance in executive session: One experience that is among the trickiest for a CAE to navigate is the executive session with the audit committee. During the typical executive session everyone who is not a board member leaves the room and the internal auditor meets with the audit committee alone. Over the course of a few years of executive sessions with the audit committee, I can say from experience that there are two things you never want to do: one is to have something to tell them in every executive session, and the other is to have nothing to tell them in any executive session. So, the goldilocks theory applies here, you want to strike the right balance. What to bring up, how to bring it up, and what you need to do both before and after you bring it up is a whole course in and of itself. It is an art, not a science. Don’t be trivial or cavalier about what you bring up. The audit committee wants you to bring things up, and they want them to be of substance.

6) Proof you really get the business and the strategic plan – Whether it is deserved or not, a common complaint by operating leaders and managers within many companies is that internal audit does not understand the business. The last thing you want is for the audit committee to second guess your conclusions. So, if you are confident that you know the business and the strategic plan (and you’d better be), let it show. It should show up in your audit plan, your priorities, and your explanation of internal audit’s observations and conclusions. Don’t risk having the audit committee doubt you. They want comfort that you know the business and are in lockstep with the strategic plan. Give them the confidence that you do.

Another point to make here is to remember that you are a businessperson. As we go about our internal audit work, we tend to put blinders on, as if the audit plan and the audit projects are the only reason for our existence. Of course, they are not. So, when we update the audit committee on what we are doing, what hat are we wearing? An auditor’s who happens to work for the business? Or a businessperson’s who happens to be an auditor? The audit committee wants the latter.

7) That you align with second line functions: Not always, but often the only way that second line functions (risk management, compliance, security, and others) coordinate and collaborate with internal audit is if internal audit (namely the CAE) initiates the coordination and takes a lead role in it. Apart from the added cost of redundant activities, the audit committee doesn’t want a bunch of disjointed terminology, reports, and conclusions coming from the various “risk and control” functions of your organization. They want you to coordinate and collaborate across the second and third lines. If they aren’t telling you that, they are telling someone else behind your back!

8) Courage: Like everyone else in the organization, days are always going to bring obstacles, difficult co-workers, things not going according to plan, changed schedules, broken promises, and other hurdles. But, more often than many other employees in other departments, you will from time to time be called on to summon up some courage. From an obstinate audit client that is making your job difficult to a senior audit client manager that is disagreeing with you no matter how right you are—not to mention fraud investigations, hotline accusations, and executives who are doing questionable things—you are going to come across matters that are so egregious that you must raise them, regardless of the consequence. They are, hopefully, rare, but if you are in internal audit long enough, those times will arise. They will require backbone and strength of conviction, and are not for the faint of heart. But guess what, that is exactly what the audit committee wants from you: a reservoir of courage and the ability to call on it when it matters most.

9) That you understand the politics, but are not political – All organizations are political by nature. Whenever people get together and resources are scarce, win-lose games happen. Corporate politics are a fact of life. As much as we’d all like to be apolitical and let the facts drive what the right answers are, if we don’t learn how to navigate the organization’s politics, we will not be able to get our jobs done effectively. Does that mean we need to use the politics to our advantage? Sheepishly, the answer is yes, but not in an underhanded way. It’s important to know who to talk to, about what, and when; how to position what you are going to say; who needs a heads-up on what; who are the influencers in the organization; and so on. We need to know all that and leverage it to our advantage. Our audit committee members are some rather experienced and savvy businesspeople, and they are also navigating the organization’s politics to do their governance jobs. So, yes, they do expect you to understand the politics to get your job done well and know how to report things to them with an understanding of how the politics works, but they also don’t expect you to be overly political.

10) That you know when you may not be objective: Objectivity is such an important tenet to what internal auditors do and how we do it that we need to be ultra vigilant and self-aware when there is a risk of our objectivity being impaired. Audit committees expect us to be self-aware of when our objectivity might be impaired, or even the potential appearance of it being impaired. So, park that ego, realize you are subject to your own biases, and be self-aware enough to advise the audit committee when your objectivity could be impaired. They expect you to do that.

Earning that Paycheck

Even though they may not tell you directly, take it from us that your audit committee wants you to: be brief, tell them only what they need to know, share your professional opinion, be open about your concerns, leverage executive sessions properly, understand the company’s strategic objectives and strategic plan, collaborate with the second line, be courageous, know the business, navigate organizational politics, and say when your objectivity might be impaired. Easy peasy. Well, not really. But, as we concluded, that’s why you get paid the big bucks.

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

In 2023, organizations may face new and expanded cybersecurity and compliance mandates, which could vary from location to location and from one industry to the next. As a result, your organization may be looking to obtain a certification or will need to pass an audit for a specific set of standards or requirements.

While recognition for demonstration compliance or receiving certification is a great reason to celebrate, the process leading up to that is often time-consuming and sometimes dreaded, especially if you must undergo an audit first.

But audits don’t have to be as frustrating as they once were. With the right resources and tools, you can pass your next audit with ease. Here are five tips from Audit International to help:

Know your current program state.
Don’t wait until the audit is underway to find out where you might have gaps or weaknesses. Go ahead and assess your current compliance state so you know what you need to address before your real assessment gets underway. Consider using a cybersecurity compliance platform that automates these assessments for you and look for a platform that gives you real-time compliance scoring, so you’re never caught off-guard if something isn’t functioning as you intended or you’ve overlooked an important control or other security measures.

Document and evidence.
You can do everything correctly and score 100 on your current assessment, but if you don’t have a document repository that puts everything you need right at your fingertips in one place, or if you can’t supply all the necessary proof and evidence an auditor may want, you likely won’t get credit for what you’re doing right. Put away those binders of dusty old printouts you haven’t looked at since your last audit. Instead, use a cybersecurity management platform to track and retain all of your evidence and documentation all in one place for easy, shareable access with your auditors.

Put teamwork to work for you.
Instead of chasing down who’s responsible for which compliance requirement and trying to understand what they’re doing and how well they’re doing it, use a compliance management platform to help you automate task assignments, track progress, send alerts when those tasks are complete, and assign new tasks as they pop up. A platform like Apptega can even externally alert your auditor when your team has completed an evidence request or other necessary task.

Communicate across your organization.
One of the challenges in building a compliance culture is often that program managers speak industry lingo and not the same language that people in different roles within the organization can understand and relate to their day-to-day responsibilities. Instead of scrolling through hundreds, maybe even thousands of rows of data to find what you need for your next compliance conversation, consider using a compliance management platform that has a pre-built library of reports you can quickly draw on for your next engagement, whether that’s your C-suite, an auditor, or your tech team.

Don’t go at it alone.
While you can meet all the requirements on an audit prep checklist, the reality is when you work on a program, it’s easy to overlook issues an outside eye might catch. Before your next audit, go beyond a self-assessment and consider working with an outside compliance consultant to take a closer look at your existing program and help you seek out and address issues before your auditor finds them.

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”

With businesses facing the strongest economic headwinds in years, the Chartered Institute of Internal Auditors is urging internal auditors to embrace data analytics to navigate more risky, uncertain, and volatile times ahead.

To support their call to action the Chartered IIA, a professional organization for internal auditors in the U.K. and Ireland, in partnership with AuditBoard has published a new report “Embracing data analytics: Ensuring internal audit’s relevance in a data-led world.” The report is aimed at encouraging internal auditors to fully embrace data analytics in the age of systemic risk.

The aftermath of the pandemic, the war in Ukraine and now a recession has all magnified and exacerbated a multitude of business-critical risks. These major risk events are having compounding downstream effects on supply chains, inflation, growth, costs, Forex rates, cybersecurity, and workplace mental health. Creating an adverse business risk environment of a kind not seen for decades. Making it challenging for boards to keep pace with the myriad of risks they now face.

“Data is key for organizations to navigate more risky times ahead and it is key for the future of internal audit. Understanding what the data shows about risk resilience in today’s complex environment will help ensure organizations’ success. We urge businesses and internal audit to embrace data analytics,” says John Wood, Chief Executive of the Chartered Institute of Internal Auditors.

However, in these challenging times harnessing and embracing the power of data analytics can enable internal audit to deliver faster and more incisive insights on fast moving risks, that boards can then act upon swiftly. Helping organizations to quickly identify, manage, and mitigate emerging risks during rapidly evolving situations.

Needs Improvement
The report is based on a survey of 298 internal audit executives from the private, public, and third sectors across the UK and Ireland. The survey revealed:

60% of internal audit functions are already using some for of data analytics, an additional 7% having advanced to AI. However, this still leaves a third yet to adopt data analytics.
The top three risk areas for using data analytics are financial (62%), fraud (17%), and legal and compliance (6%).
The top three benefits of using data analytics include greater level of assurance (48%), 100% audit coverage (21%) and enhanced efficiency (14%).
The top three barriers to fully embracing data analytics include lack of skills (49%), lack of resources (24%) and lack of time to implement (12%).
Only 17% expressed concern that internal auditors could be replaced by robots in the future. Instead, data analytics and AI can free up internal auditors’ time to focus on strategic and systemic risks that could be coming down the track.

The report makes several recommendations for boards and internal audit, including:

– Boards and internal audit should ensure that senior management has defined the organization’s top five risks, and that the data support this view and is correct and reliable.
– Boards and internal audit should ensure that the organization has its own data strategy in place.
– Boards should work with internal audit to identify what data is available to improve risk assurance, and how data analytics could be applied to this data to improve assurance coverage across the organization.

– Boards and internal audit should work together to champion a data analytics culture and promote a data-first mindset.
“Given the warp speed at which risks can emerge and wreak havoc, embracing data-analytics is non-negotiable for boards and internal audit if they are to stay on top of the multitude of risks that organizations are now wrestling,” says Richard Chambers, Senior Internal Audit Advisor of AuditBoard, and former President of the Global IIA. “Data analytics enables faster and higher quality assurance for boards to then act on. In stormy economic times a data-led approach has never been more urgent.”

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”

Audit International recommend five ‘Under the Radar’ Areas to Audit that May Not Be on the Audit Plan.

As internal auditors, we all have a “spidey sense” of what we should be auditing.

Sure, we should, of course, conduct comprehensive risk assessments that drive our audit plan, and many of the usual suspects will end up on that plan: cybersecurity, regulatory compliance, financial reporting, third-party relationships, and you know the rest.

But there are things, we would strongly profess, that should be audited, even if we aren’t formally auditing them and they never make it to the actual audit plan. Just by being aware—casting that web, if you will—you should constantly informally “audit” a few critical areas.

What might be some of those things we should (lower case) audit, even if we aren’t (upper case) Auditing them? Here’s Audit Internationals take on five:

1
Culture: Are Disconnects, Even if Subtle, Surfacing?

So much has been written and said about doing culture audits and internal audit’s potential role in doing such a review. Perhaps, however, your organization doesn’t support internal audit doing a full-blown culture audit. Does that mean you throw your hands up and do nothing with the topic? Heck, no!

Look, we are among the very few in the organization who have the benefit of both grasping the desired culture and viewing the entire company because of our day-to-day work. So, why not leverage that and tune into what is going on around us and notice the organizational behaviors, actions, and attitudes that are consistent with, as well as (importantly) counter to, the desired culture.

So, what’s an internal auditor to do?

Some caveats, though. First, be sure you completely understand the desired culture, both what is formally stated through things like the organization’s listed core values as well as what is implied in the “how things are done around here” subtleties. The formal and the informal culture are equally important. Then, as you go about your work in various departments and interact with people at all levels of the organization, be cognizant of behaviors, language, demeanor, protocols, and other elements that seem inconsistent with what you expected.

Now, if you witness such imbalances, and you’ll know because it will make you a bit uncomfortable, talk with close colleagues or discuss it amongst your team. If something seems amiss, continue to keep your eyes and ears open and provide your internal audit function leadership with examples of what you are witnessing. If there are culture issues in a particular area of your organization, it is likely manifesting itself in a number of other issues as well. Your internal audit function leadership will guide you on what to do and may provide guidance on the next course of action. Chief audit executives will need to consider when and how to elevate such delicate issues. Yes, it’s a sensitive topic, but something that might be critical to address. Your spidey sense will guide the way.

2
Employee Engagement: Are People Checking Out?

While it has been a topic in the corporate world for more than 20 years, at least since the Gallup Organization and their Q12 employee survey instrument brought it into the lexicon, “employee engagement” has re-emerged these days. By now, we’ve all heard the new buzz phrase “quiet quitting.” While it’s a catchy label that has been slapped on what is, in essence, just disengagement, it’s not to be taken lightly. Employees who have become disengaged in your company’s mission, vision, and values don’t have passion to do their best. This should be deeply problematic to executive leaders and, in turn, to you. It is a significant and costly drain on everything your organization does.

So, what’s an internal auditor to do?

Just like with the culture topic, we, as internal auditors, interact with more of the organization across all levels (along with HR) than most anyone else in the entire organization. Therefore, we have our finger on the pulse when it comes to engagement and its evil twin, disengagement. Do we have a general sense though the course of our internal audit work that people care or if they are they just going through the motions? Sure, we do.

We don’t need to be scientific about it, and we don’t have to call anyone or any function, department, or location out, per se, but if we see that there is a trend developing toward greater levels of disengagement, let it be known. Make it a part of what we absorb about the organization on a daily, weekly, and monthly basis. Elevate the concerns, whether to HR, department levels, or even the senior management. In other words, don’t ignore it.

3
The Physical Facilities: Are Things in Disrepair?

As much as we may not all be going into a physical office as much anymore, many employees will still spend at least some time in the office or at company facilities. And, the physical state of the office location, branch, facility, or building space is important. Not only can facility disrepair be unhealthy or unsafe, but it can also just negatively affect employee psyche or customer impressions. Pay attention to what things look like and what is the state of the physical environment around you. It may signal deeper problems or an overall neglectful view of the business.

We all have stories about what we’ve witnessed. I remember walking past a locked closet and smelling a damp odor. I could have just ignored it, thought it was just me, or figured that someone else was probably aware of it. Instead, I decided to mention it to the facilities manager of the location. And, lo and behold, behind the rightfully locked door a roof leak had infiltrated the space and it was a wiring closet. It could have been a big problem if it were ignored for any length of time.

So, what’s an internal auditor to do?

Keep your eyes and ears open as you go about your work. Does something seem amiss regarding the physical location? Mention it to someone who could do something about it. What’s the worst that could happen? They tell you “thanks, we are aware of it.” At best, you help address an issue before it gets out of hand. Sometimes we all become blind to our physical surroundings because we’ve just been there for so long. But a fresh set of eyes and ears might just help the organization out and make employees and customers even more appreciative of the physical space they show up to and that the organization spends so much money on. Internal audit can have a unique perspective of noticing what gets unnoticed.

4
The Parking Lot Check: Is Fraud Hiding in Plain Sight?

Closely related to the physical state of the facilities is the state of the employees. Ever see a change in someone’s habits that don’t sync-up with what has gone on in the past, and you wondering “what’s up with that?” Perhaps someone is showing up to the office in a new luxury car, expensive clothes, or talking about some lavish vacation they went on?

Most often, there is a great explanation, and it is none of our business. But, also, any of us who have been around the block a few times will also know that, occasionally, these changed behaviors are clues that something is amiss and that someone may be on the take. You could call this “doing a parking lot audit.” So many frauds and embezzlements have left a trail of these clues as the perpetrator wanted to channel their ill-gotten gains into the fruits of luxury and apparent success. It’s not an outright indicator or fraud, of course, but it might be a red flag to dig deeper, especially if things weren’t adding up already.

So, what’s an internal auditor to do?

Just keep your eyes and ears open, being observant to uncharacteristic behaviors, purchases, and chatter could provide clues to someone who is taking advantage of their position and situation to pilfer from your company. No, don’t go around accusing people of things where you have no proof, of course. But eyes open and be vigilant. And, if you see something, say something to a trusted colleague within your internal audit department. If necessary, elevate it within your department and, if warranted and approved, do some follow-up in a clandestine manner. You may just catch something in its preliminary stages and head it off at the pass, so to speak. Most people steal from the company in small increments, and it escalates from there if they feel they are getting away with it undetected. But, in hindsight, there were usually always clues … perhaps no further away than in the parking lot.

5
Hotline Activity: Is Volume Up, or Has Volume Decreased?

Most internal audit functions have some role in monitoring their organization’s whistleblower hotline for employees, and sometimes also third parties, to file complaints. This may seem like a no-brainer, but you’d be surprised how often small complaints (that point to bigger problems) go unnoticed. Your internal audit function may have complete ownership of managing what comes though, you may partner with someone else in the organization, such as compliance, human resources, or legal, or you just get things passed to you for review or investigation as needed from one of these organizational partners. Regardless, you need to have some role in monitoring the volume of activity. What types of activity are coming through? Are there recurring issues? What are the trends? It doesn’t take an audit, but it does take awareness. Changes in volume can be very telling, and that could be changes in either direction (increased or decreased volume).

Increases in activity might spell some brewing issues of a more macro sense and, alternatively, decreases in volume may spell a level of distrust in the confidentiality of the hotline or a perceived lack of seriousness with which reported items might be getting addressed.

So, what’s an internal auditor to do?

It doesn’t have to be you, so long as someone in your internal audit function is attuned to the trends, both in terms of volume and types of activity. And, if there are notable changes in the trends, up or down, it might be time for a deeper understanding of what might be going on. This could be a signal of troubles brewing that are inconsistent with the desired culture.
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To be clear, internal auditors don’t need a formal audit plan initiative to keep abreast of important developments in the organization. It’s not easy, I know, as the formal audit plan has us busy enough, but a little observation may go a long way. Head up, eyes and ears open, use all your senses and leverage your well-honed intellectual curiosity and professional skepticism. Do some ad-hoc auditing of things you might not be able to (upper case) Audit and don’t necessarily make it to the formal audit plan. The organization will be better for it, and you will enhance your engagement and contributions innumerably.

As popularized in the Spiderman comics of yesteryear and said in more recent movies, “with great power comes great responsibility.” Wield it judiciously!

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