Posts Tagged “audit committee”
Audit International know the common expression, “you only get one chance to make a good first impression.” For internal audit, this chance often comes during the kickoff meeting. This introductory meeting will often set the tone for the entire audit. Its primary objective is to align the auditors and auditee on the audit’s scope, objectives, timeline, and expectations. The meeting provides an opportunity to establish clear lines of communication, clarify roles and responsibilities, and build rapport between the audit team and the auditee.
Here, Audit International will provide a step-by-step guide on how to conduct an effective internal audit kickoff meeting, highlighting its importance, objectives, key participants, and necessary preparations.
Preparing for the Internal Audit Kickoff Meeting
There are several steps internal auditors can take to prepare for the kickoff meeting. They include:
- Define the Audit Objectives: Clearly articulate the purpose and goals of the audit. Identify the specific areas or processes to be examined and the desired outcomes.
- Determine the Scope: Define the boundaries and limitations of the audit. Specify the time frame, departments, locations, or functions to be included.
- Assemble the Audit Team: Select auditors with the relevant expertise and knowledge. Assign roles such as lead auditor, documentation reviewer, and subject matter experts as necessary.
- Conduct Pre-Meeting Research: Familiarize yourself with the auditee’s processes, policies, and applicable regulations. Review previous audit reports, findings, and corrective actions.
- Prepare an Agenda: Outline the topics to be discussed during the meeting. Allocate sufficient time for each agenda item and prioritize critical issues.
- Send Invitations: Distribute meeting invitations to the key participants, including auditors, auditee representatives, management, and any other relevant stakeholders. Provide the agenda and any reading materials.
The Internal Audit Kickoff Meeting Process
If you have prepared well for the kickoff meeting it should go smoothly. Keep in mind that auditees may have some anxiety about the upcoming audit. They will often have preconceived notions that they audit may be an exercise in the internal auditors trying to play “gotcha!” It’s important to alleviate these fears and clearly communicate the purpose of the audit.
They may also have concerns about the schedule of the internal audit work and see the audit as a distraction from their day-to-day duties. Indeed, we all have busy schedules and they may view the audit as providing extra work on top of their already full days. For this reason, it’s also important to be transparent about the scheduling of the audit work and to work to make the audit as painless as possible for the process or unit that is being audited.
The following are some steps to take during the kickoff meeting to help allay these fears, set expectations, and communicate clearly to the auditees:
- Introduction and Opening Remarks: a. Welcome all attendees and introduce yourself and the audit team members. b. State the purpose of the meeting and the audit’s importance to the organization. c. Outline the meeting’s agenda and expected outcomes.
- Review of Audit Objectives and Scope: a. Present the audit objectives, scope, and expected deliverables. b. Provide an overview of the audit methodology and explain any unique approaches or tools to be used. c. Discuss the audit timeline, key milestones, and any dependencies.
- Roles and Responsibilities: a. Clarify the roles and responsibilities of the audit team members. b. Define the roles and expectations for auditee representatives, including the provision of requested documentation or information.
- Communication and Information Sharing: a. Establish channels and protocols for communication throughout the audit process. b. Discuss the frequency and format of progress updates, status meetings, and any interim reporting requirements. c. Specify the confidentiality of information shared during the audit and any data protection measures.
- Document Review and Access: a. Discuss the documents, records, or systems that auditors may require access to during the audit. b. Explain the need for auditee cooperation in providing necessary documentation promptly. c. Address any concerns regarding sensitive or confidential information.
- Q&A and Discussion: a. Provide an opportunity for auditees to ask questions or seek clarification. b. Encourage open dialogue and address any concerns or challenges raised. c. Seek input from auditees regarding specific areas of focus or potential risks.
- Closing Remarks: a. Summarize the key points discussed during the meeting. b. Reiterate the importance of cooperation and commitment from all parties involved. c. Establish the next steps and confirm any follow-up actions or meetings.
Post-Kickoff Meeting Actions
Congratulations, you’ve conducted a great internal audit kickoff meeting. The internal audit team and the auditees are now on the same page and everyone knows what do expect during the audit. The initial work involving the kickoff meeting isn’t done, however. To set the upcoming audit on the right path there is still some work to do. Post-kickoff meeting activities include:
- Documentation and Reporting: Document the meeting minutes, including the key discussions, decisions, and action items. Distribute the minutes to all attendees for review and confirmation.
- Follow-up Actions: Assign responsibilities for any action items identified during the meeting. Set deadlines and establish accountability to ensure timely completion.
- Ongoing Communication: Maintain regular communication with auditee representatives to address any queries or provide clarifications as needed. Share progress updates and adhere to the agreed-upon reporting schedule.
Conducting a well-executed internal audit kickoff meeting is a crucial step towards a successful audit process. It establishes a foundation for effective communication, collaboration, and understanding between auditors and auditees. By clearly defining the audit objectives, scope, roles, and responsibilities, the kickoff meeting ensures a focused and efficient audit process. Preparing adequately, following a structured meeting agenda, and documenting the discussions and action items contribute to a productive engagement. By leveraging the guidance provided in this article, organizations can maximize the value derived from internal audits and drive continuous improvement within their operations.
If you have executed the kickoff meeting well, the auditees will be all smiles when you arrive to conduct the actual audit.
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
Let’s face it. Even here at Audit International, we understand Internal audit still suffers from some rather negative stereotypes. There are plenty of companies or units where internal auditors are not welcomed with open arms. Audit clients may view internal audit with suspicion, expecting a “gotcha” mentality or may feel like they are under surveillance.
Sure, it’s often undeserved and some of it comes with the territory, but we may even be perpetuating such negative views with the words we use. Words and phrases that internal auditors consider just a normal part of the profession’s vocabulary may actually be words that trigger negative reactions in our audit clients. And often, internal auditors don’t realize they are contributing to the hostility by using them.
Words matter and good internal auditors choose them carefully. But auditors are also as prone to using professional jargon as anyone. These are words that have become so commonplace that we might not think too much about what they really mean, especially to others. We all use them. Yet, how they might be interpreted may not be how we intended. So, what can we do about it?
Here are seven words that we should consider their meanings more closely and either use them more carefully or strike them from our vocabulary completely.
1. “Finding”
Most internal auditors call what we consider reportable (in writing and verbally) a “finding.” Think about that for a moment, though. It’s not as if the vast majority of our audit observations were hiding or lurking in some hard-to-discover, dark and foreboding place, and it took our best Indiana Jones skills to unearth them. Lo and behold, ah ha! We have a “finding.” The word relates a context of sleuthing and uncovering things that were hidden, perhaps intentionally.
So put yourself in the shoes of your audit clients. We come along and have all these “findings,” as if they weren’t doing their jobs and it took us to find these gems of reportable conditions. Worse yet, we are often reporting as “findings” what audit clients told us directly. How would you feel if someone walked through your house and told you at the end of their visit that they found the carpets needed vacuuming, the furniture needed to be dusted, and relayed a few other of their insufficient housekeeping “findings.” You’d likely be inclined to never invite them back.
Try using the words “observations,” “conclusions,” or “conditions,” rather than “findings.” You may find they work better in your organization. Audit clients will feel less like they are being accused of hiding information or that they didn’t see something that the auditors later uncovered.
2. “Weakness”
When we observe an issue, we also sometimes couch that issue by using another troubling word, “weakness.” We may not be able to avoid calling breakdowns in internal controls, as they relate to SOX-like work, “control weaknesses” if the controls are not working as they should (or at all). But we should avoid calling observations outside of controls “weaknesses,” if possible.
Think about it. You go into the manager’s office during an audit, and you say, “excuse me, if you have a few minutes I’d like to go over a few weaknesses that have come to our attention during our review of your area.” Expect immediate defensiveness. We might as well be criticizing their first-born by pointing out weaknesses in how the child looks or plays with others. The word connotes physical ineptitude and can strike a visceral blow to any manager’s ego.
Like weaknesses, “deficiencies” isn’t any better for all the same reasons. So, perhaps, try “opportunities,” or “matters for attention,” rather than “weaknesses.” Even “challenges” or “difficulties” will garner a better response from audit clients.
3. “Material”
While the term “material” has been part of auditing language forever and, although tough to really quantify, is an important and meaningful word. I mean, if it’s not material why look at it or consider it at all? We also have the SOX-related nomenclature of “material weaknesses” (which people want to avoid as best as possible). Look, if you tell someone something is “material” and it truly is agreed that it is “material,” that’s a big deal.
Yet when we tell someone who is the owner of something that we want to talk with them about a matter that is “material,” what would be the natural reaction of the person on the receiving end of that word? Disbelief, denial, and outright defensiveness are natural human reactions when told something is “material,” in a bad way, which affects them or their responsibilities. Think about being in the doctor’s office because you have not been feeling well. After a bit of consultation and tests, the doctor comes in the room and tells you that there is something “material” to discuss. You are likely to act with disbelief, denial, and defensiveness, naturally. The word conveys an urgency we might not intend. Do we really want our clients to react that way, now or in the future?
Note that “material” has an important legal context. The Securities and Exchange Commission defines “materiality” as anything a reasonable investor would deem relevant to their decisions about whether and how to invest. While it’s important to use this word carefully in this legal context, it’s also easy to adopt the word and use it outside this context, which can result in misusing it. Another problem with “material” is that it implies that everything else isn’t important or that other aspects of an audit client’s work are meaningless, which is not a great sentiment to convey.
So, perhaps, when you don’t really have to use the word “material” (or “significant” for that matter) in consultation or in writing, maybe consider some different language. Hey, there’s something important I want to run by you when you have a moment, and maybe we can write about the top matters for attention without calling them “material” (unless, of course, we must).
4. “Disclosed” or “Uncovered”
Like the word “finding,” the word “disclosed” (or the word “uncovered’) has a similar connotation. It’s as if the issue was hiding and no one knew about it or would ever find it without you, and your brilliance—the internal audit superhero with x-ray vision. OK, sometimes things were truly hidden, unintentionally or, worse yet, purposefully, and we did use our internal audit superpowers to uncover it and then we get to puff our chest and—cue music here—disclose it. But, come on, that’s rare.
Yet, we use the terminology all the time. For example, resulting from of our testing, it was disclosed that blah, blah, blah. Or, based on our review of the area, it was uncovered that yada, yada, yada. Now, if you’ve got sneaky and underhanded clients, who are going around hiding stuff from you that you truly uncovered and want to disclose to the world, then fine. But most clients don’t do that, and you want to collaborate with them in the future.
Imagine how you’d feel if the external team you hired to do your Quality Assurance Review (QAR) started telling everyone, verbally and in writing, what their work (and only their work) disclosed and uncovered in your internal audit department? How would you react to that? “Disclosed” implies that something was formerly a secret and now you are airing the dirty laundry out for the world to see.
So, maybe we need to back off the “disclosed” and “uncovered” language, at least a bit. Options might include, “along with management, we identified …,” “taking full stock of the evidence, it can be concluded that …,” “testing demonstrated that …,” or similar language. Just don’t use “revealed” instead. That’s just as bad.
5. “Entrance” and “Exit”
OK, you may need to bear with me a bit on this one.
We’re going to start an audit project, and our first meeting with the client is called, in many companies, an “entrance meeting.” Then, when we’ve concluded all our fieldwork, what do we call the last meeting with the client to wrap things up and ride off into the sunset to work on the audit report for weeks on end? The “exit meeting.” They are decent terms, descriptive of exactly what they are … our entrance (ugh, the auditors are here) and our exit (yes, they are leaving, let’s party).
Let me ask you this, though. Is this audit, the one you are doing an entrance into and an exit from, the first and last time you will ever see these folks? I sure hope you have an ongoing relationship and are interacting all year long, or at least on occasion. If that’s the case, there is no entrance and there is no exit because, like the song Hotel California, you may never leave. And, if you’ve done your relationship management right, they are happy about that.
The point is that “entrance” and “exit” are old-school terms from when we did things on a cyclical basis and may or may not come back. Back then, relationship-building was less important and audits had a fixed beginning and end. So, maybe we need to stop calling them “entrance meetings” and “exit meetings,” and just call them something else that isn’t so clinical and auditor sounding. Schedule your Project Introduction Meeting at the beginning and, maybe, your Project Wrap-Up Session at the end, or something like that. And, if you are well down the path of an agile implementation, all that entrance and exit stuff becomes moot anyway.
6. “Consulting”
Back in 1999, the Institute of Internal Auditors introduced the well-accepted and globally codified definition of Internal Auditing as: “An independent, objective assurance and consulting [emphasis added] activity designed to add value…” Back then, the word “consulting” was viewed positively. And, for internal audit to be positioned to not only provide assurance, but to also be viewed as a consultant? Well, to borrow a ’90s term, that would be “da bomb!”
But, somewhere along the way, the word “consulting” came to be viewed less positively, and we’ve started to insert the word advising to soften the term. Should we blame consultants for tarnishing a good word, and making people view consultants and, in turn, consulting, negatively? Perhaps, but that’s not the point.
We all want to be advisors, and the gold standard, the place to be, the coolest accolade, would be to be trusted and be an advisor. So, in our pursuit of being that vaulted trusted advisor, let’s drop the word consulting from our vocabulary, once and for all. Look, your clients might want to “consult” with you, but hopefully you are “advising” them.
7. “Satisfactory”
Often, we as auditors don’t want to overcommit, and use words that might get us into trouble later if something is determined to be different than our work concluded. There is just so much we can evaluate and then we must draw a conclusion and move on. So, we settle on words like “satisfactory,” even if things are notably better than the word implies. From an internal audit perspective, we are hedging out bets. We don’t want to be overly flowery with praise, and just conclude something is either “satisfactory,” “needs improvement,” or “unsatisfactory.”
Put yourself on the other side of the table. Let’s say, for instance, you’ve worked hard at something, gone the extra mile, and made sure it was done exceptionally well. Then, someone comes in, looks it over, and decides that things seem “satisfactory.” Ouch, gut punch! You put in a ton of effort, expected to get an “A” grade, and the professor gives you a “C.” That’s kind of deflating.
Let’s not forget that the word “satisfactory” means acceptable or good enough, but not outstanding or great. Yes, there are reasons to fall on the crutch of concluding, placing our highest auditor grade on something, that it is “satisfactory.” But, perhaps, if we can avoid it, we take the risk, rely on our work, and conclude that something better than a measly “satisfactory.” Don’t be afraid to say if something is exceptional, great, works well, or exceeds the requirement.
The Last Word
There is a lengthy list of good reasons, justifications, and rationalizations for why we use the words we do as internal auditors. Many of them have stood the test of time. Many are in use, and still exist, because we are hearing the world through our own ears, and not our clients’.
If we stop for a minute, and consider what these words sound like and what they actually mean, and the impressions they may leave on the ears of our clients who hear them, perhaps they are not the best words to use. Perceptions are reality, and if you want to change perceptions, maybe one way to do that is to change our vocabulary. In other words, say what you mean and mean what you say.
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”
As the threat of climate change mounts, Audit International know that businesses must take steps to counter its damaging effects. This is in order to meet ambitious government Net Zero targets, which aim to halve emissions in a little over a decade.
The promising news is that the majority of organisations now understand that sustainability must be made a priority when it comes to devising their overall strategy.
However, companies are often left in the dark as to how best to report on their ESG credentials in a way that’s impactful and means something to shareholders and other stakeholders. It’s clear that what’s needed is a uniform set of standards for measurement and reporting, just as there is for financial performance. This is particularly prevalent in the Accounting sector, where calls are increasingly being made to introduce universal and transparent ESG standards.
However, the world of sustainability reporting is a confusing and often disparate mass of names and frameworks. They include the Climate Disclosure Standards Board (CDSB), the Global Reporting Initiative (GRI), the International Integrated Reporting Council (IIRC), the Sustainability Accounting Standards Board (SASB) and the Task Force on Climate-related Financial Disclosures (TCFD).
The good news is that a forerunner has emerged that promises to offer a single source of truth when it comes to ESG reporting. It is called the International Sustainability Standards Board (ISSB). The ISSB will do for sustainability reporting what the International Accounting Standards Board (IASB) does for financial reporting. That is, develop standards for companies to report their performance to investors. Both will be under the International Financial Reporting Standards (IFRS) Foundation umbrella.
Where did the new framework originate and what exactly is it?
Created at 2021’s COP26, ISSB will provide a global baseline for high-quality sustainability reporting that supports the work being done in the US by the Securities and Exchange Commission (SEC) and the European Union (EU)’s Corporate Sustainability Reporting Directive (CSRD).
The ISSB is focused on ‘single materiality’ or the ESG information that drives valuation and matters most to investors. This is also the focus of the SEC and so the mandates are consistent. In contrast, the CSRD has a broader ‘double materiality’ mandate, which means it will cover information of interest to stakeholders, even if it is not of interest to investors. Linking the two is the concept of ‘dynamic materiality’, meaning that more light can be shed on ESG issues – such as climate change – moving forwards.
The ideal outcome is that ISSB becomes a global standard which integrates the work of all previous standards and frameworks focused on investor needs. Ideally, the SEC and EU can use its standards. The EU can then top these standards up with those covering double materiality. As dynamic materiality makes these relevant to investors, the ISSB can then take over responsibility for the standard setting process.
How can ISSB success be achieved?
The corporate community has a key role to play in ensuring the success of the ISSB. Investors are increasingly demanding information on a company of interest’s sustainability performance. At the same time, companies are increasingly being accused of greenwashing their sustainability reporting by making it appear more environmentally sound than it is.
Having standards, with proper audits, addresses both issues. That said, it’s important to note that standards aren’t targets for issues like carbon emissions or diversity and inclusion. Rather, they provide credible information on the reporting done by a company on its progress in achieving whatever targets it decides to set, if any.
While ensuring that ISSB is a success, companies can also take steps to secure their own long-term viability. The first way is to participate in the standard setting process. As with financial standard setting, exposure drafts for proposed standards will be published in the public domain. Companies need to join investors in providing their input, including constructive critiques. If a company has an opportunity to participate in any advisory councils and working groups or share its views in comment letters, it should make the effort to do so.
The second approach is to proactively adopt these standards. There will be an inevitable lag between when the standards are published and the country in which the company is headquartered making them mandatory. However, those who wait will likely lose out.
As some companies quickly adopt ISSB’s standards, investor pressure will mount for others to follow suit so they can compare companies’ performance and do their own analysis. Failure to report won’t give a company the benefit of the doubt. Rather, investors will likely assume the worst, all to the possible detriment of the company’s stock price.
Ultimately, the ISSB will make life better for any company which cares about having a sustainable, long-term corporate strategy. Therefore, companies should give their full support to make these standards the best and most accurate they can be.
“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 this final article of the series, Audit International focus on the third element of ESG- Governance risk. This differs from the first two elements – Environmental and Social – in that several governance risks have long been recognized and included in our audit plans. However, many more have recently gained prominence. Therefore, it is important that internal audit understands these risks and is well positioned to provide assurance.
Governance risks :
Some governance risks are broad in nature. Others, are very narrow. Some have little in terms of universal benchmarks, while others have well-established frameworks or regulations. Here are some of the main risks that should be considered:
– Shareholder rights and engagement – are there any limitations on certain classes of shareholders, and does the business engage effectively on important issues?
– Board structure and diversity – are there independent directors, and does the board have sufficient diversity of experience, style, and background? Increasingly, neurodiversity is a consideration, and in some countries a workers’ representative is a requirement.
– Executive compensation – is this structured to be in line with corporate objectives, and is it consistent with peers in comparison to the wages of other staff?
– Anti-bribery and corruption – many countries have a comprehensive legal framework.
– Tax transparency and policy – what is the organization’s approach to tax, and particularly the jurisdictions it operates and pays taxes in?
– Ethics and culture – a broad topic, ethics encompass all the above and more. Culture has become a hot topic over the past 15 years with the link between a strong organization-wide culture and performance becoming increasingly apparent.
– Data protection – often also included as a social risk, good information governance is relevant here as well.
– Typical impacts for the organization will be reputational, legal and regulatory, people, financial, and ultimately strategic.
Getting started – Determining the key risks :
Compared with environmental and social risk, it is much more difficult to take a holistic approach to governance risk, given the breadth of topics. However, it is likely that many activities and risks are already in your audit universe. A governance code may have been adopted by your organization, although these may only cover some of the issues described above. Understanding the relevant governance code(s) –mandatory or optional – is a good starting point. This will depend on jurisdiction(s), market listings, regulators, and industry practices. Governance codes can be principle-based or more prescriptive, and will typically define some or all of the following, often on a “comply or explain” basis:
– Clarity of purpose
– Leadership
– Integrity
– Board composition and division of responsibilities
– Board effectiveness
– Decision making
– Risk management, internal controls, and audit
– Accountability, transparency, and reporting remuneration
In understanding governance risks, you should also take into account what specific legal or regulatory requirements there are around any of these issues. This may include reporting requirements around diversity or executive pay or matters which must regularly be reported and considered by the board. Also, consider what other stakeholder expectations are relevant. This is likely to focus on investors, as they have been increasingly vocal and prepared to vote against boards that do not adequately address specific issues.
With this background information, along with your consideration of the issues highlighted earlier in this article, you can ensure your risk assessment incorporates relevant governance risks.
How internal audit can make an impact :
As always, we should leverage work done by the first and second lines in considering where we can make the biggest impact. We should consider our risk assessment alongside any new information we have about regulatory changes, emerging issues in our sector, or jurisdictions, and investor interest.
Some Examples :
– Governance framework
– Governance codes were mentioned earlier in this article. Whether your organization has adopted a code in full or developed its own framework, it will need to produce a regular (typically, annual) report of compliance with the code. Assessing the processes supporting this reporting is often a good way to execute broad audit coverage of governance risks. Such reports are expected by regulators, provide assurance to the board, and are sometimes published (at least in part in the annual report). – Therefore, it is important that they give an accurate picture.
Reports may take many forms and will often include qualitative assertions and specific data or examples. It is important that any data reported is accurate, but equally as important that narrative assertions or examples are supported by evidence. Internal audit can provide assurance over the processes to collate this evidence, ensuring it is complete and accurate and that the right oversight controls are in place. We can also review the report and verify that the conclusions reached fairly reflect the evidence available. Generally, we take a combined approach to provide comprehensive and broad assurance.
Board composition :
Board composition has been under the spotlight, and while practices have improved there is often still a lack of transparency in recruitment, objective evaluation, and diversity. This is a sensitive audit which needs to be conducted by experienced auditors. When done well, it provides real insight and impact.
It is important not to make this about the individuals currently serving on a board, but about the effectiveness of processes around recruitment, structure, skills-determination, and performance evaluation. Consider some or all of the following:
Is there an evaluation of the skills required on the board and an up-to-date skills matrix? Is this specific enough to ensure the board members possess the right range of skills and experience but sufficiently flexible to attract a diverse pool of candidates?
Do recruitment processes include defining an ideal candidate profile, pre-determined selection criteria, and stakeholder involvement in the exercise? Are candidates sourced in a way that ensures a wide pool of candidates, recognizing that there may be a need for confidentiality?
How are conflicts of interest identified and managed?
What are the rotation policies/term limits for non-executive board members?
How is board performance evaluated? Is there a self-assessment process and a periodic independent assessment?
Is there a training plan for the board and individual board members? Is there an individual appraisal process?
Does the committee structure support effective delegation but ensure the board maintains its responsibility for strategy and oversight?
How effective is the relationship between executives and non-executives? Does the structure facilitate both support and challenge?
Is there an effective process for succession planning?
Do boards allow time for open discussions and strategic thinking, as well as formal meetings?
Some of this can be done by document review — including board papers and minutes, skill matrix, recruitment process documents, etc. But much of this will also require interviews with board members and those who support the board, such as the corporate/company secretarial or corporate governance team.
This article concludes the series on what internal audit should know about ESG risks. If you missed the first two articles, be sure to go back and read our previous blogs, to get you up to speed on our suggestions on how internal audit can approach environmental and social risks.
“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”
Here at Audit International this week, we are are all talking about the Chartered Institute of Internal Auditors dropping their ‘Risk in Focus 2023’ report. The report compiles the results of 9 in-depth interviews, 4 round table events with 39 participants, and responses from 834 Chief Audit Executives (CAE)’s from across 15 European countries. In a nutshell, the report has some solid contributors, meaning, the top 10 areas which are concerning other CAE’s, might be worth you thinking about also – especially as you prepare your 2023 annual plan.
The Risk in Focus 2023 report has had a great refresh and shows the movement of each of the risks over the years. This year’s report shows 15 categories worth consideration:
– Mergers and acquisitions
– Health, safety and security
– Communications, reputation and stakeholder relationships
– Fraud, bribery and the criminal exploitation of disruption
– Organisational culture
– Organisational governance and corporate reporting
– Financial, liquidity and insolvency risks
– Supply chain, outsourcing and ‘nth’ party risk
– Business continuity, crisis management and disasters response
– Climate change and environmental sustainability
– Digital disruption, new technology and AI
– Changes in laws and regulations
– Macroeconomic and geopolitical uncertainty
– Human capital, diversity and talent management
– Cybersecurity and data security
The report finds that the greatest movers, in terms of focus / attention given to this particular topic by CAE’s, found the following four categories had the most increased attention and focus since 2020:
– Macroeconomic and geopolitical uncertainty
– Human capital, diversity and talent management
– Supply chain, outsourcing and ‘nth’ party risk
– Climate change and environmental sustainability
This years report also highlights the impact the war in Ukraine has had on many of the businesses and risks highlighted in the report.
For each of the risks, the report provides suggestions on how Internal Audit can help the organisation.
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A recent study revealed that 82% of finance and business leaders must comply with sustainability requirements or ESG regulations. Even without mandatory regulatory standards in place, Audit International would bet their bottom dollar that more companies would voluntarily take on sustainability initiatives and thus, produce ESG reports.
Why? Because more stakeholders are looking.
The number of parties with vested interests in ESG performance has dramatically increased. The tendency is to think of investors as the sole consumer, judge, and jury of ESG reports, but that’s changing, especially as other stakeholders find themselves subject to ESG expectations.
So, who’s really looking at your ESG reports? And why do they care?
Investors
Let’s start with the obvious: investors! Today’s investors want to ensure their money supports organizations that align with their values. Increasingly, those values are moving further and further away from brown stocks. Investors are leaning away from companies that might risk damaging the environment, operate with inequities, or are vulnerable to corruption.
While sustainable investing is value-based for many investors, it’s also the safer, more lucrative investment in many cases.
A study by Nordea Equity Research reported that, over three years, companies with high ESG ratings outperformed the lowest-rated companies by as much as 40%.
A Bank of America Merrill Lynch study found that firms with a healthier ESG record yielded higher three-year returns. They were also more likely to become high-quality stocks, less likely to experience significant price drops, and less likely to go bankrupt.
All this to say, an ESG score isn’t just a number. It indicates to investors that your company is a proactive, forward-thinking entity that will satisfy the investor’s need for ROI and their conscience.
Internal stakeholders
Many stakeholders within a business can benefit from ESG performance data.
For example:
Sales and marketing can use ESG data to showcase a company’s sustainability performance in their efforts to entice new customers.
IR and PR teams can tout ESG successes to improve the company’s reputation.
HR reps can use social data to attract talent.
Finance teams and chief executives can use ESG insights to improve profitability, contain costs, identify new business opportunities, and recognize areas of investment and divestment when ESG data is connected to financial performance.
Organizations can put ESG performance data to work in many ways. Regarding business value, ESG reports can give every department leverage in furthering the growth and goodwill towards an organization.
ESG scoring bodies
A good ESG score is a golden ticket to a favorable ESG reputation. To receive one, you’ll have to complete surveys or create reports designed by third-party providers, who then calculate ESG scores based on the metrics and ESG performance you reported. Like a credit score or a bond rating, an ESG score demonstrates your company’s ability to meet its ESG commitments, performance, and risk exposure.
Notable ESG scoring organizations are Bloomberg ESG Data Services, Sustainalytics, ESG Risk Ratings, JUST Capital, MSCI, Refinitiv, Dow Jones Sustainability Index Family, and RepRisk.
Banks and financial institutions
Banks, capital markets, and wealth managers are moving towards ESG agendas. This is not just an ethical move but one of demand, risk, and reward.
In terms of demand, millennials lean significantly towards sustainable investments. A survey by EY found that millennials are twice as likely to invest in a fund or stock if social responsibility is a component of the value creation narrative. (Might I remind you millennials are the demographic soon to be society’s primary wealth holders.)
In terms of risk, the liability to banks is two-fold. First, banks are subject to the same sustainability scrutiny as other businesses — customers want to bank with sustainably responsible banks. And second, banks face similar challenges to investors: lending to companies that aren’t sustainable could also pose threats to their business. Will a coal mine be able to repay its debts when sustainable alternatives take over? While banks might not be in this scenario just yet, in the future, it’s possible that businesses could see requests for funding denied if they don’t prove to be sustainable enough.
In terms of reward, again, we see companies with strong ESG performing better than those with weak ESG. An analysis completed by global investment manager BlackRock found that up to 88% of sustainable funds outperformed their non-sustainable counterparts between January 1, 2020, and April 30, 2020. Why would a wealth manager allocate funds to an unsustainable stock when a more sustainable and equally (if not more) profitable alternative exists? Why choose to lose/win when you could choose to win/win?
Regulators
Incoming! A stampede of regulations is making its way into the ESG reporting arena. Two regulations of note are:
The EU’s Corporate Sustainability Due Diligence (CSDD)
In February 2022, the European Commission published a draft of the CSDD. If passed, the CSDD would require companies to disclose the impacts of their operations on human rights and the environment.
The US’s new climate-related disclosures
In March 2022, the SEC proposed expansive new climate-related disclosures related to greenhouse gas emissions, climate risks, transition plans, and governance.
Sullivan and Cromwell LLP has a great round-up of the latest (up to May 2022) ESG regulatory advancements here. The bottom line: ESG is being written into everything from litigation to financial institutions, disclosure and governance, and law. While your particular flavor of ESG regulation will be subject to your jurisdiction and industry, you can bet on increased regulatory scrutiny coming your way soon.
Consumers
B2C companies find themselves with a consumer who cares about their product, how it’s made, and who’s making it. Recent PWC research found that:
Consumers aged 17 – 38 years are almost twice as likely to consider ESG issues when making purchasing decisions than others.
Over half of consumers surveyed said that a company’s purpose and values played a role in their purchasing decisions.
49% of consumers and 66% of millennials use the internet to learn more about a company’s ESG practices before buying a product or service.
From this, we can conclude a few things. The future of the sales will be dependent on ESG performance. And consumers aren’t satisfied with marketing promises — they want the ESG evidence, and your reports will be front in center of their investigations.
Everyone’s looking at ESG
Don’t make stakeholders struggle to seek out your ESG performance. By using a corporate performance management approach to ESG reporting, you can tell your sustainability story, disclose according to multiple new and evolving frameworks, and connect financial outcomes, operational activities, and ESG performance to ensure sustainability is always tied to doing good for the earth, people, and your bottom line.
“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:
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At Audit International, we know when people hear buzzwords like ‘data analytics’, ‘artificial intelligence’ and ‘machine learning’, it can be intimidating. Many people don’t fully understand such concepts, but in truth, you don’t need to. You just need to get comfortable with them. And you probably already are: familiar services like Netflix or Spotify use artificial intelligence to understand your preferences and make subsequent suggestions based on that knowledge. The level of consumers’ expectations is continually increasing, and the successful companies are those that are advancing with technology. The same is true for businesses and their expectations. In audit, the revolution is underway and the sections that follow highlight the key drivers for this change.
Improve the audit experience –
The volume of data available to auditors is astounding, but in most cases, this data is simply not being used. If this were happening in any other industry, there would be questions to answer. Data analytics can improve the audit experience in several ways, for both the audit team and for the client.
Improve audit quality-
During the planning phase of the audit, audit teams must shift their focus away from the old mindset of “what could go wrong?” Through analytics, we can turn our attention from what could go wrong to what has gone wrong. Auditors have access to the client’s complete financial data for the period under audit – if they focus on analysing and understanding the data, they could identify an unexpected transaction or trend in the process. During the execution phase, auditors should also build on the knowledge gained in planning to truly understand the business in question and focus their attention on higher risk transactions. Finally, auditors should move away from a ‘random sample’ approach and, instead, focus on the transactions that appear unusual based on their knowledge of the client, business or industry. These are just a few areas where improvements in audit quality can be achieved using data analytics.
Improve efficiency-
In the examples above, the use of data analytics in planning will identify what has gone wrong and any associated unusual transactions. In execution, these transactions will be tested as part of the audit sample. It could also cover some requirements under auditing standards concerning journal entry testing, as the journal entries will likely be the data that highlighted what went wrong in the first place. Again, this is just one example of efficiencies gained without even considering the hours saved by automating processes like creation of lead schedules and population of work papers.
Post-pandemic world-
The world will be a very different place in years to come. Firms with the ability to perform in-depth analysis using data analytics undoubtedly have a significant advantage over those that do not, given the efficiencies they can gain and the potential reduction of physical evidence required from clients, among other things. Due to the changes we have all had to endure, auditors may also have additional procedures to perform (e.g. roll-back procedures where they were unable to attend stock counts at year-end due to the COVID-19 closures of businesses). Such procedures have the potential to be automated, saving even more time and effort for audit teams.
Improve engagement-
Rather than spend time performing mundane tasks such as testing large randomised samples, data analytics allows audit teams to jump into the unusual transactions. This will make the job more interesting to auditors and cultivate a curious and questioning mindset, which will, in turn, lead to improved scepticism and audit quality.
Improve client experience-
This might happen in two ways. First, the time saved by the client’s staff (who, in theory, will have fewer samples for which to provide support) and second, through the value the audit adds to the business. As an example, consider an audit team performing data analysis on the payroll for their client. As payroll is a standardised process, the audit team has an expectation around the number of debits and credits they would see posted to the respective payroll accounts each month. As part of their analysis, however, they find an inconsistent pattern. This can be queried as part of the audit and the client will be better able to understand a payroll problem, which they were previously oblivious to.
Client expectations-
Given the level of data analysis that occurs daily in the life of anyone using a smartphone, a consistent, high quality is understandably expected in people’s professional lives, too. Audit clients, like all consumers, want more. They want a better and faster audit. They want an audit that requires minimal interference with the day-to-day running of their business, without compromising the quality of the auditor’s work. With troves of data now available to auditors, such expectations are not entirely unreasonable. Audit firms have access to vast amounts of financial and related data – in some instances, millions of lines of information – that, if analysed robustly and adequately, would improve their processes, their clients’ experience, and the quality of their audit files.
Aspirations of professionals-
Audit professionals can often struggle with work-life balance, as we here at Audit International know. Though most firms are getting on top of remote working, the hours in busy season are long. In a time of continuous connectivity, the time frame around ‘busy season’ is also becoming blurred. Through the use of technology, we will one day make auditing a ‘nine to five’ job. Many will scoff at that idea and, although we do not expect this to happen in the next five years, or even ten years, it is possible. By automating mundane tasks and continuously upskilling our graduates, we can transform how an audit team completes work. There will be more scope to complete work before clients’ financial year-ends, thus moving much of the audit out of the traditional ‘busy season’. Machines can complete specific tasks overnight so that auditors could arrive at their desk, ready to work on a pre-populated work paper that needs to be analysed by a person with the right knowledge. With appropriate engagement by all parties (i.e. audit teams, senior management, and audit clients), we could significantly reduce the hours spent on audit engagements and give this time back to auditors. Along with attracting high-calibre graduates, we will retain high-quality auditors in the industry while also avoiding mental fatigue and burnout, which will again lead to better quality audits.
Graduate recruitment-
Graduates joining firms in recent years have particular expectations of the working world. They want job satisfaction, flexible hours, remote working, and an engaging role that will challenge them. Professional services firms have to compete for the very best graduates, and no longer just against each other – a host of technology-enabled businesses are attracting talent on an unprecedented scale by meeting the needs listed above. Technology, and data analytics, in particular, can offer the solution to the graduate recruitment challenge – by making the work more efficient and automating mundane and repetitive tasks, graduates can instead focus on analysis. Time and time again, when we talk to candidates, we always hear that if they find their work challenging and interesting, they will feel more engaged.
Challenges-
This move towards technology is not without its risks to the profession. Automating basic tasks removes the opportunity for graduates to form a deep understanding of these sections of the audit file. The onus is therefore on the current cohort of Chartered Accountants to take the reins, both to drive technology advancement forward and also provide practical, on-the-job coaching to ensure that this knowledge is not lost for the generations that follow.
“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:
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Transit systems. Healthcare facilities. Financial services firms. What do they all have in common? Organizations within these sectors — and essentially all industries, for that matter — have been hit by ransomware, a type of malware where cybercriminals demand a ransom payment to unlock access to your private and confidential systems and files.
While many cybersecurity risks exist, ransomware is often one of the more pressing challenges. Not only can it bring operations to a screeching halt, but it can also cause issues like data leaks and reputational damage. A global survey by cybersecurity software company Sophos finds that 66% of surveyed organizations suffered ransomware attacks in 2021. “It took on average one month to recover from the damage and disruption,” Sophos adds.
Given the severity of ransomware risk, internal auditors should aim to help their organizations reduce these threats, along with overall cybersecurity risks. How? As Audit International will examine in this article, internal audit departments can take steps such as conducting IT/cybersecurity audits and using technology like internal audit management software to improve internal controls and collaboration.
Review IT practices and controls :
Even though internal auditors generally aren’t responsible for choosing cybersecurity software and establishing employee training to recognize ransomware risks, they can still provide assurance over IT practices and controls, such as with an IT audit.
When IT teams conduct phishing tests to see whether employees are tricked by email scams that can cause ransomware issues, internal auditors are then able to review those results and ensure that the organization is meeting a sufficient standard to prevent social engineering. If the results demonstrate gaps in employee preparedness on ransomware risk or other cybersecurity risks, then internal auditors would likely want to communicate that risk to other stakeholders, like boards and senior management.
Internal audit leaders might also review remote work policies to ensure that IT teams are appropriately managing these with ransomware risk in mind, rather than just focusing on the functionality of work-from-home environments. While internal auditors often rely on guidance from IT leaders, they can still audit areas like access logs to ensure that only approved devices, with the appropriate threat intelligence and data protection technologies, are connecting to their networks.
Align key stakeholders :
Improving ransomware protection also means internal auditors need to align key stakeholders, rather than just collaborating with IT. That means pulling together information from multiple departments to make sure everyone’s on the same page.
Internal auditors should check with finance teams to see how they’re accounting for the potential costs of a ransomware attack, and then ensure that other key stakeholders, like boards and senior management, understand and agree with this approach. Otherwise, issues like not having a sufficient budget to recover from a ransomware attack may arise.
“Regardless of their size or revenue, organizations should assume they will be targeted with ransomware, and they should examine their prevention, detection, mitigation, response, and recovery measures,” notes Zachary Ginsburg, research director for the Gartner Audit and Risk practice, in a Gartner press release.
Leverage internal audit management software :
Internal auditors can mitigate ransomware risk by leveraging internal audit management software. Many technologies are designed to assist with cybersecurity risk management, but from an audit perspective, internal audit management software is important for gaining assurance.
Overall, internal audit teams have an opportunity to make a significant impact when it comes to ransomware risk management. Planning ahead and focusing on internal alignment can go a long way toward reducing ransomware attacks and other cybersecurity risks.
“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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– 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.
