2024 Audit&Risk_issue Jan.Feb
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FRONT F E AT U R E S
11 Update
The latest news affecting 35 Division vision
the profession.
Award-winning internal
audit at The Central Bank
18 Reportage of Ireland.
Key findings from the
Chartered IIA’s “Supply
Chain ESG Risks:
Harnessing the Potential of 41 Count the carbon
Internal Audit”
How internal audit can help
sustainability teams understand
21 Audit & Risk Awards auditable data.
Nominations are open –
nominate before 31 January.
47 Valued worldwide
Why governments and
organisations across the world
value internal audit skills.
Supply chain,
52 Tools for the job
outsourcing and “nth”- Why it’s time to re-examine root-cause analysis.
party risk ranked
8 th
M E M B E R M AT T E R S
For support and guidance on all topics visit the Chartered IIA’s Community Hub.
2
H
appy new year. It is hard to believe that I became CEO of the Chartered IIA
a full year ago. The time has flown by and I have learnt so much about the
profession and I have met many of our amazing members. It’s gratifying
to see that we have achieved many of the things we set out to do, even if some
of our progress so far has been inward-looking – a wide-ranging restructure and
establishing the foundations for better IT capability and new website. These are
the underpinnings of success that will enable everything we want to improve in
future for our members. As I have said many times, and I hope it
will be evident by what we do, our focus is our members. We
exist because of, and for, our members.
Behind the scenes, and importantly for our future, we have put a lot of effort
into our lobbying activities. The audit reform bill has not yet materialised, but it
is still on the agenda and it is important that the internal audit profession has a
voice that government and regulators are aware of and listen to. This has been
developing over many years, but the opinion of the internal audit profession is
now sought and really matters.
This is why the highlights of the past year for me personally have been the
Internal Audit Conference, the Scotland Conference, the Wales Conference
and the Ireland Conference. These were my chance to meet members from all
four nations and beyond and learn what they think about the profession and the
challenges it faces.
4
I have been particularly struck by the passion that internal auditors feel for their
work. This is wonderful and not common in all sectors. When I attended IIA Global
events, I was also delighted to discover how much respect the Chartered IIA
enjoys internationally. We are one of the largest and most active institutes and
the work done by our members in the UK and Ireland is highly regarded.
It is therefore good to see our relationship with the European institutes and with
IIA Global growing and developing. We need to work together because we all want
the same thing – a strong profession that is recognised for the value it adds.
So, as we start 2024, I would like first to thank the Council and staff and everyone
else who has supported the Chartered IIA over the past year – as well as all those
who have helped me personally to understand the profession and get a feel for
what members do and what they want from us.
In the coming year, we will build on what we have already begun. There is work to
do on the new Global Internal Audit Standards and we will continue our review of
what we do and how we work.
I am looking forward to this –
especially since so much more
will be possible once we have
the IT to support us. This is
critical. Not only will it transform
the experience of members
accessing our resources, but
we will be able to devote
more time to providing what
members want.
The year ahead will undoubtedly be challenging in many ways, but the stronger
foundations we have built in 2023 have put us in a better position to seize
opportunities and focus on growth. Engagement is an essential part of this. I
hope to speak to many more members this year and want you to talk to us, tell us
what you want and help us to develop and progress. We will listen.
T
he name NEOM is a combination of the Greek and Arabic words “NEO”
and “Mustaqabal” to form NEOM – “New Future”. When I was first
approached to take on the role of Chief Internal Audit Officer at
NEOM, the initial challenge was simply to comprehend the scale and breadth
of the ambition.
In 2020, NEOM already employed people from over 60 countries and this figure
has since risen to almost 100. Establishing trust with colleagues who have a
variety of perspectives on the value and role of internal audit was essential. Sir
Dave Lewis, former CEO of Tesco, had turned me into an evangelist for the power
of trust and transparency to help teams grow, prosper and deliver at speed.
And speed was vital because the ambition and pace of NEOM drives a delivery
culture. Two data points show the scale of this ambition – NEOM will source over
150 million tonnes of structural steel (enough for 221 Eiffel Towers) and, at its
peak, NEOM will employ over 300,000 construction workers.
From day one, NIA was clear that its purpose is “to protect NEOM”. Wherever
possible, this must be done as partners – not to catch people out. We are there
to guide and be the conscience of the business wherever needed. In the early
months, developing a team that listened more than it talked and focused on
helping rather than assuring was key.
This commitment to transparency was one of two pillars of success in the first
three years. The second was the prioritisation of talent development in every
decision. Vision 2030 set clear ambitions for KSA to develop young talent and it is
at the heart of the NIA strategy and vision. We are developing the next generation
of KSA business talent, not “just” internal auditors. All our strategic and
operational decisions have “skills/capability/development” as a lens to inform
the decision.
7
One example of this is our “wise owl” model of co-sourcing, which involves
bringing global experts into NIA on a contractual basis to help us develop our
talent rapidly. Peter Terium, former CEO of RWE leads our energy business
ENOWA. I also brought in a retired head of programme assurance at EY (then
PwC), who had extensive experience in the energy sector, for a set number of
days. The business benefited and it had an immense impact on the development
of young KSA talent.
NIA has grown from one to 80 people in three years, and 30 of these are KSA
graduates. Almost half (46%) of the team are women and we have developed
resilience and wellbeing programmes to drive both psychological safety and
performance. We are on track to support our first 60 qualified professionals
and have identified our first KSA Head of Audit for a trading subsidiary – Saiel
AlMutari at Tonomus.
We have come such a long way already, but, with the launch of the NEOM
Investment Fund (NIF) and new offices opening in London and New York, there is
still much more to look forward to.
J
anuary is a traditional time for reassessing your life and your future.
Whether you make New Year’s resolutions or have taken time over the
winter holidays to think about what you have to offer and what you find
most rewarding, it’s an opportunity to look further ahead and remind yourself of
your options.
The value of good internal auditing lies in its ability to increase transparency,
improve processes and offer assurance that things are done in the way
management believes and states that they are done. Increased knowledge can
lead to ideas for further improvements, prevent unforeseen problems (and enable
organisations to react swiftly when issues occur), increase resilience and enable
managers to spot and benefit from opportunities. These are the bigger picture and
are the reasons why many internal auditors find their role so rewarding.
9
However, it is easy to lose sight of this bigger picture. People get used to working in
one type of organisation or sector and see a direct career path laid out like stepping
stones. Recognising the broad benefits of good internal auditing practice and skills
is useful if you want to assess all your opportunities.
Similar questions can also be asked of the whole internal audit function particularly
at a time when IIA Global is publishing its new Global Internal Audit Standards.
A step back
Before deciding where you want to go, it is useful to take a step back and evaluate
where you are now, what you already have to offer, and what tools you have at
your disposal.
The answers to such basic questions can be surprising. People who have spent
years working their way up to senior management may realise that they find
managing people stressful and frustrating and decide to become an expert in a
specialist audit area or a consultant.
10
Others may discover that they most enjoy making people and processes work
more efficiently and decide to look for a role in the business or elsewhere where
they can develop this further – perhaps to return to internal audit with a different
perspective in future.
Knowing where you want to go is usually the hardest thing to establish. Once
you have an objective, things become more straightforward. The economic
environment has become tougher and is unpredictable, but internal audit skills are
diverse and most internal auditors have been exposed to experiences and people
that give them multiple options. Skills are still in short
supply, so the jobs market is open to people who wish
to move sideways or take an alternative path. Knowing where you
Bear in mind that internal audit skills are common want to go is
across sectors and the IIA Global designations are just usually the hardest
that – global. If you decide to move sector or continent,
thing to establish
much of what you know and do now will be relevant. You
may just need to do additional research.
1
Look at the courses, forums and conferences hosted by the
Chartered IIA and use these to make contacts in the sectors you’re
interested in, or to boost the skills you want to develop.
2
Join a special interest group and look for sessions that will help you
build a better understanding of best practice in important areas such as
data analytics or fraud.
3
If you want to move sector, look at the institute’s sectoral groups, for
example, those for insurance, retail and construction.
4
Keep an eye on the jobs advertised on the institute’s Jobs Board and
note what skills are in demand and what is expected of applicants in your
target sector or to progress to the next level. They may be evolving rapidly in
some areas, so it’s easy to be out of date.
If your ambitions are for your team, the same applies. Once you know
where you want to get to, you can identify the skills and resources you lack
and plan to acquire them. Again, the Chartered IIA is a good place to start –
especially given the forthcoming changes to the IPPF.
1
New reports and guidance are published regularly and offer an excellent
starting point for work on topics from geopolitical risk and data analytics to
fraud and supply chain resilience.
2
Communities and forums will provide contacts who may be able to help
you by sharing skills and experiences.
3
If you and your team have already achieved great work, don’t wait
for others to recognise this and offer you promotion or new challenges.
Nominate for the A&R Awards and tell everyone about it. Publicising and
sharing good work benefits everybody and may also advance your career in
the process.
Next Update
12
Update
Contents
The proposals are similar to those put forward by the US accounting watchdog,
the Public Company Accounting Oversight Board (PCAOB), in June 2023. The
13
Update
Contents
The FRC’s consultation will close this month. If adopted, the changes will come
into force for audits of financial statements for periods beginning on or after
15 December this year.
The legislation, which came into force in October, also makes it an offence to
provide a false statement to the register. The UK government says the new powers
are the most important changes to the agency in its 180-year history.
Further provisions in the Act include the creation of a criminal offence of failing
to prevent fraud, which makes organisations liable if they benefit from a fraud
committed by employees. The National Crime Agency (NCA) gains new powers
to force businesses to hand over information that it suspects relates to money
laundering or terrorist financing, while the NCA and law enforcement agencies have
greater authority to seize, freeze and recover crypto assets.
14
Update
Contents
It predicts that in the next six months financial services regulators will focus more
intensely on firms’ risk management and controls, data quality and processes,
and management/board accountability. Specifically, KPMG expects regulators
to scrutinise financial risks and broad risk-management practices, including
leverage ratios, liquidity risk and maturity, and operational risks.
One reason for non-compliance is that Russia was more closely integrated into the
global economy than other countries subject to sanctions regimes, such as Iran,
Syria and North Korea. Another
is that it can be hard to identify
the true beneficial owners of
sanctioned companies.
If a breach is identified, the authorities may take no action, or they may issue a
warning letter or a civil penalty, or start a criminal prosecution. These actions can
be taken against bodies and individuals and can lead to prison sentences. The
highest financial penalty issued to date was a £20.5m fine imposed on Standard
Chartered Bank in 2020.
15
Update
Contents
The ICO’s research found that 70% of people would find it intrusive to be
monitored by an employer in any way. Monitoring personal devices was considered
the most intrusive practice (83%), followed by recording audio and video (78%) and
taking screenshots or webcam footage (77%). Monitoring timekeeping and access
was considered the least intrusive practice.
Update
Contents
In addition, 36% of respondents said they have “cut corners” on cyber security
practices, while 7% said they often skip steps such as using safe networks or
setting strong passwords to save time.
CROs also said the risk function is expanding beyond traditional risk management
into the area of threat management, while resources are being cut. Compliance and
regulation were the most significant risk management issues they expected to face
in the next two to five years. However, 80% of CROs said they were confident about
their organisation’s ability to deal with cyber security threats and data breaches,
while 70% felt well prepared to tackle disruptions from new technologies, such as
generative artificial intelligence (AI).
The survey revealed that 61% of respondent finance functions either have no plans
for AI implementation or are still in the initial planning phase.
Gartner’s research also shows that finance is currently well behind most other
business functions when it comes to investments in AI by the organisation: just 1%
of finance functions have adopted or intend to invest in the technology.
The lag is blamed on other priorities, lack of technical capabilities, low-quality data,
and insufficient use cases.
Next Reportage
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Reportage
Contents
8
of annual internal
<5% th
audit time is spent
on supply chain
risks, according
to roundtable
participants and
interviewees for in the Chartered IIA’s Risk in Focus 2024
this report. survey. However, respondents predicted it
would fall to 9th place by 2027.
Environmental
3 scopes
The Green House Gas (GHG) Protocol is the standard for GHG
accounting and has three defining scopes:
Scope 1 – direct emissions.
Scope 2 – indirect emissions including those from purchased energy.
Scope 3 – indirect emissions from upstream and downstream
activities in the supply chain including: raw material extraction,
transportation, product and service use, and waste disposal.
Reportage
Contents
Environmental (continued)
Actions for internal audit Sustainability plans – audit and provide assurance;
question whether environmental targets are achievable,
Compliance and regulation – understand the realistic and measurable; look for evidence.
regulatory landscape, review the supplier code of Sustainability practices – make recommendations
conduct, audit contracts, evaluate compliance, for improvements in the supply chain.
monitor changes. Roles and responsibilities – ensure these are clear
Business continuity – assess the effectiveness of and allocated to supply chain and those overseeing
business continuity plans for supply chain disruption. risks in the first, second and third lines.
Environmental risk assessment and mitigation Supplier risk management – assess the organisation’s
strategies – assess risks of potential extreme understanding of supplier challenges and monitoring
weather events, test resilience of supply chains; to detect problems. Ensure contracts are robust
identify vulnerabilities; question relevant processes and organisations know if, where and why
and measures. standards cannot be met.
Legislation and
Actions for internal audit Recommendations – identify
improvements to supplier
initiatives relevant
Supplier compliance audits – evaluate management, process improvement
for organisations
the code of conduct; ensure due and risk mitigation.
operating in the UK
diligence is adequate; work with Policy development and compliance –
and Europe include:
procurement and supply chain teams contribute to the development of
2015 UK Modern anti-corruption policies, supplier
to ensure codes are up to date.
Slavery Act codes of conduct, and ethical sourcing
Risk assessments – identify
UK Ethical Trading vulnerabilities and recommend guidelines. Ensure these are
Initiative understood and adherence monitored.
mitigation strategies.
EU Conflict Monitoring systems – collaborate Relationships – build relationships
Minerals with other departments to provide in the first and second line to improve
Regulation assurance. Use technology and understanding of supply chain risk
data analytics. and provide assurance on risk
mitigation processes, potential flaws
and culture.
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21
However, there are also many benefits – previous nominators have found the
nomination process itself beneficial, since it made them create a concise
document stating clearly all their achievements. Being shortlisted is a huge
boost to morale and exciting for all concerned. It also demonstrates to the wider
organisation that their internal audit team has demonstrated best practice and
been recognised for it by their professional institute. This is something that can be
publicised and used to improve understanding of, and confidence in, the function
and in team members. It can lead to better cooperation, build the function’s
reputation and help to attract applications for vacant roles.
Categories:
Outstanding Team
Public Sector | Private Sector (non-FS) | Financial Services Sector | Third Sector
Inspirational Leader
“What made it most exciting was the “When we won, the team was over
support we got from stakeholders. the moon, it was a real recognition
So many people said such good of all the work they had put in and we
things – I couldn’t fit them all on the all felt it was one of the best things
nomination form.” that’s happened in our careers.”
Ed Wilton, Audit Director, Kingfisher Phil Hart, Chief Internal Auditor,
ClearBank
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for the A&R Awards Event
on 20 June.
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what it takes
Entry deadline
31 JANUARY 2024
24
Contents
A mission for
more
Sandro Boeri was elected President
of the Chartered Institute of Internal
Auditors UK and Ireland at the AGM in
October. What does he want to achieve
in his time in office and why does he
believe it’s time for internal audit to
come out of the shadows?
Explore
25
I
nternal audit’s time has come – the turbulent, rapidly changing post-Covid
Contents
During his time in office, he intends to help the profession seize this opportunity
and wants internal auditors to become known for their role in promoting trust in
our society.
Boeri became President of the Chartered IIA in October, but his involvement in, and
passion for, the internal audit profession began long before this. “I have been an
internal auditor for a vast amount of my career, stretching back to 1979,” he says. “I
always had a love for, and fascination with, our profession.”
He first joined the Chartered IIA’s Council three years ago and has spent the past
year as Deputy President, so he is well aware of the challenges the institute faces.
He has been closely involved in recent efforts to build its influence.
“I stood for election because I knew that it would put me in a position to influence
the profession,” he explains. “The institute went through a difficult time during
the Covid crisis and my predecessor, Peter Elam, and the then CEO John Wood,
together with the institute’s staff, did great work stabilising its finances. I want to
help the new CEO, Anne Kiem, and the executive team to build on this and grow
both the institute and its influence more widely.”
Objectives
First, he wants to encourage Council to be, and do, “more” – “I believe that we
need to be more strategic and that if we provide a stronger strategic outlook for
the institute and the profession, we will support Anne and the executive team to do
their work.” This work has already begun and Council is currently changing what it
considers and how frequently it does this, he adds.
Second, he believes that the Council should meet in-person more frequently. “We
got used to operating virtually during Covid lockdowns, but I believe that in-person
work creates better understanding and builds collaboration,” he explains. “We will
meet in-person at least three times a year.”
Third, he intends to work more closely as a “critical friend” to Anne and the executive
team. “The Council isn’t there to second-guess everything the executive does, but to
support and to challenge,” he says. He is encouraging every Council member to have
their own area of focus and to meet the executive team regularly to support this.
26
Fifth, he aims to help the profession to progress along the path to “internal audit
Nirvana” – a state where the whole profession embraces data analytics and artificial
intelligence, has a voice at the “top table” and reacts nimbly to change in the risk
landscape.
“All internal audit teams should have a full real-time view of the audit universe and
we must be agile and react to risks as they arise. We
must consign sample testing and annual planning to
the museum,” he argues. “We need a seat at the top All internal audit
table and must offer the kind of support that makes teams should have a
the people at the top seek our opinion because we are full real-time view of
objective, respected and knowledgeable.”
the audit universe
To this end, he is currently drawing up a mindmap
with the executive team that will focus actions on
encouraging the profession to move in this direction.
This will be part of every discussion and will influence the institute’s strategic
direction in the future.
Conscience
Beyond these stated objectives, Boeri is passionate about internal audit’s role in
helping organisations to understand and accept their responsibilities not only to be
honest and transparent, but to have a position on social justice issues. He believes
that staff and customers today expect organisations to have a view on key social
and moral debates and to act with integrity to back these up with actions.
This is a complex area, which carries many risks and pitfalls. Internal audit can
help organisations both to appreciate why they should state their position, and
help them to see where their actions undermine their positive words – creating
reputational and other risks.
“We can help to ensure our organisations don’t run away from the moral dilemmas
Contents
in our society, but engage with them positively. The newer generations coming into
the workplace expect this. They don’t think that profit is the only issue
that’s important.”
Recognition
So, what would he like to leave as a legacy from his time as an internal auditor
and as President of the institute? “I would like to be remembered as one of a
number of people who made our profession recognised and appreciated by the
public – because we help move the dial in society,” he says. “I want more people to
understand that we are a profession that is respected and should be listened to.”
He feels strongly that internal auditors should feature more as experts and thought
leaders in discussions in mainstream media programmes. They should contribute
to national debates about social issues, business, risks and opportunities. If they
have enough interesting opinions, then people will start to ask “Who are they? What
do they do? Where do they get their information?” he adds.
In the past, internal audit has tended to stay hidden beneath the surface of
organisations – it’s not in most businesses’ interests to highlight those who
capture and mitigate risks before they become public. However, there are good
arguments for making internal audit’s role more widely known and the current
demand for integrity and trust reinforces these.
“It’s always an option not to be known, but that is the option of irrelevance,” he
says. “I only have one life, so I want to see this happen soon.”
28
Contents
Career in nutshell
2017 - today
Deutsche Bank – Group Audit Co-Head of People-Enablement and
Head of Culture Assessment.
1999 - 2017
Risk Audit – Owner
1999 - 2000
Gerrard Group – Head of Internal Audit
1996 - 1998
Sumitomo Mitsui Banking Corporation – Head of Internal Audit
1996 - 1997
Lazard – Senior Internal Auditor
1989 - 1996
Credit Agricole – Head of Audit & Compliance
1986 - 1989
Amsterdam Rotterdam Bank, London Branch – Head of Internal Audit
1985 - 1986
Manufacturers Hanover Trust – Internal Auditor
1979 - 1985
Kleinwort Benson – Internal Auditor
Raising
the bar
The Global Internal Audit Standards
will become effective in January
2025. They have huge potential to
increase best practice and improve
the reputation of the profession
globally. What is changing and what
do you need to do?
Explore
30
T
he global IIA’s International Standards for the Professional Practice of Internal
Contents
Auditing are changing. This is good news for IIA members worldwide – but it
will require some attention and adaptation to meet the new requirements.
There is no immediate change to syllabi for existing students.
Billed as “an evolution”, rather than a revolution, the new Global Internal Audit
Standards build on the existing ones to clarify what good internal audit looks like
in a rapidly changing world and enhance consistency worldwide. They will support
chief audit executives (CAEs) by providing explicit guidance on the position of
internal audit within organisations and the resources it needs to perform at the
required level. They will also enable the IIA, centrally and nationally, to build the
reputation of the profession and increase understanding of its value.
Many of the changes are already common practice in mature internal audit
functions, but most CAEs will need to adapt some elements of what they do
to ensure continued conformance. However, all IIA members stand to gain in
the long term from increased consistency, clearer explicit details of roles and
responsibilities and a stated purpose that can be used to inform, educate and
influence those who need to know more about the profession. Raising the bar
for all internal audit functions strengthens the reputation of the function and the
profession everywhere.
The Chartered IIA has played an important role in shaping The Standards
and ensuring that members in the UK and Ireland have had a voice in their
development. It has been represented on the global IIA Standards Board by
Liz Sandwith, who has worked with the Chartered IIA as its Chief Professional
Practices Adviser, and, more recently, by Peter Elam, its Immediate Past
President, who will continue to be a member of the global IIA Standards Board for
the next six years.
Sandwith was involved from the beginning of the process, which began when the
global IIA surveyed members for their views of the current IPPF and what could be
improved. Her term finished last year, but she was invited to continue as a special
adviser to the project. Elam joined the board in July last year.
“The Chartered IIA is one of the biggest IIA affiliates and we have a very active
membership, so our perspective and input is highly valued,” Elam says.
The IPPF and the Standards had not been significantly overhauled for many years
and there was a consensus – backed by about 19,000 comments from members
and relevant bodies worldwide – that the world and the profession had changed.
What good looks like now is different from when they were first drafted. New
audit topics have become standard, new tools are widely used and the scope of
internal audit work has developed. Organisations need and expect more wide-
ranging support than was previously common.
31
Contents
What is changing?
Others will need to do more, but the intention is that the revised Standards
document will provide a useful template that a CAE can use as a basis for a
conversation with their team and their stakeholders. It sets out the basis for good
internal audit practice, so those who do not currently conform in all areas will have
evidence of what needs to change and can use this to educate management and
secure any structural alterations or additional resources.
One area that CAEs should consider carefully is Domain 3 of The Global
Standards, “Governing the Internal Audit Function”, which concerns the
oversight of the internal audit function. This defines explicitly for the first time not
only the CAE’s role and responsibility to report to the audit committee and board,
but also the audit committee’s responsibilities to engage with and oversee the
internal audit function.
32
the audit committee, defining the kind of relationship it should have with internal
audit and demonstrating the strength and importance of this relationship,” says
Sandwith. “It’s a massive opportunity for CAEs who can now take it to the audit
committee and say ‘this is how we should be working together and this is what we
need to build on’.”
While neither the internal audit function nor IIA Global can dictate how boards
or audit committees respond, it is a strong indicator of what good looks like,
adds Elam. “Many board members are part-time, or come to the role with little
experience of internal audit, so this explicit description of their responsibilities will
help to educate and inform them.”
Domain 4, “Managing the Internal Audit Function”, also turns actions that
were previously good practice into requirements for a strong function. New CAEs
will therefore have guidance stating their responsibilities and what constitutes
good performance.
“It’s brilliant that this is now explicit because it can be used as a template for new
CAEs, to educate management and to support negotiations for resources, as well
as a timely reminder for those who have been in the role for some time,” Sandwith
points out.
The last, Domain 5 “Performing Internal Audit Services”, sets out how to plan
and conduct engagements and how to communicate findings and monitor
action plans.
New guidance on topical areas for internal audit (Topical Requirements) are also
being published to support those embarking on specific audit areas.
More information about the scope and detail of these requirements will be
provided by the Chartered and Global IIA and in future articles in Audit & Risk.
33
Contents
When will the Global Internal Audit Standards come into force?
They will become effective and replace the current Standards in 2025.
There are still 12 months before The Global Internal Audit Standards become
mandatory (January 2025), so CAEs and their teams have time to assimilate and
assess them and put any necessary changes in place. IIA Global and the Chartered IIA
will be supporting members and offering advice and guidance, so watch for further
information on websites and in future issues of A&R.
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Division
vision
Over the past three years, The Central
Bank of Ireland Internal Audit Division has
restructured; developed and implemented
a new strategy and improved its
performance against a series of targets.
Its success won it the Audit & Risk Award
for Outstanding Team – Public Sector in
2023. So what did they do?
Explore
36
P
roviding internal audit services in a central bank is a challenge. It requires
Contents
“The Central Bank of Ireland (CBI) always has ambitions to be best in class and
our framework, the Internal Audit Capability Model for the Public Sector (IACM),
is strong at producing ideas and a roadmap to improvement, but we needed
the experience and knowledge to implement these ideas effectively,” says Paul
Wrafter, Head of Internal Audit at the CBI. “We recognised we would have to
develop our staff to get the skills we needed to reach our goals.”
Wrafter joined the CBI from Allied Irish Banks plc (AIB), where he had experience
developing teams. At the CBI, he found a function that was unaccustomed to
change, but was keen to develop. “It was essential to explain to the whole team
how improvements could help them to gain the support of auditees and improve
their outputs,” he says.
“We have four pillars in the CBI, so we needed audit teams that mapped against
these,” he explains. “We changed the team structure and each area of the
business had a point of contact, which greatly improved communications.”
The Audit Committee and the Governor fully supported the changes, he
adds. They also identified what they required from audit reports, updates and
dashboards and Wrafter began an ongoing process of actively seeking feedback
and ideas for improvements.
“People can get apprehensive when you talk about agile or data analytics, but
you often find you’re already doing more than you think,” Wrafter adds. “We are
part of the Eurosystem, so we utilised our network to speak to peers, compare
practices and get new ideas, while members of the team started to sit on
more committees and working groups in the CBI so we could learn and extend
our influence. This was also great for developing internal audit managers to
collaborate more with various areas of the organisation .”
38
People
Contents
One important indication of progress was the annual CBI staff survey, as
previous feedback showed room for improvement. “We needed to identify what
we should start doing, stop doing and continue doing. We want people to enjoy
coming to work and know that they have opportunities here and elsewhere in the
organisation,” Wrafter says.
A skills assessment process was designed by the team, covering over 400
competencies. This provided invaluable insights into development needs
across both subject matter areas of the CBI and audit competencies. Training
programmes were developed to address any gaps identified. Each team member
is assessed and has a personal training plan. Consequently, the internal audit
team’s satisfaction has risen from 54% in the CBI staff survey to 75%.
The aim is to hire staff at entry level wherever possible and then train and
promote them within the division. Wrafter says he’s also happy when team
members are promoted to other roles in the CBI. The movement goes both ways.
“It’s all about getting the right balance of industry knowledge and internal audit
skills and experience in the wider team.”
Results
All this work has led to results. Against the IACM for example, the team is now
performing at level five (optimising) in the areas of services and the role of internal
audit; professional practices; performance management and accountability;
and governance structures. They have reached level four to five for people
management and organisational relationships.
A new data analytics working group is involved in more than half of all internal
audit reviews and the team’s data analytics strategy has been assessed as
excellent by Gartner. Wrafter says the quality assurance and improvement
programme (QAIP) has led to “significant improvements” in the quality of audit
outputs. They have improved relationships with, and the involvement of, business
units in the audit process, which has increased understanding of internal audit
in the organisation. A structured stakeholder engagement programme ensures
that internal audit meets managers at all levels and provides regular updates on
internal audit activity (in addition to formal executive reports).
Externally, the team has increased its contacts and influence. Wrafter now
lectures for the Chartered Accountants Ireland on its Risk Management, Internal
Audit & Compliance Diploma and chairs one of the seven sub-committees of the
Internal Audit Committee (IAC) of the European System of Central Banks. Four
other team members sit on IAC sub-committees.
39
The aim to integrate assurance has been furthered by working with the first and
Contents
second lines to improve cooperation and promote a more mature three lines
system. The team has created a risk-grading matrix to align individual business
processes in the audit universe with second-line processes, resulting in a unified
view of risk across the lines. Requests for advisory work have increased and such
work now comprises about 20% of the internal audit plan.
Looking ahead, Wrafter is keen for internal audit to highlight more emerging risks.
“Emerging risks form part of our annual planning and ongoing engagements to
ensure we help the organisation to build and maintain resilience in uncertain
times. A recent example would be our review of Environmental, Social and
Governance (ESG) aspects and the CBI’s Climate Change Division.”
The awards
“The process of nominating for the Audit & Risk Awards was straightforward,”
he adds. “The Governor and Chair of the Audit Committee, among others, were
more than happy to provide endorsements. It was a great motivator for the team
when we were shortlisted for the award and we saw it as tangible recognition for
all the hard work put in over the past few years.”
“The awards event was excellent and we received many messages congratulating
the whole division afterwards,” Wrafter adds. “It’s a huge award – internal audit
recognition doesn’t get any bigger than winning an award from the Chartered IIA.
Nothing else out there compares with it in our industry.”
m i n at i ons for
No
e n e x t Audit &
th s close
w a rd
Risk A nuary.
on 31 Ja
BECOME A
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Acquire and strengthen the managerial Raise the profile and value of your
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the carbon
Sustainability requirements are
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Richard Brasher looks ahead to
a day when carbon accounting
is as auditable as financial
accounting. But to reach that point,
sustainability teams need internal
auditors’ skills today.
Explore
42
I
n Climate Change 2023: Synthesis Report the UN states that “The extent to
Contents
which current and future generations will experience a hotter and different
world depends on choices now and in the near term” and, according to the
Chartered IIA’s Risk in Focus 2024, “Climate Change, Biodiversity & Environmental
Sustainability” is consistently ranked in the top ten risks facing organisations
today. Rules and regulations are still evolving in different jurisdictions, but even
organisations that are not yet directly required to report sustainability performance
should expect to in future either in their own right or as part of a supply chain.
Unfortunately, there are no complete answers. But since taking on the role of VP of
Sustainability, having until now been a chief audit executive (CAE), the lens
through which I view sustainability has changed. I now like to focus my new team
on three key areas: Commitment, Action and Reporting. But, I believe that as a
methodology for internal auditors as well, this helps to frame the challenge.
1. Commitment
This is in effect what companies are doing in their sustainability reports. And the
level of commitment is not trivial. Often, the commitments cover three areas
roughly following the environmental, social and governance acronym (ESG). For
example, an organisation might commit to reducing Scope 1 and Scope 2 carbon
emissions by 50% by 2030 and 100% by 2050, or to improve employee engagement
by a certain percentage by a certain year.
So, one important first step for internal auditors should be to consider how these
commitments were made. Are they based on scientific evidence? Are they in line
with the Paris Agreement and compatible with limiting global warming to 1.5°C?
Have they been committed with the Science Based Targets initiative (SBTi), and
43
have they been approved? One question that is often overlooked is whether they
Contents
are in line with the overall strategy of the organisation (or whether the strategy of
the organisation is in line with the sustainability commitments it is making)?
2. Action
This is where it all happens, and so should be an area of focus for internal
audit. What are the action plans for each commitment? For example, does the
organisation have a coherent, logical and scientific carbon abatement strategy
that matches the commitments made? Has the organisation developed a marginal
abatement cost curve to ensure that the actions taken reduce emissions in a way
that is most financially beneficial to the organisation, as well as its stakeholders and
society at large?
Here, it can be helpful to play the useful role of “critical friend” focusing more
on advisory rather than assurance engagements to help the sustainability team
especially at the early stage. If, for example, a plan has been agreed to move a fleet
of vehicles to BEV or PHEV by 2030, but no actions have been undertaken by the
fleet department in the given jurisdiction, then internal audit could legitimately ask
“why not?”.
Likewise, an internal audit team might help the sustainability team by double-
checking the logic behind the choice of actions taken and where these actions are
happening. For example, if management chooses to purchase electric vehicles
in a country where electricity is “dirty” (carbon intensive), this could be rightly
questioned or challenged.
3. Reporting
percentage of the average pay level of male employees”, then there must be data to
support the disclosure. Obtain the data, check it and conclude on the audit step.
But there are nuances to consider as well. One of the key attributes of the new
European Sustainability Reporting Standards (ESRS), which were published so
that organisations could comply with the European Corporate Sustainability
Reporting Directive (CSRD), is the concept of double-materiality. Broadly speaking,
this requires an organisation to consider impact materiality (the impact of an
organisation on the outside world) and financial materiality (the financial impact
of the outside world on the organisation). This process is hugely important, but
also hugely subjective. Apart from mandatory disclosures, how an organisation
decides what is material and what is not and, therefore, what gets disclosed and
what doesn’t is largely up to the organisation itself to decide, as long as it is
appropriately documented.
Amid the complexity, two things are certain: sustainability cannot be ignored
by internal audit departments in any organisation, and actions taken today
will inevitably affect how effectively sustainability departments guide their
organisations to make the right choices for the future of us all. Considering
in turn each element of Commitment, Action and Reporting might therefore be
as good a place to start as any when planning the first internal audit engagement
on sustainability.
45
Contents
One solution is to ask a utility or fuel billing manager to collate the data
needed, another is to use artificial intelligence (AI) to parse the relevant
data into tables.
Once the quantities of fuel and energy used are known, these amounts
must be multiplied by the correct carbon intensity factors – eg, the amount
of carbon emitted for each litre of fuel or kWh of electricity used. This can
vary significantly, according to the distance the oil or gas travels, how it is
transported, how electricity is generated in each country etc, etc.
When complete, this process will provide figures for Scope 1 and 2 GHG
emissions that internal and external auditors can select by region and/or
year to support with relevant source data, so that disclosed figures can be
traced and verified.
I personally foresee a day when all invoices will include the carbon cost
as well as the financial cost. Sustainability-based ERP systems will
automatically collect these figures and store them. Such carbon-ERP
systems will need to be global to cover the entire organisation. For many
years, finance teams have operated “No purchase order, no pay” policies.
One day, maybe we will have “No carbon data, no pay” policies. It would
make sustainability auditing much more straightforward.
Valued
worldwide
John Chesshire explains why governments
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Chartered IIA certification and internal
audit experience highly – and how this can
lead to a global career and opportunities to
make a real difference to governance and
peoples’ lives.
Explore
48
A
n internal audit certification, membership of the Chartered IIA and relevant
Contents
Making connections
Contents
The work with the OECD has been particularly interesting. I’ve led on designing,
developing and implementing (with local experts) a National Internal Audit
Certification Programme for central and local government internal auditors in
Georgia, based on the global IIA Competency Framework. Many people there would
struggle to study for the CIA qualification in English, so we have designed and
implemented something that works locally. The first students sat the exams for the
first and second modules in November 2023. Results so far have been positive.
Sharing experiences
Contents
It’s incredibly rewarding to help internal audit leaders in other regions to modernise
their teams in line with the IPPF (and its successor) and to move away from a
historical focus on inspection towards a more risk-based approach. Elements
of culture vary in different countries, but generally the problems and concerns
are the same as they are here. Often, it’s about helping teams to create a more
participative relationship with management in the first and second lines, and to
move towards adding value and improving, rather than blaming, or even punishing
wrongdoers. In the UK, we’ve been doing this for longer, so we have valuable
experience to pass on and this is hugely appreciated.
It’s also rewarding to help internal audit teams become more skilful at combating
fraud and corruption – and I’ve seen teams enjoy real successes here. There are lots
of good people doing good things, but in some places, they must deal with a long
tradition of corruption.
This means that internal audit skills are not only useful, but they are also warmly
received. I admire the courage of these internal auditors because tackling fraud and
corruption is dangerous – internal auditors have been killed for doing their jobs in
some countries. It’s a risk, but it’s also a sign that what they are doing is effective.
The new Global Internal Audit Standards include a Standard on courage and my
experiences have made me realise that this means very different things in different
places. It can have direct, personal consequences in many jurisdictions. People I’ve
worked with have spoken up despite being threatened and even fired for doing their
jobs too well.
Of course, delivering internal audit training overseas is not all glamorous travel
– I sometimes deliver live online courses for the Institute of Internal Auditors in
Australia, which means working from 2am-5am in UK time. It’s not much better
doing the same for clients in Malaysia and Singapore. When doing in-person work,
there is a lot of hanging around airports and delayed flights.
But the work is hugely varied. In addition to training, I’ve delivered many external
quality assessments overseas, worked directly with overseas government
ministers, met a president or two, and worked with a huge number of fantastic
internal audit and risk colleagues. Helping to develop the National Certification
Programme for a whole country is particularly exciting – you don’t get a chance to
do something like that very often.
John Chesshire leads Chartered IIA courses including Sanctions: It’s a World
of Pain Out There, People auditing: assurance over employee engagement, and
Environmental, Social and Governance. He also co-leads Geopolitical Risk and the
Role of the Internal Auditor. He is the owner of JC Audit Training Limited.
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52
Going underground
It’s time to look again at root cause analysis, says
James C Paterson.
I
f you have been following the development of the new Global Internal Audit
Standards, you may be aware of proposals to incorporate root cause analysis
(RCA). RCA is a vital tool for delivering insight and value and is invaluable for
developing a better thematic analysis of findings (another proposed new
requirement in The Standards).
I became familiar with various RCA techniques when I was Chief Audit Executive
of AstraZeneca, but in the dozen years since I started working on this topic with
others, I have seen a range of good and less good practices. I shared some of my
research in my most recent book on the subject, Beyond the Five Whys, at IIA
Global’s international conference in Amsterdam and believe these may interest
internal audit colleagues more widely.
First, I should point out that, while the Five Whys technique is still commonly used
by internal audit teams, it implies there will be just one root cause for a problem.
This is rarely the case.
The Bowtie diagram (Diagram 1, below) demonstrates why seeking a single root
cause is a problem. Threats and risks can result in incidents or near misses (risk
exposures) which can, in turn, result in consequences of different magnitudes. We
use detective and preventative controls to stop incidents (risk exposures) arising,
and then recovery controls to reduce the severity of the impacts if these fail.
Before After
OBJECTIVE
THREATS
Incident or
close call
So, if something goes wrong, or a risk is out of tolerance, at least one preventative
and one detective control has let us down (and possibly the recovery measures
as well).
Facts &
Circumstances
Immediate
cause(s)
Contributing
cause(s)
Root
cause(s)
Some audit teams may find it hard to stop seeking a single cause for an audit
observation, but sometimes we must take a step back from a simplistic approach,
to take two steps forward.
Thus, a person who makes a mistake – or who deliberately causes harm – is not a
root cause. If we find fraud or bribery and punish the perpetrator, we still need to
ask: “Were the anti-fraud or anti-corruption arrangements adequate? Were there
shortcomings in risk assessments, processes, systems, etc, that explain why the
fraud or corrupt act was possible?” It’s not about one person’s behaviour.
It is also about systems thinking – stepping back to see the bigger picture of
connections and dependencies. When we find a fraud, or corruption, punishing the
person should not end the story. The deeper question is “What in our organisation
as a system (processes, policies, etc) made this possible?”
When you think this way, you start to question whether the organisation is serious
about addressing certain risks properly. This may extend to questioning the clarity
of roles and accountabilities, the maturity of certain processes (and the resources
invested in making them work) and the way incentives and deterrents work. There
are eight main causal factors that can explain many problems we might see,
although which of these applies in a specific situation depends on the facts and
circumstances of the case.
It’s also important to watch for repeating problems – for example, out-of-date
access rights or projects running into difficulty – which invariably indicate systemic
problems. If you recognise that “every system is set up to get the issues it currently
gets”, you will see how issues are recurring because underlying causal factors have
not been addressed or resolved.
Additional points
• Using a technique such as the fishbone diagram for RCA can help the audit
team to cluster the reasons for problems into common categories, which can
then aid thematic analysis. Remember, however, that the common categories of
“people, process and systems” do not explain why something happened. Similarly,
identifying “culture” or “tone from the top” as a root cause does not explain why
the culture or tone at the top is failing.
• Effective RCA in internal audit starts at the beginning of assignments, not at the
end. Sometimes root causes for problems lie between departments or across a
process. If you scope an assignment without thinking about possible root causes,
you may find an important cause is beyond the scope of what you planned to do. In
these circumstances you might need to extend an assignment mid-way to draw out
the causes, which can cause delays and frustration.
55
• It is not true that RCA will inevitably extend internal audit assignments. Indeed,
it can be a valuable tool to help you zoom in on critical causal factors during the
execution of work programmes and speed up assignments. By the time you finish a
well-designed work programme, you should already know most of the key causes.
• RCA helps to produce better audit reports, because it can enable you to combine
observations (which may be symptoms) that highlight issues and relevant actions
at the level of more significant (and insightful) underlying problems.
• Because actions to address root causes may be more substantial than quick
fixes, the internal audit team should, obviously, consider the cost/benefit of what
they are proposing management should do. Consequently, it is essential to pay
attention to the potential impact of risk control shortcomings, not just to the
current impact of what has been found. (See Diagram 3.)
Observation(s) Observation-based
recommendation Corrective action(s)
(condition)
Criteria Gap(s)
Cause(s)
Priorities / owner(s)
Opinion / rating
milestones
Lastly, being good at RCA has benefits beyond internal audit assignments. It can
help an internal audit team to think critically about current challenges. For example,
if we look at issues such as repeated problems getting management to implement
audit actions fully and sustainably, we might find that the problems stem from
shortcomings in how actions were agreed, a failure to set interim milestones, or a
lack of clarity about verification requirements to demonstrate that a risk is now “in
control”. Put simply, RCA is a general purpose tool to help an internal audit team
think more carefully about the challenges it encounters.
56
Lastly, being good at RCA also helps us to understand better some of the cultural
aspects of organisations and it is worth noting that recent research by the
Chartered IIA identified that nearly 50% of internal audit teams use RCA as a tool
for understanding organisational culture. This is another reason why it’s timely that
IIA Global is giving this important technique a new prominence.
James C Paterson is Director at Risk & Assurance Insights Ltd. He is the course
tutor on the Chartered IIA’s course on Root Cause Analysis (the next one takes
place on 6 February). He is the author of “Lean Auditing” and “Beyond the Five
Whys. Root Cause Analysis and Systems thinking,” published by Wiley.
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Training insights
Contents
J
anuary is the time to make new year’s resolutions and to look back at the
past year – and ahead to the new one. Many people take the time to
consider their own careers and the skills they think they will need to
progress to the next step. Chief audit executives (CAEs) may also be doing the
same for their teams.
Given the challenges in the global geopolitical and economic environment, internal
auditors need all the skills at their disposal to keep on top of both current and
emerging risks, provide meaningful assurance to the board and audit committee
and embark on new forms of audit work and advisory support. So it’s never been a
better time to think about the skills you currently lack, or areas where you may need
some inspiration.
The Chartered IIA offers a wide range of courses. At one end, there is training that
covers the basics for those new to the profession or those working in allied roles in,
for example, the second line, who need to understand key internal audit processes.
These can provide the fundamental skills and understanding that help to get new
trainees started, or enable teams elsewhere in the business to work better with their
internal audit colleagues. CAEs could benefit by suggesting that other managers
consider sending their staff on these.
At the other extreme, there are courses for those who already have internal audit
qualifications and experience, but who are embarking on audit work in unfamiliar
areas – such as geopolitical risk, people risk, sustainability or culture – and would like
some ideas and background knowledge before they start.
Training insights
Contents
For those seeking guidance on specific topics in bitesized chunks and at their own
pace, there are also online training courses. These cover a huge range of subjects,
from ethics and ethical dilemmas to interpreting financial reports, recognising
unconscious bias, quality in internal audit and fraud risk. The material remains
accessible for 90 days from purchase, so you can access it when it suits you best and
you gain continuing professional education (CPE) points when you complete it.
All live courses are taught by skilled and experienced trainers, who encourage debate
and interaction and participants often come away with new contacts (the trainer or
fellow attendees) who can offer useful insights and support when they come to put
their learning into practice.
Training insights
Contents
For a full list of Chartered IIA training courses, access the training brochure.
Next Q&A
61
Under the Resources tab on our website you will find sections for technical
skills, interpersonal skills and leadership. Within “technical”, for example, there is
guidance to help at each stage of the audit process, so, for instance, you can find
help with scoping if that is new to you. Within “interpersonal”, you will find tips to
help with difficult conversations and coaching – areas that you will find yourself
doing with team members.
Q: I am thinking about studying for a formal internal audit qualification, but I’m
not sure which one to do now that the Standards are changing. Can you help?
A: An assurance map is a tool that can add real value to the board. You raise
a common challenge as the process of documenting assurance can reveal
duplication, gaps and also sources of information that were previously unknown.
62
Q&A
Contents
A: 1nternal auditors fulfil their assurance and advisory role in a variety of ways for
projects/change programmes. These may include:
The Chartered IIA has published several pieces of guidance on this topic. The
relevance of these will depend on the scope of your work.
Next Events
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