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Approach Note on Internal Audit
            CA. Deep Kumar Mendiratta
Contents
Sl. No.      Particulars                                      Page #
Section I
     1.      Internal Audit - Basics                            4

     2.      ERM Framework                                      6

     3.      Internal Audit Guidelines                          9

     4.      Internal Audit Process, Approach & Methodology     14

Section II
     1.      Assessing Risks & Internal Controls                22

     2.      Internal Audit Sampling Methodology                29

     3.      Internal Audit Tools                               32

     4.      Reporting and Follow-up                            37

     5.      Internal Audit & Fraud                             40




Page 2
Section I - Why Internal Audit ?
Internal Audit- Basics
Definition of Internal Audit:
Internal auditing is an independent, objective assurance and consulting activity designed to add value
and improve an organization’s operations. It helps an organization accomplish its objectives by
bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk
management, control, and governance processes.

Objectives of Internal Audit:
          Risk Management
          Control
          Governance
Risk:
Risk is the potential that a chosen action or activity (including the choice of inaction) will lead to a
loss (an undesirable outcome). The notion implies that a choice having an influence on the outcome
sometimes exists (or existed).
Internal Control:
Internal Control is a process, effected by an entity’s board of directors, management, and other
personnel, designed to provide reasonable assurance regarding the achievement of its objectives
(Operational, Reporting & Compliance).




 Page 4
Why Internal Audit ?


     CARO (Companies      Require listed companies to have an internal audit system commensurate
                          with its size and nature of business. To comply with the requirements
     (Auditor’s Report    companies may either have an internal audit department or can outsource
       Order, 2003)       the internal audit function to an external agency.




                          Requires audit committee role to include oversight of the internal audit
                          function as one of the terms of reference. The agreement requires the audit
           Clause 49      committee to review with management performance of internal audit
                          function.




         Companies Act,   Requires companies to appoint an auditor or auditors at every annual
          1956 (Section   general meeting to hold office from the conclusion of that meeting until
                          the conclusion of next annual general meeting.
              224)




Page 5
Section I – ERM Framework
Enterprise Risk Management
ERM defined:
A process, effected by an entity's board of directors, management and other personnel,
applied in strategy setting and across the enterprise, designed to identify potential events
that may affect the entity, and manage risks to be within its risk appetite, to provide
reasonable assurance regarding the achievement of entity objectives

The key to effectively protecting and growing returns for an organization’s shareholders is to
identify and manage the risks that could prevent the organization from achieving its business
objectives. The enterprise risk assessment is an efficient, comprehensive process that provides
insight on inherent risks from an industry perspective and links them to the organization’s
objectives, initiatives, and business processes.

Entity objectives can be viewed in the context of four categories:
     Strategic
     Operations
     Reporting
     Compliance

Enterprise risk management requires an entity to take a portfolio view of risk. Management
considers how individual risks interrelate and develops a portfolio view from two perspectives:
    Business unit level
    Entity level




 Page 7
Enterprise Risk Management Framework




Page 8
Section I - Internal Audit Guidelines
Compliance to Auditing Standards (ICAI)
Standards on Internal Audits:

• Standard on Internal Audit (SIA) 1, Planning an Internal Audit

• Standard on Internal Audit (SIA) 2, Basic Principles Governing Internal Audit

• Standard on Internal Audit (SIA) 3, Documentation

• Standard on Internal Audit (SIA) 4, Reporting
                                                      Adobe Acrobat
• Standard on Internal Audit (SIA) 5, Sampling          Document



• Standard on Internal Audit (SIA) 6, Analytical Procedures

• Standard on Internal Audit (SIA) 7, Quality Assurance in Internal Audit

• Standard on Internal Audit (SIA) 8, Terms of Internal Audit Engagement

• Standard on Internal Audit (SIA) 9, Communication with Management




 Page 10
Compliance to Auditing Standards (ICAI)
Standards on Internal Audits:

• Standard on Internal Audit (SIA) 10, Internal Audit Evidence

• Standard on Internal Audit (SIA) 11, Consideration of Fraud in an Internal Audit

• Standard on Internal Audit (SIA) 12, Internal Control Evaluation

• Standard on Internal Audit (SIA) 13, Enterprise Risk Management

• Standard on Internal Audit (SIA) 14, Internal Audit in an Information Technology
  Environment

• Standard on Internal Audit (SIA) 15, Knowledge of the Entity and its Environment

• Standard on Internal Audit (SIA) 16, Using the Work of an Expert

• Standard on Internal Audit (SIA) 17, Consideration of Laws and Regulations in an
  Internal Audit

• Standard on Internal Audit (SIA) 18, Related Parties

 Page 11
Compliance to Auditing Standards
The IIA Standards types:
a) Attribute Standards: address the attributes of organizations and individuals
   performing internal audit services. The attributes addressed are:
     Purpose, Authority and Responsibility
     Independence and Objectivity
     Proficiency and Due Professional Care
     Quality Assurance

b) Performance Standards: describe the nature of internal audit services and provide
   quality criteria against which the performance of these services can be measured.
   The criteria addressed are:
     Managing Internal Audit Activity
     Nature of Work
     Engagement Planning
     Performing the Engagement
     Communicating Results
     Monitoring Progress
     Management’s Acceptance of Risk

c) Implementation Standards: expand upon the Attribute and Performance Standards,
 providing guidance in specific types of engagements.

 Page 12
Compliance to Auditing Standards (illustrative)
S.N.                                            Title of Standard
  1       1000 - Purpose, Authority, and Responsibility
  2       1010 – Recognition of the definition of Internal Auditing, the Code of Ethics, and the Standards in
          the Internal Audit Charter
  3       1100 - Independence and Objectivity
  4       1110 - Organizational Independence
  5       1111 – Direct Interaction with the Board

  6       1120 - Individual Objectivity

  7       1130 - Impairments to Independence or Objectivity
  8       1200 - Proficiency and Due Professional Care
  9       1210 - Proficiency
 10       1220 - Due Professional Care
 11       1230 - Continuing Professional Development
 12       1300 - Quality Assurance and Improvement Program
 13       1310 - Quality Program Assessments
 14       1311 - Internal Assessments
 15       1312 - External Assessments


Page 13
Section I - Internal Audit Process
IA Process Overview

1. Define               2. Validate            3. Execute               4. Retain

                        2.1
1.1                                            3.1
                        Request and receive
Define objectives of                           Execute audit steps
                        Data
analysis
                                                                        4.1
                                               3.2
                        2.2                                             Document process
1.2                                            Identify discrepancies
                        Validate Control                                reproduce data
Gain an understanding
                        Totals
                                               3.3
                                                                        4.2
1.3                                            Discuss discrepancies
                        2.3                                             Document Retention
Define data                                    with stakeholders and
                        Perform data quality
requirements                                   validate errors
                        Assessment
                                               3.4
                                               Assess impact on
                                               objectives




      Page 15
Execution Process Overview

 Control                                     Understand
                               Gather Info                  Evaluate
Evaluation                                   the Process



 Control                       Develop                                   Consider
              Reassess Scope
              Reassess Scope                 Sampling or
 Testing                       Test Plan                    Testing     Substantive
                                               CAATs
                                                                          Testing


Substantive                    Develop       Sampling or
  Testing                                                    Testing
                               Test Plan       CAATs



 Formulate                      Assess                      Agree Action
  Findings                       Root          Prioritize   Plan with the
                                Cause                       Management



  Page 16
Evaluation Process
 Control Objective
       Risk                                                 Microsoft Office
                                                        Excel 97-2003 Worksheet


                                       Is
         Is a                       there a
      Control in      NO           mitigating            NO                       Missing Controls
        Place?                      Control
                                        ? And in the appropriate
                                           timeframe?
             Yes                   Yes
                                                                                  Missing /
                              Assess Mitigation                                   Mitigated Controls
        Does
     the control
     address the                         NO                                       Inadequate Controls
                 e.g. Are all relevant
        risk?
                 attributes covered

     Yes
Determination on Adequacy of Control Design

   Page 17
Risk and Control Matrix
                Sub                                                                                Documents to be          Conclusion
Sr.                         What Can Go
    Process   Process/                          Control Description         Test Procedures        Referred for Test       (Effective /
No.                         Wrong (Risk)
              Activity                                                                                Procedures           Ineffective)

 1 Client Quantity       • Incorrect quantity • Quantity assessment • Obtain the latest            • Measurement
   Billing Assessment    assessment by the is done against the          Project Review Report sheets from the site
   (Invoicin & Work      billing engineer      schedule of work         (PRR) and Daily Progress • PRR and DPR
   g&                    leading to under- (target billing) and the Report (DPR) for the           • Raised RA Bills and
   Collectio             billing to the client actual work carried out period under review         certified RA Bills
   n)                    • Incorrect quantity at the site               • Select sample RA Bills
                         assessment by the • The quantity               and review whether
                         billing engineer      assessment is also cross related records certifying
                         leading to over-      checked against the      the completion of
                         billing to the client MPR/DPR (Prepared by measured work are
                                               the planning             maintained
                                               department who inturn • Ensure measured works
                                               get the data from        are strictly in accordance
                                               execution department with scope of work and
                                               and sub-contractors/ any variation is
                                               vendors)                 seperately parked as
                                                                        'Extra Work/Item'
                                                                        • Quantities for billing
                                                                        are supported by site
                                                                        measurements/Stock
                                                                        consumption and
                                                                        issuance records




  Page 18
Steps to Follow after identifying a Finding
• Discuss and validate errors with responsible stakeholders and process owners

• Consider whether there are any compensating controls within the process or system,
  and extend the testing scope, if necessary

• Assess impact - Whether or not the objectives of the test have been met and if
  alternative measures need to be taken

• Evaluate Exceptions or Errors Identified during Controls Testing for the following:

     i.     Potential Effect on control objectives
     ii.    Incidence, or level of error
     iii.   Cause of the control breakdown
     iv.    Actual Effect, if applicable




 Page 19
Elements of a Finding
Criteria:
Provides a context for evaluating evidence and understanding the findings (Control Objectives)
  • Policies & Procedures (Expectations of what should exist)
  • Contracts & Agreements
  • Laws & Regulations
  • Standards & Benchmarks
  • Defined business practices or measures which performance is compared or evaluated against

Condition:
Condition is a situation that exists or what was occurring when the control weakness was identified
i.e. The Exception or Deficiency
Cause:
Identifies the reason for the condition or the factor(s) responsible for the difference between the
situation that exists (condition) and the required or desired state (criteria), Common factors
include; poorly designed policies, procedures, or criteria, inconsistent, incomplete, or incorrect
implementation, segregation of duties or business conditions.
Effect or Risk Impact:
A clear, logical link to establish the impact or potential impact of the difference between the
situation that exists (condition) and the required or desired state (criteria), which identifies the
outcomes or consequences of the condition. Effect or risk impact may be used to demonstrate the
need for corrective action in response to identified condition.

 Page 20
Recommendations
• Should address the root cause not just the symptoms
• Be relevant and practical
• Compare the benefits to costs
• More than 1 recommendation may be required to completely address an issue
• Use best practices as a source for creative insight, adapting to the needs of the
  organization
Example:
Audit Objective:              Evaluate and Document Credit limit Increase Procedures
Risk/Control Objective:       Credit Limit Increase are manually reviewed and
                              approved prior to processing the request in the system
Sample Selection:             15 credit limit increase accounts from a system
                              generated report
Documents Obtained:           Credit limit increase MIS and the credit limit increase
                              delegation of authority and Income documents
Exceptions noted:             3 of 15 credit limits increases were not reviewed
                              and approved per the delegation of authority and excess
                              credit limit was granted to customers.


 Page 21
Section II - Assessing Risks & Internal Controls
Internal Control Structure
In many cases, you perform controls
and interact with the control
                                            Monitoring:
structure every day                         • Monthly reviews of performance reports
                                            • Internal audit function


                                                MONITORING
                                                                             Information & Communication:
                                                                             • Vision and values
                                             INFORMATION AND                 • Issue resolution calls
                                              COMMUNICATION                  • Reporting
                                                                             • Corporate communications (e-
                   Control Activities:                                         mail, meetings)
                                            CONTROL ACTIVITIES
                   • Credit limits
                   • Approvals
                   • Security                                                Risk Assessment:
                   • Block Codes /           RISK ASSESSMENT                 • Monthly Risk Control meetings
                     policies                                                • Internal audit risk assessment

                                          CONTROL ENVIRONMENT


                                            Control Environment:
                                            • Tone from the top
                                            • Corporate Policies
                                            • Organizational
                                              authority
              An internal control structure is simply a different way of viewing the business
              – a perspective that focuses on doing the right things in the right way.
    Page 23
Concepts and Objectives
Control definition reflects certain fundamental concepts:

      Internal control is a process
      Internal control is effected by people. It's not merely policy manuals and forms,
      but people at every level of an organization.
      Internal control can be expected to provide only reasonable assurance, not
      absolute assurance, to an entity's management and board.


Objectives of Internal Control

Internal controls are established to further strengthen:

      The reliability and integrity of information.
      Compliance with policies, plans, procedures, laws and regulations.
      The safeguarding of assets.
      The economical and efficient use of resources.
      The accomplishment of established objectives and goals for operations or programs.




  Page 24
Control Techniques
Prevention techniques are designed to provide reasonable assurance that only valid
transactions are recognized, approved and submitted for processing. Therefore, many of
the preventive techniques are applied before the processing activity occurs. In most
situations, preventive techniques are likely to be more effective in a strong control
environment, when management authorization criteria are well-defined and properly
communicated.

Control type definitions:
Preventive - Manual
Preventive - System

Examples of preventive controls include:

 • Segregation of duties (Preventive-Manual)
 • Business systems integrity and continuity controls, e.g., application design standards,
   change controls, security controls, systems backup and recovery (Preventive – System)
 • Physical safeguard and access restriction controls (human, financial, physical and
   information assets) (Preventive-Manual)
 • Effective "whistle blowing" processes (Preventive-Manual)




  Page 25
Control Techniques
Detection techniques are designed to provide reasonable assurance that errors and
irregularities are discovered and corrected on a timely basis. Detection techniques normally
are performed after processing has been completed. They are particularly important in an
environment that has relatively weak preventive techniques. That is, when front-end
approval and processing techniques do not provide reasonable assurance that unacceptable
transactions are prevented from being processed or do not assure that all approved
transactions are processed accurately. In this case, after-the-fact techniques become more
important in detecting and correcting processing errors.

Control type definitions:
Detective - Manual
Detective - System

Examples of detection techniques include:
 • Reconciliation of batch balance reports to control logs maintained by originating
   departments. (Detective – Manual)
 • Review and approval of reference file maintenance (“was-is”) reports. (Detective –
   Manual)
 • Reconciliation of interface amounts exiting one system and entering another.
   (Detective – System)
 • Review of on-line access and transaction logs. (Detective – System)


  Page 26
Risk Analysis
                           Risk Analysis


       Risk                    Risk             Risk
    Assessment              Management       Monitoring

                                                Process
          Identification       Control It
                                                 Level


                               Share or         Activity
    Measurement
                              Transfer It        Level


                              Diversify or
          Prioritization                      Entity Level
                                Avoid It

Page 27
Role of a Process Owner
 General Expectations
  • Acknowledge the responsibility for the design, implementation and maintenance
    of the control structure within the business processes
  • Contribute direction to identify, prioritize and review risks and controls
  • Remove obstacles for compliance; remedy control deficiencies
  • Continue or begin a program of self-assessment and testing to monitor the
    controls within the processes
  • Quarterly
          - confirm key controls are implemented and effective
          - maintain documentation to support this assessment

 Immediate Action Items
  • Educate personnel about the requirements and effort
  • Reinforce internal focus on controls within the process
  • Surface any risks, concerns or issues promptly to allow adequate attention for
    correction (don’t wait for an audit)
  • Fix control gaps within reasonable timescales


Page 28
Section II - Internal Audit Sampling
Sampling
Population:
The entire set of universe from which a sample is selected & reviewed, and about which the auditor
wishes to draw conclusions.
Data availability for population:
An important aspect in sample selection is the availability of data. Depending upon the population,
entire data may or may not be available. In cases where entire data is not available, same should
be brought to the attention of the Management, be agreed with the stakeholders and be clearly
mentioned as a scope limitation.
Systematic selection:
A systematic approach is used by the auditor to select items, to minimize any potential human
judgment or bias. Every nth item within the population is selected in accordance with a defined
sampling interval.
Haphazard selection:
The auditor, without any conscious bias, selects sample items randomly, i.e., without any special
reason for including or omitting items from the sample
Stratification:
Prior to carrying out analytical procedures, it is important to stratify / classify the data into
separate logical sections. This classification would not only help in analyzing trends unique to that
particular category but would also help in assessing materiality while selecting a sample.




 Page 30
Sampling
Perform Analytical procedures:
Analytical procedure is defined as an evaluation of financial information made by a study of
plausible relationships among both financial and non-financial data
Analyse abnormal transactions:
If the analytical procedures highlight certain abnormal transactions (where there are significant
aberrations), they should be separated and reviewed separately. Such transactions should be
reviewed in addition to the regular sample selected.
Using Excel / CAAT:
In case the testing objective can be applied by using excel / CAAT on the entire population, audit
procedures should be performed on the entire population else samples should be selected for
testing
Determining sample size and selecting sample:
The sample size will depend on the frequency of the control being tested and the level of evidence
that is judged to be necessary, by the client and the engagement team. For this purpose the
engagement team should define the areas under scope as either High or Low risk
Performing audit procedures and Evaluating Test results:
When weaknesses in internal controls are identified we should consider whether there are any
compensating controls within the process or system. If we believe there are appropriate
compensating controls, we should extend the testing scope to include testing of these compensating
controls.


 Page 31
Section II - Internal Audit Tools
Need for Mathematical Tools
     To recognize early warning bells, as part of audit procedures, and
     protect business against fraud or error.

     Identify transactions that are indicative of fraud or error using
     tested and proven fraud & error detection techniques

     “Scientific” sample selection through automated procedures

     Reduced dependence on random sampling

     To Identify red flags at Financial Statements Level.




Page 33
Using Excel as a Tool
•     ‘IF’
•     ‘IF’ in combination with ‘AND’
•     ‘IF’ in Combination with ‘AND’ & ‘OR’
•     ‘CountIF’ and ‘SUMIF’
•     ‘SUMIFS’
•     ‘VLOOKUP’
•     Pivot Table Function
•     Setting Filters
•     Formula Auditing




    Page 34
Using Excel as a Tool (illustrative)
 Statistical Functions:

COUNT             Computes the number of numbers in a range

COUNTA            Computes the number of entries, including text entries in a
                  range

AVERAGE           Sums the numbers in a range and divides the total by the number
                  of numbers

MEDIAN            Computes the middle value in a range of numbers

MODE              Computes the value that occurs most frequently

VLOOKUP           Searches for a value in the leftmost column of a table, and then
                  returns a value in the same row from a column you specify in the
                  table.

PIVOT             Summarizes the columns of information in a database
                  relationship to each other.
  Page 35
Analyzing data in IDEA
Use of data analytics tools facilitates creating a virtual room where all relevant
audit content can be stored and accessed.




 Page 36
Section II - Reporting and Follow-up
Audit Report Structure
     Covering Letter
     Background/ Function Overview
     Purpose/ Objectives
     Scope of Work
     Audit Approach
     Limitation
     Executive Summary (Significant Findings)
     Detailed Observations
     Follow Up of Prior Recommendations




Page 38
Audit Report Structure
S.N      Priority   Issue                                Risk                  Performance            Management                Responsibility
o.                                                                             Improvement            Response                  / Timelines
                                                                               Observation

1        High       It was observed that in 48 out of    Incorrect    credit   The authority &        Adequate steps will be    Risk Team
                    60 cases (total population of 850    limit offered to      responsibility         taken up to ensure the
                    cases     for     credit     limit   customer leading      within the Risk        policy adherence by       March 2013
                    enhancement for period March-        to increased credit   Team should be         having        periodic
                    May,2012) the credit limits          risk exposure for     explicitly defined     process trainings for
                    enhanced for existing customers      the       Company,    & documented for       account management
                    was not as per the parameters        which          may    approving        the   team. The risk team
                    defined in the policy. Excess        eventually lead to    credit         limit   would      additionally
                    credit limit amounting to Rs         higher                increase               support the training
                    13.22 Lacs was given to              delinquencies.        deviations and the     requirements of the
                    customers. For details refer                               same should be         AMU team.
                    Annexure 1                                                 approved as per
                                                                               DOA.


2        High       Late Payment Charges amounting       Possibility      of   Business     should    The implementation of     Marketing
                    to Rs 1.3 Lacs were short-levied     Revenue leakage       evaluate         the   the revised LPC tier      Team
                    on 260 accounts and the same         for     LPC     and   possibility       of   from Rs.700 to Rs.750
                    was excess levied on 296             Customer              Implementing           was delayed by ~40        March 2013
                    accounts. Further, the Finance       dissatisfaction   /   continuous control     days due to set up
                    Charges on these accounts would      negative     impact   mechanism              miss, later identified
                    be incorrect as the LPC is not       on      brand     /   through        data    by pricing team and
                    accurately levied                    reputation            analytics tools and    rectified   on   12th
                                                                               System        Audit    November 2012.
                                                                               should be carried
                                                                               out.




    Page 39
Section II - Internal Audit and Fraud
Anti Fraud Control Framework


                            Code of conduct
                            Ethics policy
                            Gifts and hospitality
                            Agents
                            Facilitation payments

                                   Policy         Tone from top
          Cross culture                           Zero tolerance
          Disclosure         Voice       People   Board
          Openness                              responsibilities
          Employee/ suppliers    Process          Due diligence
                                                  Training
                                                  Education
                           Roles and responsibilities
                           Accountability
                           Annual sign off
                           Self assessment
                           Testing




Page 41
Fraud Prevention Strategy




Page 42
Thank You




 Page 43

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Approach note on internal audit [compatibility mode]

  • 1. Approach Note on Internal Audit CA. Deep Kumar Mendiratta
  • 2. Contents Sl. No. Particulars Page # Section I 1. Internal Audit - Basics 4 2. ERM Framework 6 3. Internal Audit Guidelines 9 4. Internal Audit Process, Approach & Methodology 14 Section II 1. Assessing Risks & Internal Controls 22 2. Internal Audit Sampling Methodology 29 3. Internal Audit Tools 32 4. Reporting and Follow-up 37 5. Internal Audit & Fraud 40 Page 2
  • 3. Section I - Why Internal Audit ?
  • 4. Internal Audit- Basics Definition of Internal Audit: Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization’s operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes. Objectives of Internal Audit: Risk Management Control Governance Risk: Risk is the potential that a chosen action or activity (including the choice of inaction) will lead to a loss (an undesirable outcome). The notion implies that a choice having an influence on the outcome sometimes exists (or existed). Internal Control: Internal Control is a process, effected by an entity’s board of directors, management, and other personnel, designed to provide reasonable assurance regarding the achievement of its objectives (Operational, Reporting & Compliance). Page 4
  • 5. Why Internal Audit ? CARO (Companies Require listed companies to have an internal audit system commensurate with its size and nature of business. To comply with the requirements (Auditor’s Report companies may either have an internal audit department or can outsource Order, 2003) the internal audit function to an external agency. Requires audit committee role to include oversight of the internal audit function as one of the terms of reference. The agreement requires the audit Clause 49 committee to review with management performance of internal audit function. Companies Act, Requires companies to appoint an auditor or auditors at every annual 1956 (Section general meeting to hold office from the conclusion of that meeting until the conclusion of next annual general meeting. 224) Page 5
  • 6. Section I – ERM Framework
  • 7. Enterprise Risk Management ERM defined: A process, effected by an entity's board of directors, management and other personnel, applied in strategy setting and across the enterprise, designed to identify potential events that may affect the entity, and manage risks to be within its risk appetite, to provide reasonable assurance regarding the achievement of entity objectives The key to effectively protecting and growing returns for an organization’s shareholders is to identify and manage the risks that could prevent the organization from achieving its business objectives. The enterprise risk assessment is an efficient, comprehensive process that provides insight on inherent risks from an industry perspective and links them to the organization’s objectives, initiatives, and business processes. Entity objectives can be viewed in the context of four categories: Strategic Operations Reporting Compliance Enterprise risk management requires an entity to take a portfolio view of risk. Management considers how individual risks interrelate and develops a portfolio view from two perspectives: Business unit level Entity level Page 7
  • 8. Enterprise Risk Management Framework Page 8
  • 9. Section I - Internal Audit Guidelines
  • 10. Compliance to Auditing Standards (ICAI) Standards on Internal Audits: • Standard on Internal Audit (SIA) 1, Planning an Internal Audit • Standard on Internal Audit (SIA) 2, Basic Principles Governing Internal Audit • Standard on Internal Audit (SIA) 3, Documentation • Standard on Internal Audit (SIA) 4, Reporting Adobe Acrobat • Standard on Internal Audit (SIA) 5, Sampling Document • Standard on Internal Audit (SIA) 6, Analytical Procedures • Standard on Internal Audit (SIA) 7, Quality Assurance in Internal Audit • Standard on Internal Audit (SIA) 8, Terms of Internal Audit Engagement • Standard on Internal Audit (SIA) 9, Communication with Management Page 10
  • 11. Compliance to Auditing Standards (ICAI) Standards on Internal Audits: • Standard on Internal Audit (SIA) 10, Internal Audit Evidence • Standard on Internal Audit (SIA) 11, Consideration of Fraud in an Internal Audit • Standard on Internal Audit (SIA) 12, Internal Control Evaluation • Standard on Internal Audit (SIA) 13, Enterprise Risk Management • Standard on Internal Audit (SIA) 14, Internal Audit in an Information Technology Environment • Standard on Internal Audit (SIA) 15, Knowledge of the Entity and its Environment • Standard on Internal Audit (SIA) 16, Using the Work of an Expert • Standard on Internal Audit (SIA) 17, Consideration of Laws and Regulations in an Internal Audit • Standard on Internal Audit (SIA) 18, Related Parties Page 11
  • 12. Compliance to Auditing Standards The IIA Standards types: a) Attribute Standards: address the attributes of organizations and individuals performing internal audit services. The attributes addressed are: Purpose, Authority and Responsibility Independence and Objectivity Proficiency and Due Professional Care Quality Assurance b) Performance Standards: describe the nature of internal audit services and provide quality criteria against which the performance of these services can be measured. The criteria addressed are: Managing Internal Audit Activity Nature of Work Engagement Planning Performing the Engagement Communicating Results Monitoring Progress Management’s Acceptance of Risk c) Implementation Standards: expand upon the Attribute and Performance Standards, providing guidance in specific types of engagements. Page 12
  • 13. Compliance to Auditing Standards (illustrative) S.N. Title of Standard 1 1000 - Purpose, Authority, and Responsibility 2 1010 – Recognition of the definition of Internal Auditing, the Code of Ethics, and the Standards in the Internal Audit Charter 3 1100 - Independence and Objectivity 4 1110 - Organizational Independence 5 1111 – Direct Interaction with the Board 6 1120 - Individual Objectivity 7 1130 - Impairments to Independence or Objectivity 8 1200 - Proficiency and Due Professional Care 9 1210 - Proficiency 10 1220 - Due Professional Care 11 1230 - Continuing Professional Development 12 1300 - Quality Assurance and Improvement Program 13 1310 - Quality Program Assessments 14 1311 - Internal Assessments 15 1312 - External Assessments Page 13
  • 14. Section I - Internal Audit Process
  • 15. IA Process Overview 1. Define 2. Validate 3. Execute 4. Retain 2.1 1.1 3.1 Request and receive Define objectives of Execute audit steps Data analysis 4.1 3.2 2.2 Document process 1.2 Identify discrepancies Validate Control reproduce data Gain an understanding Totals 3.3 4.2 1.3 Discuss discrepancies 2.3 Document Retention Define data with stakeholders and Perform data quality requirements validate errors Assessment 3.4 Assess impact on objectives Page 15
  • 16. Execution Process Overview Control Understand Gather Info Evaluate Evaluation the Process Control Develop Consider Reassess Scope Reassess Scope Sampling or Testing Test Plan Testing Substantive CAATs Testing Substantive Develop Sampling or Testing Testing Test Plan CAATs Formulate Assess Agree Action Findings Root Prioritize Plan with the Cause Management Page 16
  • 17. Evaluation Process Control Objective Risk Microsoft Office Excel 97-2003 Worksheet Is Is a there a Control in NO mitigating NO Missing Controls Place? Control ? And in the appropriate timeframe? Yes Yes Missing / Assess Mitigation Mitigated Controls Does the control address the NO Inadequate Controls e.g. Are all relevant risk? attributes covered Yes Determination on Adequacy of Control Design Page 17
  • 18. Risk and Control Matrix Sub Documents to be Conclusion Sr. What Can Go Process Process/ Control Description Test Procedures Referred for Test (Effective / No. Wrong (Risk) Activity Procedures Ineffective) 1 Client Quantity • Incorrect quantity • Quantity assessment • Obtain the latest • Measurement Billing Assessment assessment by the is done against the Project Review Report sheets from the site (Invoicin & Work billing engineer schedule of work (PRR) and Daily Progress • PRR and DPR g& leading to under- (target billing) and the Report (DPR) for the • Raised RA Bills and Collectio billing to the client actual work carried out period under review certified RA Bills n) • Incorrect quantity at the site • Select sample RA Bills assessment by the • The quantity and review whether billing engineer assessment is also cross related records certifying leading to over- checked against the the completion of billing to the client MPR/DPR (Prepared by measured work are the planning maintained department who inturn • Ensure measured works get the data from are strictly in accordance execution department with scope of work and and sub-contractors/ any variation is vendors) seperately parked as 'Extra Work/Item' • Quantities for billing are supported by site measurements/Stock consumption and issuance records Page 18
  • 19. Steps to Follow after identifying a Finding • Discuss and validate errors with responsible stakeholders and process owners • Consider whether there are any compensating controls within the process or system, and extend the testing scope, if necessary • Assess impact - Whether or not the objectives of the test have been met and if alternative measures need to be taken • Evaluate Exceptions or Errors Identified during Controls Testing for the following: i. Potential Effect on control objectives ii. Incidence, or level of error iii. Cause of the control breakdown iv. Actual Effect, if applicable Page 19
  • 20. Elements of a Finding Criteria: Provides a context for evaluating evidence and understanding the findings (Control Objectives) • Policies & Procedures (Expectations of what should exist) • Contracts & Agreements • Laws & Regulations • Standards & Benchmarks • Defined business practices or measures which performance is compared or evaluated against Condition: Condition is a situation that exists or what was occurring when the control weakness was identified i.e. The Exception or Deficiency Cause: Identifies the reason for the condition or the factor(s) responsible for the difference between the situation that exists (condition) and the required or desired state (criteria), Common factors include; poorly designed policies, procedures, or criteria, inconsistent, incomplete, or incorrect implementation, segregation of duties or business conditions. Effect or Risk Impact: A clear, logical link to establish the impact or potential impact of the difference between the situation that exists (condition) and the required or desired state (criteria), which identifies the outcomes or consequences of the condition. Effect or risk impact may be used to demonstrate the need for corrective action in response to identified condition. Page 20
  • 21. Recommendations • Should address the root cause not just the symptoms • Be relevant and practical • Compare the benefits to costs • More than 1 recommendation may be required to completely address an issue • Use best practices as a source for creative insight, adapting to the needs of the organization Example: Audit Objective: Evaluate and Document Credit limit Increase Procedures Risk/Control Objective: Credit Limit Increase are manually reviewed and approved prior to processing the request in the system Sample Selection: 15 credit limit increase accounts from a system generated report Documents Obtained: Credit limit increase MIS and the credit limit increase delegation of authority and Income documents Exceptions noted: 3 of 15 credit limits increases were not reviewed and approved per the delegation of authority and excess credit limit was granted to customers. Page 21
  • 22. Section II - Assessing Risks & Internal Controls
  • 23. Internal Control Structure In many cases, you perform controls and interact with the control Monitoring: structure every day • Monthly reviews of performance reports • Internal audit function MONITORING Information & Communication: • Vision and values INFORMATION AND • Issue resolution calls COMMUNICATION • Reporting • Corporate communications (e- Control Activities: mail, meetings) CONTROL ACTIVITIES • Credit limits • Approvals • Security Risk Assessment: • Block Codes / RISK ASSESSMENT • Monthly Risk Control meetings policies • Internal audit risk assessment CONTROL ENVIRONMENT Control Environment: • Tone from the top • Corporate Policies • Organizational authority An internal control structure is simply a different way of viewing the business – a perspective that focuses on doing the right things in the right way. Page 23
  • 24. Concepts and Objectives Control definition reflects certain fundamental concepts: Internal control is a process Internal control is effected by people. It's not merely policy manuals and forms, but people at every level of an organization. Internal control can be expected to provide only reasonable assurance, not absolute assurance, to an entity's management and board. Objectives of Internal Control Internal controls are established to further strengthen: The reliability and integrity of information. Compliance with policies, plans, procedures, laws and regulations. The safeguarding of assets. The economical and efficient use of resources. The accomplishment of established objectives and goals for operations or programs. Page 24
  • 25. Control Techniques Prevention techniques are designed to provide reasonable assurance that only valid transactions are recognized, approved and submitted for processing. Therefore, many of the preventive techniques are applied before the processing activity occurs. In most situations, preventive techniques are likely to be more effective in a strong control environment, when management authorization criteria are well-defined and properly communicated. Control type definitions: Preventive - Manual Preventive - System Examples of preventive controls include: • Segregation of duties (Preventive-Manual) • Business systems integrity and continuity controls, e.g., application design standards, change controls, security controls, systems backup and recovery (Preventive – System) • Physical safeguard and access restriction controls (human, financial, physical and information assets) (Preventive-Manual) • Effective "whistle blowing" processes (Preventive-Manual) Page 25
  • 26. Control Techniques Detection techniques are designed to provide reasonable assurance that errors and irregularities are discovered and corrected on a timely basis. Detection techniques normally are performed after processing has been completed. They are particularly important in an environment that has relatively weak preventive techniques. That is, when front-end approval and processing techniques do not provide reasonable assurance that unacceptable transactions are prevented from being processed or do not assure that all approved transactions are processed accurately. In this case, after-the-fact techniques become more important in detecting and correcting processing errors. Control type definitions: Detective - Manual Detective - System Examples of detection techniques include: • Reconciliation of batch balance reports to control logs maintained by originating departments. (Detective – Manual) • Review and approval of reference file maintenance (“was-is”) reports. (Detective – Manual) • Reconciliation of interface amounts exiting one system and entering another. (Detective – System) • Review of on-line access and transaction logs. (Detective – System) Page 26
  • 27. Risk Analysis Risk Analysis Risk Risk Risk Assessment Management Monitoring Process Identification Control It Level Share or Activity Measurement Transfer It Level Diversify or Prioritization Entity Level Avoid It Page 27
  • 28. Role of a Process Owner General Expectations • Acknowledge the responsibility for the design, implementation and maintenance of the control structure within the business processes • Contribute direction to identify, prioritize and review risks and controls • Remove obstacles for compliance; remedy control deficiencies • Continue or begin a program of self-assessment and testing to monitor the controls within the processes • Quarterly - confirm key controls are implemented and effective - maintain documentation to support this assessment Immediate Action Items • Educate personnel about the requirements and effort • Reinforce internal focus on controls within the process • Surface any risks, concerns or issues promptly to allow adequate attention for correction (don’t wait for an audit) • Fix control gaps within reasonable timescales Page 28
  • 29. Section II - Internal Audit Sampling
  • 30. Sampling Population: The entire set of universe from which a sample is selected & reviewed, and about which the auditor wishes to draw conclusions. Data availability for population: An important aspect in sample selection is the availability of data. Depending upon the population, entire data may or may not be available. In cases where entire data is not available, same should be brought to the attention of the Management, be agreed with the stakeholders and be clearly mentioned as a scope limitation. Systematic selection: A systematic approach is used by the auditor to select items, to minimize any potential human judgment or bias. Every nth item within the population is selected in accordance with a defined sampling interval. Haphazard selection: The auditor, without any conscious bias, selects sample items randomly, i.e., without any special reason for including or omitting items from the sample Stratification: Prior to carrying out analytical procedures, it is important to stratify / classify the data into separate logical sections. This classification would not only help in analyzing trends unique to that particular category but would also help in assessing materiality while selecting a sample. Page 30
  • 31. Sampling Perform Analytical procedures: Analytical procedure is defined as an evaluation of financial information made by a study of plausible relationships among both financial and non-financial data Analyse abnormal transactions: If the analytical procedures highlight certain abnormal transactions (where there are significant aberrations), they should be separated and reviewed separately. Such transactions should be reviewed in addition to the regular sample selected. Using Excel / CAAT: In case the testing objective can be applied by using excel / CAAT on the entire population, audit procedures should be performed on the entire population else samples should be selected for testing Determining sample size and selecting sample: The sample size will depend on the frequency of the control being tested and the level of evidence that is judged to be necessary, by the client and the engagement team. For this purpose the engagement team should define the areas under scope as either High or Low risk Performing audit procedures and Evaluating Test results: When weaknesses in internal controls are identified we should consider whether there are any compensating controls within the process or system. If we believe there are appropriate compensating controls, we should extend the testing scope to include testing of these compensating controls. Page 31
  • 32. Section II - Internal Audit Tools
  • 33. Need for Mathematical Tools To recognize early warning bells, as part of audit procedures, and protect business against fraud or error. Identify transactions that are indicative of fraud or error using tested and proven fraud & error detection techniques “Scientific” sample selection through automated procedures Reduced dependence on random sampling To Identify red flags at Financial Statements Level. Page 33
  • 34. Using Excel as a Tool • ‘IF’ • ‘IF’ in combination with ‘AND’ • ‘IF’ in Combination with ‘AND’ & ‘OR’ • ‘CountIF’ and ‘SUMIF’ • ‘SUMIFS’ • ‘VLOOKUP’ • Pivot Table Function • Setting Filters • Formula Auditing Page 34
  • 35. Using Excel as a Tool (illustrative) Statistical Functions: COUNT Computes the number of numbers in a range COUNTA Computes the number of entries, including text entries in a range AVERAGE Sums the numbers in a range and divides the total by the number of numbers MEDIAN Computes the middle value in a range of numbers MODE Computes the value that occurs most frequently VLOOKUP Searches for a value in the leftmost column of a table, and then returns a value in the same row from a column you specify in the table. PIVOT Summarizes the columns of information in a database relationship to each other. Page 35
  • 36. Analyzing data in IDEA Use of data analytics tools facilitates creating a virtual room where all relevant audit content can be stored and accessed. Page 36
  • 37. Section II - Reporting and Follow-up
  • 38. Audit Report Structure Covering Letter Background/ Function Overview Purpose/ Objectives Scope of Work Audit Approach Limitation Executive Summary (Significant Findings) Detailed Observations Follow Up of Prior Recommendations Page 38
  • 39. Audit Report Structure S.N Priority Issue Risk Performance Management Responsibility o. Improvement Response / Timelines Observation 1 High It was observed that in 48 out of Incorrect credit The authority & Adequate steps will be Risk Team 60 cases (total population of 850 limit offered to responsibility taken up to ensure the cases for credit limit customer leading within the Risk policy adherence by March 2013 enhancement for period March- to increased credit Team should be having periodic May,2012) the credit limits risk exposure for explicitly defined process trainings for enhanced for existing customers the Company, & documented for account management was not as per the parameters which may approving the team. The risk team defined in the policy. Excess eventually lead to credit limit would additionally credit limit amounting to Rs higher increase support the training 13.22 Lacs was given to delinquencies. deviations and the requirements of the customers. For details refer same should be AMU team. Annexure 1 approved as per DOA. 2 High Late Payment Charges amounting Possibility of Business should The implementation of Marketing to Rs 1.3 Lacs were short-levied Revenue leakage evaluate the the revised LPC tier Team on 260 accounts and the same for LPC and possibility of from Rs.700 to Rs.750 was excess levied on 296 Customer Implementing was delayed by ~40 March 2013 accounts. Further, the Finance dissatisfaction / continuous control days due to set up Charges on these accounts would negative impact mechanism miss, later identified be incorrect as the LPC is not on brand / through data by pricing team and accurately levied reputation analytics tools and rectified on 12th System Audit November 2012. should be carried out. Page 39
  • 40. Section II - Internal Audit and Fraud
  • 41. Anti Fraud Control Framework Code of conduct Ethics policy Gifts and hospitality Agents Facilitation payments Policy Tone from top Cross culture Zero tolerance Disclosure Voice People Board Openness responsibilities Employee/ suppliers Process Due diligence Training Education Roles and responsibilities Accountability Annual sign off Self assessment Testing Page 41