LIBERTY UNIVERSITY INTERNAL AUDIT DEPARTMENT CHARTER INTRODUCTION: The Internal Audit Department Charter defines the purpose, authority, and responsibility of the Internal Audit Department (Internal Audit) at Liberty University (University) and management’s commitment to the professional practice of internal auditing. It grants Internal Audit the authority to carry out its mission as directed by the Audit Committee of the Board of Trustees (Committee). MISSION: Internal Audit is an independent and objective assurance and consulting activity guided by a philosophy of adding value and improving the University’s operations. Internal Audit assists the University in accomplishing its strategic objectives by bringing a systematic and disciplined approach to examining and evaluating the adequacy and effectiveness of its governance, risk management, and internal control processes. AUTHORITY: Internal Audit has full authority to perform examinations, audits, and investigations of all operations, activities, affairs, and financial records of the University. Internal Audit, with strict accountability for confidentiality and safeguarding of records and information, is authorized complete and unrestricted access to all University records, reports, activities, physical properties, and personnel pertinent to carrying out any engagement. Internal Audit will also have complete and unrestricted access to the Committee. PROFESSIONALISM: Internal Audit is governed by the Institute of Internal Auditors’ Definition of Internal Auditing, Code of Ethics, and International Standards for the Professional Practice of Internal Auditing (Standards). This mandatory guidance constitutes principles of the fundamental requirements for the professional practice of internal auditing and for evaluating the effectiveness of Internal Audit’s performance. In addition, Internal Audit will adhere to its standard operating procedures manual, the University’s policies and procedures, and applicable laws and regulations. Internal Audit personnel will maintain sufficient knowledge, skills, experience, and other competencies necessary to perform its responsibilities through continuing education activities. ORGANIZATION: The University’s Manager of Internal Audit (Manager) serves as the “Chief Audit Executive” as defined by the Standards. The Manager reports functionally to the Committee and administratively to the Chief Financial Officer. This reporting relationship ensures Internal Audit is independent and free of influence from any element in the University. The Committee will: • Approve the Internal Audit charter and risk-based annual audit plan. • Approve the Internal Audit budget and resource plan. • Receive reports on Internal Audit’s performance relative to the audit plan as well as any other activities and matters. • Make inquiries of management and Internal Audit to determine whether there are inappropriate scope or resource limitations. LIBERTY UNIVERSITY INTERNAL AUDIT DEPARTMENT CHARTER The Manager will communicate and interact directly with the Committee including executive sessions and between Committee meetings as appropriate. INDEPENDENCE AND OBJECTIVITY: Internal Audit will remain free from interference by any element in the University regarding matters of audit selection, scope, procedures, frequency, timing, or report content to maintain the independence and objectivity required in both fact and appearance. The Manager will confirm to the Committee, at least annually, the organizational independence of Internal Audit. Internal Audit will have no direct operational responsibility or authority over any of the activities audited. Accordingly, Internal Audit will not implement internal controls, develop procedures, install systems, prepare records, or engage in any other activity that may impair judgment. Internal Audit will exhibit the highest level of professional objectivity in gathering, evaluating, and communicating information about the activity or process being examined. Internal auditors will make a balanced assessment of all the relevant circumstances and not be unduly influenced by their own interests or by others in forming judgments. RESPONSIBILITY: The scope of Internal Audit encompasses but is not limited to: • Evaluating the risk exposure related to achievement of the University’s strategic goals and objectives. • Evaluating the reliability and integrity of financial and operating information and the means used to identify, measure, classify, and report such information. • Evaluating new and established systems and modifications to ensure adequate internal controls and compliance with University policies and procedures, laws, and regulations. • Evaluating the means of safeguarding assets and verifying the existence of such assets. • Evaluating the effectiveness and efficiency with which resources are employed. • Evaluating the efficiency and quality of University operations including identifying opportunities to improve operating performance. • Monitoring and evaluating governance processes and the effectiveness of the University’s risk management processes. • Evaluating the performance of external auditors and the degree of coordination with Internal Audit. • Performing consulting and advisory services related to governance, risk management, and controls as appropriate for the University. • Reporting periodically on Internal Audit’s purpose, authority, responsibility, and performance relative to its plan. • Reporting significant risk exposures and control issues including fraud risks, governance issues, and other matters needed or requested by the Committee. • Evaluating specific operations at the request of the Committee, Board, or management. LIBERTY UNIVERSITY INTERNAL AUDIT DEPARTMENT CHARTER INTERNAL AUDIT PLAN: Annually, the Manager will submit an internal audit plan to the Committee for review and approval. The plan will consist of a work schedule as well as budget and resource requirements for the next fiscal year. The Manager will communicate the impact of any resource limitations to the Committee. The internal audit plan will be developed based on a prioritization of the audit universe using a risk-based methodology, including input of senior management and the Committee. The Manager will review and adjust the plan in response to changes in the University’s business, risks, operations, programs, systems, and controls. Any significant deviation from the approved internal audit plan will be communicated to the Committee through periodic activity reports. The Manager will communicate with the external auditors to foster a cooperative working relationship and reduce duplication of effort while ensuring appropriate sharing of information and coordination of overall audit effort. REPORTING AND MONITORING: A written report will be prepared and issued by Internal Audit following the conclusion of each engagement and will be distributed to senior management and the Committee. The report will include management’s responses and corrective action plans regarding the specific findings and recommendations. Management’s responses will include a timetable for anticipated completion of action plans and explanation for any corrective action not implemented. Internal Audit will be responsible for appropriate follow-up on engagement findings and recommendations. All significant findings will be shared with the Committee and remain open until cleared. QUALITY ASSURANCE AND IMPROVEMENT PROGRAM: Internal Audit will maintain a quality assurance and improvement program covering all aspects of Internal Audit. The program will include an evaluation of Internal Audit’s conformance with the Definition of Internal Auditing and the Standards, and an evaluation of whether the internal auditors apply the Code of Ethics. The program also assesses the efficiency and effectiveness of Internal Audit and identifies opportunities for improvement. The Manager will communicate to senior management and the Committee on Internal Audit’s quality assurance and improvement program, including results of internal and external assessments. Approved by the Audit Committee November 6, 2014