April 2012 Internal Audit Introduction Recent events including global financial crises have emphasised need for internal auditing within corporate governance structures Internal audit function is now mandatory by most stock exchanges Donors increasingly demand improved accountability & financial transparency in development projects IFAD procedures do not specifically require internal audit, however, IFAD Operational Procedures for Project Audits (for use by IFAD & CIs) require that “as part of the assessment of the borrower’s capacity to implement and manage the project effectively, the appraisal mission will evaluate any internal audit (IA) mechanism for the project/ PMU” Furthermore, internal audit is considered good practice & advisable as part of underlying control framework & financial management capacity of a project, particularly if complex &/ or decentralised 1 Definition “Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization's operations. It helps an organisation accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes. ” The Institute of Internal Auditors 2 IA – Code of Ethics Principles Internal auditors are expected to apply & uphold the following principles: Integrity The integrity of internal auditors establishes trust & so provides the basis for reliance on their judgment Objectivity Internal auditors exhibit the highest professional objectivity in gathering, evaluating & communicating information. Internal auditors make a balanced assessment of all relevant circumstances & are not unduly influenced by their own interests or others in forming judgments Confidentiality Internal auditors respect the value and ownership of information they receive & do not disclose information without appropriate authority unless there is a legal or professional obligation to do so Competency Internal auditors apply knowledge, skills, & experience needed 3 What is Internal Audit? Internal Audit is a professional activity which helps organisations to achieve their stated objectives by: Analyzing key processes, procedures & operations Identifying key controls in each such operation, procedure & process Evaluating the adequacy of these controls Testing compliance of sample transactions against these controls Reporting results of the evaluation of controls and compliance testing of transactions Recommending stronger controls wherever necessary Suggesting methods to improve compliance with key controls Follow up of action taken on recommendations made in previous reports 4 What are Internal Controls? Internal Controls are important checks instituted by management to have reasonable assurance that: Operations are carried out in an efficient & effective manner Transactions are recorded accurately & completely Assets are properly recorded & safeguarded Laws are complied with Reliable reports are generated 5 Some examples of Internal Control ► Budgetary Control ► Fixed Assets Register ► Bank & Special Account Reconciliations ► Reconciliation of Financial & Physical M & E Reports 6 How are Internal Audit & External Audit different? Internal audit is focused at internal management support and improving systems, procedures and processes ⇉ External audit (EA): normally statutory requirement, unlike internal audit (IA) ⇉ EA reports are addressed to stakeholders: IA reports are addressed to Management ⇉ EA reports express an opinion on the financial statements prepared by the entity for a specified period: IA reports evaluate and check compliance against key internal controls ⇉ EA reports are usually public documents which are available to all stakeholders. IA reports are for use only by Management ⇉ EA reports do not make recommendations, although may have a Management Letter: IA reports are incomplete without ⇉ EA is basically a review of financial statements for compliance: IA seeks to ensure value for money to Management 7 Why should IFAD funded projects be subject to IA? IFAD funded projects may be subject to Internal Audit because: External audit checks overall compliance to internal controls related to financial transactions. Supervision Missions conduct only spot checks. Internal audit is inherent in government structures in most developing countries. Sample IA Terms of Reference enclosed IA has a key role in Risk management of IFAD Projects 8 What are key concerns from a FM viewpoint? ► ► ► ► ► ► ► ► ► ► ► Is the accounting system capable of recording financial transactions in a timely & accurate manner? Is the accounting system capable of tracking project expenditure by category & component? Is the accounting system capable of comparing actual expenditure to budget as per approved AWPB on a real time basis? Are withdrawal applications prepared properly & do they contain ineligible expenditures? Are procurement transactions undertaken as per Schedule 4 &/or LTB of the financing agreement? Are project assets properly recorded & safeguarded from misuse and abuse? Are Special Account & Project Account operated & reconciled properly & timely? Are proper audit arrangements in place? Are audit reports properly followed up? Does the project generate reliable & accurate financial statements & reports? Are project funds flowing smoothly, timely & transparently to intended beneficiaries? 9 Internal Audit (IA) Mandate Compliance & Advisory roles What does it do? Primary role in improving internal control, accuracy, reliability & integrity of information including financial & operational reporting Monitoring & evaluation of effectiveness of risk management processes Role in corporate oversight, safeguarding of assets, economical & efficient use of resources, compliance with laws & regulations, deterring fraud What does it not do? Perform management activities/ responsibilities (these include establishing internal controls) 10 Internal Control Myths and Facts MYTHS: FACTS: Internal control starts with a strong set of policies and procedures Internal control starts with a strong set of policies and procedures Internal control: That’s why we have internal auditors! While internal auditors play a key role in the system of control, management has responsibility for internal control Internal control is a finance thing Internal control is integral to every aspect of business/operations Internal controls are essentially negative, like a list of “thou-shalt-nots” Internal control makes the right things happen the first time Internal controls take time away from our core activities of implementing development objectives Internal controls should be built “into,” not “onto” business processes 11 Internal Control Practices How? Internal control is a process. It's a means to an end, not an end in itself Internal control is effected by people as a team, not by internal auditor. It's not merely policy manuals & 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 governing bodies/ committees Uses systematic methodology processes, procedures & activities for analysing business The cost of IA should not exceed expected benefits to be derived 12 Internal Control Structure An internal control structure is simply a different way of viewing operations – a perspective that focuses on doing the right things in the right way • Monthly reviews of performance reports • Supervisory activities • • • • • Purchasing limits Approvals/ segregations Security Reconciliations Proper operating & accounting procedures • Reporting • Corporate communications (e-mail, meetings) MONITORING INFORMATION AND INFORMATION & COMMUNICATION COMMUNICATION CONTROL ACTIVITIES CONTROL ACTIVITIES • Based on identification & analysis of risks to achievement of objectives RISK ASSESSMENT CONTROL ENVIRONMENT • • • • Corporate Policies Tone at the top, ethics Organisational authority Skilled personnel In many cases, you perform controls and interact with the control structure every day, perhaps without even realising it 13 Role in Risk Management Focus on risk of occurrences that could prevent the project from achieving its goals There are many types of risk – strategic, operational, financial reporting, legal/regulatory, fraud, ineffective/inefficient technological, human capital, credibility, etc. use of resources, Focus on areas with high risk & high probability that controls are not in place or are weak Don’t forget positive risks – opportunities! Add value by eliminating unnecessary controls, if underlying risks are minimal/within project’s risk appetite! 14 Role in Internal Control 1. Compliance audit: review of financial & operating controls & transactions for conformity with laws, regulations & procedures, e.g., • • • • • • Access to IT system appropriate to user’s role Segregation of duties in high risk areas Balancing & reconciliation between systems Systems back up & recovery Physical safeguard & access restriction controls Reconciliations, comparison budget of actual 2. Operational audit: review of various functions within project to evaluate efficiency, effectiveness, & economy 15 IA Role in Corporate Oversight Four pillars – internal audit, executive management, external audit, & Board of directors/ steering committee Combination of processes & organisational structures implemented by management to inform, direct, manage and monitor the project’s resources, strategies & policies towards the achievement of its objectives Public sector governance Principles - transparency, integrity, accountability May include review of sufficiency of human resources, training needs, policies, etc. 16 Nature of Internal Audit Activity Establish scope & activities for audit to Management Develop & execute risk based sampling & testing approach to determine whether most important controls are operating as intended (NB: input from Management required – e.g. 100% sampling of WA review) Report issues/make recommendations/negotiate action plans with Management to address issues Follow up on reported findings periodically Describe key risks facing the business activities within scope of audit Identify control procedures used to ensure each key risk is properly controlled & monitored 17 Contents of Audit Plan Updated annually Risk based audit plan developed with input from project staff including Management Summary of key goals, risks & corresponding major audits, to illustrate alignment Based on risk assessment & available resources Appendix materials, such as planning approach, assumptions & brief descriptions of all planned audits & related prioritization Approved by management/ appropriate oversight Committee 18 Contents of Audit Report Observations Narration/ description Remedial action Consequences/ fall out Recommendation for improvement (prioritized between “high” and “normal”) Response (action plan) – who, when and how 19 IA’s Proactive Role Identify Risks Find Better Ways and Best Practices Partner With Management to Find Solutions Prevent Problems Provide training Respond to policy & technical accounting questions Offer suggestions for improvement Advisory role 20 Additional Resources 21 Conclusion Why all this trouble? Additional comfort and “tightness” that the project is doing the right thing, the first time, communicating right information internally, to external auditors, donors, ministries, etc. More formal control structures reduce possibility that risks become real issues External Auditor may receive additional assurance to provide unqualified report on accounts Donor & government confidence increased, affecting financing flows What are the next steps? Identify areas of high risk & opportunities Validation of process documentation & controls Communication, with PCs & project staff 22