Developing the internal audit strategic plan 6 June 2013 Martin Robinson, Chartered Institute of Internal Auditors David Butler, Head of Internal Audit, Unum James Paterson, Director, Risk and Assurance, Insights Setting the scene – IIA guidance and October 2012 benchmarking survey Martin Robinson Training Development Adviser, Chartered Institute of Internal Auditors Definition of strategy Strategy is a means of establishing the organisation’s purpose and determining the nature of the contribution it intends to make while predefining choices that will shape decisions and actions. Strategy for the internal audit activity enables the allocation of financial and human resources to help achieve these objectives as defined in the activity’s vision and mission statements. Steps to be used to develop the internal audit strategic plan Factors influencing the frequency of reviewing the strategic plan Performing a SWOT analysis The key variables when developing a sourcing model Heads of internal audit benchmarking report – Internal audit strategic plans August/September 2012 Key issues Developing an internal audit strategic plan Some practical tips and experiences IIA Heads of Audit Forum June 2013 David Butler 9 Developing the internal audit strategic plan TOPIC AREAS ˜ Introduction ˜ The importance of communication ● Understand the importance and reliance placed upon a modern Internal audit function through the stakeholders eyes ● Ensuring that you are receiving clear messaging from your stakeholders? ˜ Understand the complexity of the matrix management of dealing with diverse and increasing stakeholder expectations ˜ Elements of the strategic plan: ● What are the top priorities for the Internal audit function? ● Build an internal audit strategy that focuses on stakeholder raising expectations 10 IPPF Practice Guide – Developing the Internal Audit Strategic Plan CRITICAL SUCCESS FACTORS The Three P’s Positioning – Is the internal audit activity strategically positioned and supported? Processes – Are the internal audit activity’s processes enabling and dynamic in meeting business needs? People – Does the internal audit activity have the right people strategy to deliver its mission? 11 Understand the importance and reliance placed upon a modern Internal audit function through the stakeholders eyes THE FOUNDATION STONES ˜ Do you have a stakeholder map for Internal Audit? ˜ Are your team aware of the stakeholder needs or purely focussed upon delivery of the plan? ˜ Do you and your team understand the different needs of the varying stakeholders? ˜ What does Internal Audit deliver is it assurance or is it protection as has been suggested by the recent UK IIA consultation document? ˜ How do we maintain credibility with each of these stakeholders – their needs seem to conflict at one level? 12 Unum UK Stakeholder Map and Offerings 2012 MODEL 13 Ensuring that you are receiving clear messaging from your stakeholders? BALANCING YOUR STAKEHOLDERS ˜ Is there strong engagement between the Chief Auditor and the Audit Committee Chairman and Audit Committee generally? ˜ What role does Internal Audit play in your organisation with the regulator(s)? ˜ Who is responsible for defining and agreeing the Audit Plan? ˜ Are we forward looking or purely retrospective? ˜ Do the stakeholder requirements conflict – which areas are a priority for us to review? ˜ How is that changing or may change? 14 Understand the complexity of the matrix management of dealing with diverse and increasing stakeholder expectations CAN AND SHOULD WE ADDRESS ALL STAKEHOLDER REQUIREMENTS? 15 Audit function status and positioning? ASSESSING THE CURRENT STATE ˜ What is the status of the Chief Auditor and the audit function? ● Organisationally ● By reputation ● Through engagement ˜ Are stakeholders? ● Advocates ● Neutral ● Negative ˜ What style of internal audit does your function deploy? ● Collaborative ● Adversarial ● Combination ˜ Does that style vary depending upon the maturity of the organisation? 16 What methods and techniques will enable you to improve engagement? HOW PLUGGED IN IS INTERNAL AUDIT TO THE CORPORATE DNA? ˜ Is the Internal Audit function appropriately engaged with the business and direction of the business ● Who in the IA function considers their role as stakeholder champions ˜ What is the Internal Audit’s circle of influence ? ● Board and Audit Committee ● Risk Committee ● Executive Committee ● Executive Risk Committee ● Senior management ● Regulator(s) ● Others? 17 What are the top priorities for the Internal audit function? SCOPE AND IMPACT OF WORK ˜ Are there any audit no go areas ● These can result from management resistance ● Lack of appropriate skills or resources ˜ Is audit engaged in evaluation of all processes? ● Strategy ● Major projects ● Mergers and acquisitions ● Financial reporting ● Operational areas ● Marketing and sales ● IT ˜ Are agreed management action plan promises delivered? ● Does anyone or everyone care? 18 Build an internal audit strategy that focuses on stakeholder raising expectations RESPONSIVENESS OF PLAN ˜ What is the time horizon that Internal Audit operates to? ● 3 months ● Annual ● Two year ● Longer than two years ˜ What inputs do you have to help define and assess the areas that audit will operate? ● Dynamic audit universe ● Mature risk management ● Trusted compliance and risk monitoring ● SOX or other assurance feeds ● Industrial networking and feeds of emerging issues ˜ Does your plan feel predictable or responsive? 19 Build an internal audit strategy that focuses on stakeholder raising expectations DELIVERY ENABLERS ˜ How does the resource model refine and match the longer term needs of the function and the organisation? ˜ Is outsourcing or co-sourcing the answer to the resource squeeze? ˜ What skills does your function have available to it on a day to day basis? ● Qualified accountants / auditors ● IT capability ● Actuarial ● Marketing and sales ● Deep operational experience ˜ How strong are the information feeds within the organisation to Internal Audit? 20 Hierarchy of audit positioning documentation OFFICIAL DOCUMENTATION ˜ Audit Committee Terms of Reference ˜ Internal Audit Charter ˜ Vision and Values Statement ˜ Mission Statement ˜ Strategic Plan ˜ Audit Manual ● Annual Plan o Technology and tools o Resourcing model o What’s in and what’s not ● Audit Engagements But …… it never stops……….. 21 Continuing evolution not revolution CURRENT WORK IN PROGRESS Enterprise Audit 2013 Workstreams Relationship Management People and Talent Performance Management Internal Communications Internal Audit Process 22 David Butler david.butler@unum.co.uk Tel : 0044 1306 874270 Contact via LinkedIN Twitter @DJBAudit Questions 23 Other Materials Developing the Internal Audit Strategic Plan – July 2012 Guidance http://www.iia.org.uk/media/56050/developing_the_internal_audit_stra tegic_plan.pdf 24 Other Materials DEVELOPING THE INTERNAL AUDIT STRATEGIC PLAN – JULY 2012 GUIDANCE (EXTRACT) The following steps can be used to develop the internal audit strategic plan: 1. Understand the relevant industry(ies) and the organization’s objectives. 2. Consider the International Professional Practices Framework (IPPF). 3. Understand stakeholder expectations. 4. Update the internal audit vision and mission. 5. Define the critical success factors. 6. Perform a strengths, weaknesses, opportunities, and threats (SWOT) analysis. 7. Identify key initiatives. 25 Other Materials ERNST AND YOUNG Ernst and Young Survey Develop a well aligned internal audit strategy ˜ http://www.ey.com/GL/en/Services/Advisory/The-future-of-internal-audit-is-now--Develop-a-well-aligned-internal-audit-strategy ˜ Unlocking the strategic value of Internal Audit - 2010 ˜ http://www.ey.com/Publication/vwLUAssets/Unlocking_the_strategic_value_of_Internal_ Audit/$FILE/Unlocking%20the%20strategic%20value%20of%20Internal%20Audit.pdf 26 Other Materials CHARTERED INSTITUTE OF INTERNAL AUDITORS Heads of Internal Audit Benchmarking Report Internal Audit Strategic Plans http://www.iia.org.uk/media/195007/2._benchmarking_report_internal_audit_strategic_plan ning_oct_2012_1_.pdf 27 “Because….” Developing an audit strategy Experiences in AZ and to date What the future might hold.. James C Paterson Director, Risk & Assurance Insights Ltd. AZ experiences Many customers, limited supply = problem Latest research ~ Booz & Co - 2013 AZ Strategy – Mark 1 ingredients Sources of value destruction Audit Directors Roundtable Key risks and IA plan Auditing harder to audit areas Improving skills mix Benchmarking /EQA AZ Strategy – Outputs IA plan vs risks and assurances IA development Governance & Risk Operational controls Compliance & IT controls Financial controls 1980s 1990s 2000s Developed from ADR idea Today Strategy for what IA covers Year 1 Year 2 Year 3 Year 4 Financial Controls 35 30 25 20 Compliance 35 35 30 25 Operational Controls 20 20 20 25 Strategic risks 10 15 25 30 TOTAL 100 100 100 100 Setting out, in broad terms the likely shape of the plan IA planning ~ Lean / Assurance approach 2* 11 1 5* 4* 3 7 6 8 10 9 12 1 – SR 2 – CR 3 – SR 4 – OR 5 – FC 6 – OR 7 – OR 8 – CR 9 – OR 10 – OR 11- OR 12 – OR IA Coverage (initial views) = Red 2* 11 1 5* 4* 3 7 6 8 10 9 12 1 – SR 2 – CR 3 – SR 4 – OR 5 – FC 6 – OR 7 – OR 8 – CR 9 – OR 10 – OR 11- OR 12 – OR Who is looking at the other areas? 2* 11 1 5* 4* 3 7 6 8 10 9 12 1 – SR 2 – CR 3 – SR 4 – OR 5 – FC 6 – OR 7 – OR 8 – CR 9 – OR 10 – OR 11- OR 12 – OR Capture Other Assurances + 2* 11 1 5* 4* +3 +7 6 8 +10 9 12 1 – SR 2 – CR 3 – SR 4 – OR 5 – FC 6 – OR 7 – OR 8 – CR 9 – OR 10 – OR 11- OR 12 – OR Past coverage? 2* 11 1 5* 4* +3 +7 6 8 +10 9 12 1 – SR 2 – CR 3 – SR 4 – OR 5 – FC 6 – OR 7 – OR 8 – CR 9 – OR 10 – OR 11- OR 12 – OR Where do you draw the line? 2* 11 1 5* 4* +3 +7 6 8 +10 9 12 1 – SR 2 – CR 3 – SR 4 – OR 5 – FC 6 – OR 7 – OR 8 – CR 9 – OR 10 – OR 11- OR 12 – OR Where do you draw the line? 2* 11 1 5* 4* +3 +7 6 8 +10 9 12 1 – SR 2 – CR 3 – SR 4 – OR 5 – FC 6 – OR 7 – OR 8 – CR 9 – OR 10 – OR 11- OR 12 – OR Do you have enough resource? 2* 11 1 5* 4* +3 +7 6 8 +10 9 12 1 – SR 2 – CR 3 – SR 4 – OR 5 – FC 6 – OR 7 – OR 8 – CR 9 – OR 10 – OR 11- OR 12 – OR ADR ~ Common misconceptions Thanks to the ADR “Because….” Skills & experience – before Experience Minimal 2-5 years 5-10 years 10+ years Potential Highest Senior Management J Redmond Middle management Line management D Winter E Godwin F James A Brown C Jones G Halliwell H Smithers “Because….” Skills & experience – new world? Experience Minimal 2-5 years 5-10 years 10+ years F Johnson J Smith G Heldon E Goodwood H Smythe K Alwyn Potential Highest Senior Management C Jakes D Wales Middle management A Brown Line management AZ Strategy – Mark 2 ingredients GRC strategy Compliance and responsible business scorecard Assurance Mapping Lean auditing New Key Performance Indicators “Because….” Experience with clients.. “Because….” Experience with clients.. over the past 3 years .. qLean auditing q Kano techniques on IA customer and value add q Speeding up delivery / streamlining reporting q Better use of technology qClarifying IA role q Anti-fraud etc. q Creating a GRC strategy q Continuous monitoring q Educating management and the audit committee qBudget / HC cuts q Use of q audit universe q Overall opinion ….to counter challenges Lean Internal Audit: Methodology on one page Review Phase Process Assignment Planning Scoping Audit Remit Fieldwork Opening Meeting Process Mapping & Key Control Testing Reporting Closing Meeting Draft Report Feedback & Monitoring Final Report Customer Survey Learning Review & Personal Feedback Mandatory Steps Framework Time Line End of Fieldwork – Personal learning review All work papers to be documented in XXX End of assignment– Overall project learning review IIA ~ 3 lines of defence in relation to effective risk governance ~ 2013 3 lines of defense Source: Berendsen Accountability framework example Global Level Accountability Framework Specialist Compliance Functions Group Legal & Compliance Specialist Compliance Audit Functions GIA External Audit & Regulators A R R C C O I C Iᴱ 2. Determine Group Level policies* A S S R C/R O I C/I Iᴱ 3. Communicate Policies* A R R C/S C/S O S I Iᴱ O A R C/I C/I Iᴱ I I Iᴱ O A R C/S C/S I/C I I - I Informed Iᴱ Informed (by exception) Company Secretary General/Factory Manager 3rd Line of Defence Assurance Providers Division / Region 2nd Line of Defence Compliance Functions Function Heads Key: R Responsible A Accountable S Support C Consulted O Oversight 1st Line of Defence Business Area Management Ethical Culture (Control Environment) 1. Establish Roles & Responsibilities Delivery of procedures, training and action 4. Maintenance of detailed standards and processes 5. Training – development and delivery Monitoring business as usual & Reporting issues upwaards 6. Monitoring of activities O A R C C I/C Iᴱ I - 7. Reporting issues or risks O A R I I/C I/C I I Iᴱ O A R CS C/S I C/S C/I Iᴱ C A R S O C A/C I/C Iᴱ S S S C C/I C/I A/R O/R Iᴱ Improvement actions and investigations 8. Management of issues & Corrective Actions 9. Ethics Investigation & Disciplinary Action Audit & Assurance 10 Compliance Auditing Plan example ~ Fraud We will carry out a high level framework review at a selection of key sites and support the implementation of CAATs and fraud awareness within Finance and Purchasing in key locations Example ~ Planning From To Based on processes Greater risk focus Largely Financial and compliance Informal discussions of value add More explicit discussions of value add contribution Little contribution to key risks Greater contribution to key risks Example ~ Planning Essential to consider other lines of defense From (Business) From IA To (Business) To (IA) Risk and process thinking not embedded Process approach More robust risk and control thinking Greater risk focus Finance and Compliance monitoring mixed Largely Financial and compliance Strengthen Finance and compliance monitoring Less need for IA to look at these areas Role and value add from IA not well understood IIA responding to requests in an informal way Deeper understanding of the unique role & contribution of IA More explicit discussions of value add contribution Culture of trust around key risk management but some suprises Limited work on key risks Greater assurance mindset around key risks to avoid surprises and disappointments Greater contribution to key risks “Because….” Audit Universe – before Where •Processes •Locations •Departments What •Compliance •Financial Controls •Operational controls •Business continuity “Because….” Audit Universe – developing Where •Processes Projects •Locations 3rd party providers •Departments Governance What •Compliance •Financial Controls •Operational controls •Business continuity Value for Money Controls design Data quality “Because….” Audit Universe – enhanced Where •Processes •Locations •Departments •Systems •Customer relations •Government / regulator returns •New markets •Networks/Applications Projects 3rd party providers Governance Sales force Non Financial reporting New business areas Emerging risks Other assurance functions What •Compliance •Financial Controls •Operational controls •Business continuity •Cost/control trade offs •Crisis management Value for Money Controls design Data quality Accountabilities Strategy implementation Reputation management Enhance audit universe will often reveal coverage issues IA effectiveness framework Remit & scope Strategy & Plan Sponsorship Supporting tools – IA & other Intelligence & Knowledge management Capability, expertise & influencing Team/management culture / style Resource management Scorecard / tracking Developed after a PwC idea Independence “Because….” Future thoughts IIA / FSA guidance Use of Assurance mapping techniques “Because….” The future? ~ FSA / IIA guidance Recommendations for IA coverage • The design and operating effectiveness of governance structures and processes of the organisation • The strategic and management information presented to the Board • The setting of, and adherence to, risk appetite • The risk and control culture of the organisation • Risks of poor customer outcomes, giving rise to conduct or reputational risk • Key Corporate Events • Outcomes of processes “Because….” Conclusions qIA strategy an invaluable tool – engaging stakeholders / Value add qWhat you are doing / how you do this and with who qIA role ~ 3 lines of defence typically very helpful qDon’t shy away from sensitive topics – this may be the only way to get on the table: q Plan coverage q Staff skills q Coverage / resources q Common issues q Benchmark / EQA qUse this to flag wider GRC strategy qDevelop an assurance approach ~ share the assurance load qDeveloping political savvy to influence key stakeholders in “must win” encounters J Paterson: Publications / Citations Topic Publication Month / Year Internal Audit ~ New rock and roll Accountancy Magazine, UK January 2005 Forbidden Territory (auditing no go areas) IA & BR UK December 2006 Meeting the people challenge IA & BR UK February 2007 Garbage in, garbage out Internal Auditor June 2007 The power of priorisation Audit Director Roundtable December 2007 Getting the most from your IA function ACCA e-bulletin June 2008 Lighting up your blind spots IA & BR Magazine UK March 2010 Mixed Messages Strategic Risk Magazine March 2010 68 J Paterson: Publications / Citations Topic Publication Month / Year Know your business Internal Auditor, US June 2010 Help or hindrance? Risk Management Professional June 2010 A problem shared (Action Learning) IA & BR Magazine UK June 2010 Culture & behavior IA & BR Magazine March 2011 Assurance Mapping CFO World March 2011 Assurance Mapping IA & BR Magazine UK April 2011 Psychology of risk and audit ACCA UK e-bulletin June 2011 Lean Auditing CIPFA Audit Viewpoint August 2011 Lean Auditing Audit & Risk W/S UK September 2011 69 J Paterson: Publications / Citations Topic Publication Month / Year HIA career paths Symmetry November 2011 Boards and Risk Risk Management Professional, UK December 2011 Audit Planning theiia.org/chapters/500 December 2011 New year new plan Audit & Risk Magazine, UK January 2012 Risk assurance and assurance mapping CIPFA Audit Committee up-date February 2012 IA KPIs IIA Denmark April 2012 Coordinating assurance Audit & Risk Magazine, UK May 2012 70 J Paterson: Publications / Citations Topic Publication Month / Year Eight things you need to know as a new HIA www.auditandrisk.org.uk July 2012 Dear Audit Committee Chair Linked In ~ CAE sub-group www.riskai.co.uk September 2012 Lean Auditing Internal Auditor, US December 2012 Audit Committee Effectiveness ACCA IA Newsletter April 12 Assurance for the Audit Committee ACCA IA Newsletter June/July 12 71 These slides have been developed for the exclusive use of those attending the HIAS workshop on 6/6/13 by James Paterson, Risk & Assurance Insights Ltd. This presentation has been prepared solely for educational and illustrative purposes. Whilst every effort has been made to ensure the factual accuracy of the content herein, no representation or warranty is given as to its accuracy. This presentation should not be relied upon as the basis for making any investment or other decision and it is not claimed that any of the content or views contained herein, whether expressly made or implied, represents the views of management. The slides should not be reproduced or circulated further without permission from James Paterson: E-mail: jcp@riskai.co.uk Web: www.riskai.co.uk Phone: +44 7802 868914 7 2