Position Statement The Institute of Internal Auditors – UK and Ireland Risk Based Internal Auditing Introduction The focus of internal audit work has shifted dramatically over the last decade. There has been a move from systems based auditing to process based auditing and the current emphasis is on Risk Based Internal Auditing (RBIA). RBIA is a much used and much misunderstood term. This paper aims to set out the Institute’s position with regard to RBIA and to offer some high level guidance on how to approach it. Internal auditors might say that they have always focused their efforts on the riskier areas of the organisation. However, this approach has historically been directed by internal audit’s own assessment of risk. The key distinction with RBIA is that the focus should be to understand and analyse management’s assessment of risk and to base audit efforts around that process. What is Risk Based Internal Auditing? The objective of RBIA is to provide independent assurance to the board that: Context The current definition of internal auditing is that it is: “An independent, objective assurance and consulting activity designed to add value and improve an organisation’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” RBIA is an approach that can help to meet these requirements. The Standards for the Professional Practice of Internal Auditing and the associated Practice Advisories emphasise adopting a risk-based approach to internal auditing. This approach is also consistent with the Turnbull guidance Internal Control: Guidance for Directors on the Combined Code, which requires directors to adopt “a risk-based approach to establishing a sound system of internal control and reviewing its effectiveness”, and to embed risk management and internal control into the culture of the organisation. Internal auditors need to adopt a risk-based approach compatible with that adopted by their organisation. There are many approaches which could be adopted by internal audit depending on the extent to which internal audit is able to rely on the risk management processes across the organisation. This enables the auditor to avoid duplicating processes already carried out by management, and allows him or her to question management’s processes or conclusions. The risk management processes which management has put in place within the organisation (covering all risk management processes at corporate, divisional, business unit, business process level, etc.) are operating as intended. These risk management processes are of sound design. The responses which management has made to risks which they wish to treat are both adequate and effective in reducing those risks to a level acceptable to the board. And a sound framework of controls is in place to sufficiently mitigate those risks which management wishes to treat. RBIA starts with the business objectives and then focuses on those risks that have been identified by management that may hinder their achievement. The role of internal audit is to assess the extent to which a robust risk management approach is adopted and applied, as planned, by management across the organisation to reduce risks to a level that is acceptable to the board (the risk appetite). While internal audit’s main contribution is to provide assurance on management’s treatment of risk (through governance and control processes) it may also advise management on other aspects of their response to risks such as decisions to terminate, transfer or tolerate risks. Risk Based Internal Auditing The Risk Based Internal Auditing approach is described schematically below: Corporate Objectives Identification of risks to achieving objectives What is the risk appetite of the business? Is the risk management process an adequate and effective process for identifying, assessing, managing & reporting on risk? Yes No Use organisation’s own view of risk as far as possible Facilitate risk identification with management Facilitate refinement Determine risk universe Determine scope and priority of assignments Based on risks select areas for review For each area, review adequacy of risk management processes to identify & manage risks Where largely OK Where not OK Evaluate processes and determine how management gain assurance that the risk management activities are being carried out as intended Facilitate risk identification and assessment • inherent risks • mitigation • residual risks Give assurance where OK and facilitate improvement where not Risk Based Internal Auditing The practice of Risk Based Internal Auditing out a range of stages of risk management maturity and the internal audit approach that might be adopted at each stage: Points of information: The scope of risk-based internal auditing includes strategic and business risks. The key starting point is to determine that appropriate objectives have been set by the organisation and then to determine whether or not the business has an adequate process in place for identifying, assessing and managing the risks that impact on the achievement of these objectives. In a mature risk management environment the focus of internal audit work may be: Auditing the risk management infrastructure, for example, resources, documentation, methods, reporting. Auditing the whole system of internal control for the complete organisation and for individual departments. Carrying out individual audit assignments that are predominantly about specific risks. Where a number of risks are controlled through a common system or process, it may be appropriate to perform a combined audit of that system or process. In less mature risk management environments, where individual audit assignments predominantly focus on complete systems, processes or business units, internal audit needs to review business objectives and risk management processes within each of these auditable entities. Where risk management processes are adequate and embedded, internal audit aims to rely, where possible, on the organisation’s own view of the risks in order to determine the audit work that it needs to carry out. Where the risk management processes cannot be relied on, internal audit needs to undertake its own risk assessment (in conjunction with management) to determine the precise level of the work required and then focus on how management assures itself that the risk management activities are operating as intended. Risk Maturity Key Characteristics Internal Audit Approach Risk Naive No formal approach developed for risk management Promote risk management and rely on audit risk assessment Risk Aware Scattered silo based approach to risk management Promote enterprise-wide approach to risk management and rely on audit risk assessment Risk Defined Strategy and policies in place and communicated. Risk appetite defined Facilitate risk management/liaise with risk management and use management assessment of risk where appropriate Risk Managed Enterprise wide approach to risk management developed and communicated Audit risk management processes and use management assessment of risk as appropriate Risk Enabled Risk management and internal control fully embedded into the operations Audit risk management processes and use management assessment of risks as appropriate Each organisation must determine how it wishes to implement risk management. This will help determine its appetite for risk and the level of it’s risk maturity. For example, not all organisations will wish to become completely “risk enabled” as they may need to weigh up the costs against their views on the potential benefits. It is for the board of directors and senior management team to determine how far along the continuum they wish to travel. In addition to risk management maturity within an organisation, the extent to which internal audit needs to undertake its own risk assessment also depends upon the degree and speed of strategic and organisational change. When undertaking an audit of a project, the risk management processes covering projects in general and also those specific to the individual project need to be covered. Conclusion The end result of each audit assignment should be to give assurance that risks are being managed to an acceptable level (as determined by the risk appetite) or to facilitate and/or agree improvements as necessary. Risk management continuum It is important to understand that not all organisations are at the same stage of risk management implementation. The following diagram sets RBIA does not preclude the use of systems-based and/or processbased auditing as circumstances dictate. It is, however, an approach that focuses on the issues that matter to the organisation and on providing assurance on the risk management framework adopted by the organisation. RBIA will enable internal audit to link directly with the risk management framework thereby leveraging synergies. Risk Based Internal Auditing Glossary of terms Risk: the chance of something happening or not happening that will have an influence upon the achievement of business objectives. Risk management activities: the methods by which an organisation chooses to manage its risks as outlined above. This replaces the traditional approach that focused purely on internal controls. Risk identification: the process of determining what can happen, why and how. Inherent (gross) risk: the status of the risk (measured through impact and likelihood) without taking account of any risk management activities that the organisation may already have in place. Risk analysis: the systematic use of available information to determine the likelihood of specified events occuring and the magnitude of their consequences. Measured in terms of impact and likelihood. Residual (net) risk: the status of the risk (measured through impact and likelihood) after taking account of any risk management activities that the organisation may have in place. Risk appetite: the level of risk that the board or management is prepared to live with. This is likely to be different for each of the risks that have been identified. About Position Statements Risk evaluation: the process used to determine risk management priorities by comparing the level of risk against predetermined standards, target risk levels or other criteria Risk assessment: the overall process of risk analysis and risk evaluation. Risk management: an iterative process consisting of steps, which when taken in sequence, enable continual improvement in decisionmaking. It is the logical and systematic method of identifying, analysing, evaluating, treating, monitoring and communicating risks associated with any activity, function or process in a way that will enable organisations to minimise losses and maximise opportunities. (Australian/New Zealand Standard on Risk Management AS/NZS 4360) Management of risk: the means by which an organisation elects to manage individual risks. These may be by treatment (i.e. to reduce impact or likelihood), termination, transfer, or the organisation may decide to tolerate the risks. The Institute of Internal Auditors – UK and Ireland (IIA) is the primary body representing, promoting and developing the professional practice of internal auditing in the UK and Ireland. Position statements are part of a range of technical and professional guidance prepared by the Institute for it’s members. They are designed to clarify the Institute's official policy position on important and potentially complex matters confronting internal auditors. Disclaimer This technical guidance material is not intended to provide definitive answers to specific individual circumstances and as such is only intended to be used as a guide. The Institute of Internal Auditors – UK and Ireland recommends that you always seek independent expert advice relating directly to any specific situation. 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