ENHANCING CONFIDENCE IN THE ACCOUNTANCY PROFESSION TO PROMOTE ECONOMIC GROWTH By Graham Ward, CBE, MA, FCA President, International Federation of Accountants International Conference on “Role of Accountancy Profession in Anchoring Economic Growth” Mumbai, India – January 20, 2006 Thank you very much for your kind introduction and for the privilege to speak with you today. This is my third visit to India in the past year, and I am always heartened by the warm welcome that I receive here. Each time, I am also impressed by the progress of the profession, the dedication of your volunteers and your receptivity to new ideas that can further strengthen India’s role in the world economy. I would like to thank both your President, Shri Kamlesh Vikamsey, and your Chief Executive, Dr. Ashok Haldia, for organizing this important conference and for inviting me to speak at it. There is no question that the international accountancy profession has a unique, critical and practical role to play in building stronger and more stable economies around the globe. In order to fully carry out this role, however, we need to continue to enhance confidence in the profession and to build trust. Investor confidence and public trust empowers our profession. Without it, the credibility of the information we produce, indeed the future of our profession itself, is put at risk. Whether we work in New York or New Delhi, we cannot afford this risk. Since corporate fraud and misconduct in the U.S. and elsewhere shook investor confidence and raised questions about the integrity of capital markets and their participants, action has been taken around the globe by governments, regulators, and accountants themselves to strengthen the profession and enhance market integrity. The International Federation of Accountants, which represents over 160 member organizations in 120 countries, has also undertaken some major initiatives, consistent with its mission which is: “To serve the public interest, IFAC will continue to strengthen the worldwide accountancy profession and contribute to the development of strong international economies by establishing and promoting adherence to high-quality professional standards, furthering the international convergence of such standards, and speaking out on public interest issues where the profession’s expertise is most relevant.” Before I describe some of our initiatives, I would like to emphasize that when I speak about “IFAC” and the work that we do, I am not speaking about a handful of individuals. I am referring to the broad, global network of volunteers that serve on our eight technical committees and boards; to our Board, which is comprised of nominees of IFAC members; to all member bodies that so actively participate Page 2 of 17 in IFAC, particularly through the IFAC Member Body Compliance Program; and of course, to the IFAC staff who support all of these groups. I am especially grateful to the Institute of Chartered Accountants of India and to its leaders, who have made a very deep commitment to the profession and to the public interest which it serves. As a founding member of the International Federation of Accountants, the Institute of Chartered Accountants of India has a long tradition of active involvement in and support of IFAC. I would like to thank those Indian representatives currently serving on our boards and committees, without whose support, IFAC could not achieve its objectives. Your President, Shri Kamlesh Vikamsey, represents India on the IFAC Board and is ably supported by Dr. Haldia, who serves as his technical advisor. I would also like to thank your immediate past president Shri Sunil Goyal, who is a member of our Small and Medium Practices Committee and previously served on the IFAC Board; Shri T.N. Manoharan, the Institute’s Vice President, who joined our International Accounting Education Standards Board last November; Shri Shanti Lal Daga, who joined our Developing Nations Committee last November; Shri Pankaj Jain, who serves on the International Public Sector Accounting Standards Board; and Shri Rajkumar Adukia, who serves on our Professional Accountants in Business Committee. These gentlemen exemplify the ICAI’s spirit of active participation in the international profession. Page 3 of 17 This spirit of international involvement has also had a positive effect on your economy. As a Board Member of the Indo-British Partnership Network, I am very aware that India, the world’s second fastest growing economy, is now the world’s second most preferred destination for foreign direct investment. It has posted an impressive growth rate of seven percent and has begun to reap the fruits of its steps towards both greater market openness and facilitating direct investment, such as rapid growth in the technology and communications sectors. I was encouraged to hear Indian Finance Minister Shri Palaniappan Chidambaram echo these sentiments at the Indian Economic Summit last November when he said, ”We must open the doors to foreign direct investment.” It is through greater international cooperation and investment that India’s impressive economic growth rate can be sustained, and it is through continued economic growth that challenges such as poverty and development can be addressed. Let me turn back to my specific topic for today: enhancing confidence in the accountancy profession in order to achieve economic growth and stability. To meet this objective, IFAC’s activities in four specific areas are directly related to achieving this goal: First, we have promoted, indeed required, adherence to high ethical standards by the 2.5 million accountants represented by our member bodies. Page 4 of 17 Secondly, we have sought to continue to enhance the quality of the audit process through the development of high quality international standards. Thirdly, we have encouraged firms and our member bodies to monitor the quality of those processes. Lastly, we have focused on encouraging strong corporate governance and management accountability. The bedrock of our international commercial system is high quality financial information: information based on ethics and integrity, on high quality international accounting and auditing standards and on the work and sound judgment of both internal and external professional accountants. Credible and reliable financial information is fundamental to investment. It builds investor confidence which, in turn, facilitates business development, contributes to job growth and leads to individual financial prosperity. Let me return to the first point – promoting high ethical standards. Ethical conduct lies at the core of all business. We do business with those we trust; we get business from those who trust us. It is at the root of generating confidence in both individuals and entities. Ethics, therefore, is a driver of business growth which demands attention from boards and investors alike. As Page 5 of 17 the world becomes more interconnected, it is the values that we share that unite us as a profession. IFAC’s values of integrity, transparency and expertise are reflected in every facet of our work. To build credibility in financial systems and to contribute to sound economic systems, we must also promote these values to all professional accountants, both in practice and in business, as well as to all those in the financial reporting supply chain. And we must do so in a way that is relevant and meaningful. IFAC’s International Ethics Standards Board for Accountants, which develops the international Code of Ethics for Professional Accountants, does just this. The Ethics Standards Board recently released an updated Code of Ethics which establishes a conceptual framework for all professional accountants to ensure compliance with the five fundamental principles of professional ethics. These principles are integrity, objectivity, professional competence and due care, confidentiality and professional behavior. Under the framework, professional accountants are required to identify threats to these fundamental principles and, if there are threats, to apply safeguards to ensure that the principles are not compromised. The framework applies to all professional accountants, those in public practice as well as those in business and government. The Ethics Standards Board, recognizing that both governmental and business accountants Page 6 of 17 play significant roles in safeguarding the public trust, plans to provide further guidance for these accountants in particular. The Ethics Standards Board is also focused on an issue that is perhaps most central to public trust and one that has received widespread attention by the media and regulators: independence. A forum on the topic was held in Brussels in October and attended by regulators, standard setters, corporate management, and representatives of IFAC member bodies. This input is part of an extensive Ethics Standards Board consultative process that will help to determine how the independence rules should be modified better to address the public interest. The second way in which IFAC is working to build confidence in the profession and contribute to economic growth, is through one of its most core activities: developing international auditing and assurance standards. These standards are developed by the independent International Auditing and Assurance Standards Board and, like IFAC’s ethics code, are subject to a rigorous due process that includes extensive public interest input. One of the IAASB’s most significant projects is improving the clarity and structure of its standards. Based on input it received at a forum in July and through responses to its 2004 Proposed Policy Statement and Consultation Paper on Clarity, in late October 2005 the IAASB released exposure drafts of four proposed standards developed using a new drafting style. These standards are Page 7 of 17 the first to be issued as part of an ambitious 18-month program to make IAASB standards more understandable and capable of being translated, and to facilitate international convergence. The exposure drafts are posted on the IFAC website and I encourage you to review them and to provide comment. In addition to focusing on clarity, the IAASB has issued a new international standard on audit documentation, designed to enhance auditor performance and audit quality by establishing stricter requirements for audit documentation. Beginning with this standard, the IAASB staff is preparing a “Basis for Conclusions” for each new international standard to increase understanding about the development of the standard – in particular, how the IAASB has responded to input received. We hope that you find this to be helpful. Earlier this month, the IAASB issued an exposure draft on another significant public interest issue – related party transactions. The proposed revised International Standard on Auditing would require the auditor to perform a minimum set of procedures to identify related party transactions and transactions not identified or disclosed by management. Other current IAASB projects are the development of standards on auditing accounting estimates and on materiality in the identification and evaluation of misstatements. Page 8 of 17 In addition to International Standards on Auditing, the IAASB also issues International Standards on Quality Control, to be applied by accounting firms for all services falling under the IAASB’s international standards. While its current agenda is clearly focused on ISA-related matters, to address expanding and changing business needs, the IAASB also has a mandate to issue International Standards on Assurance Engagements (ISAEs), which are to be applied by practitioners in assurance engagements dealing with information other than historical financial information, and International Standards on Related Services. To promote good practice, the IAASB issues Practice Statements to provide interpretive guidance and practical assistance in implementing its standards. To assist professional accountants in meeting the demands of a changing business environment and also to build further credibility in financial information provided by accountants globally, IFAC has placed increased effort on improving the transparency of the IAASB standard setting processes and on devoting more resources to them. The same focus has been placed on the standard setting work of the International Ethics Standards Board for Accountants and the International Accounting Education Board. A significant event that, I believe, will boost confidence in the profession and trust in our work is the establishment of the international Public Interest Oversight Board (PIOB). Formed in February of last year and chaired by Professor Stavros Thomadakis (a former Chairman of the Hellenic Securities Commission), the Page 9 of 17 PIOB has eight members and two observers, all very senior people, appointed by international bodies of regulators and institutions. It also is strongly supported by the Financial Stability Forum. The appointing bodies are: IOSCO, the International Association of Insurance Supervisors, the Basel Committee, the World Bank and the European Commission. The PIOB oversees the work of the IAASB and of IFAC’s Ethics and Education Committees and endorses appointments to them. In September 2005, it approved the due process and working procedures that they should follow and in December approved new appointments. This oversight will, I believe, contribute to increased credibility in all the standards that IFAC develops through its independent boards. Before I move off the topic of standard setting, I want to comment on one of IFAC’s most important objectives: convergence with national standards. Convergence is, I believe, at the core of building an investment climate of trust. Here’s why. Globalization demands high-quality standards that can be applied from Sydney to Stockholm, from Morocco to Mumbai. This puts everyone on a level playing field. Second, global standards will result in increased transparency and accountability. Investors will be better able to compare company financial statements across borders. I also believe that developing countries that adopt international standards will see increased outside investment in their economies, by Page 10 of 17 institutional and retail investors who are familiar with, and confident in, the standards, regardless of geography. There’s another consideration as well. Having a multiplicity of accounting, auditing and other standards around the world is against the public interest. It creates confusion, encourages error and facilitates fraud. The cure for those ills is to have a single set of international standards, of the highest quality, set in the public interest by an international expert body which transparently consults with, and recognizes the legitimate interests of, the international community. In consultation with IFAC boards and committees, and other relevant interested parties, IFAC staff is further developing the concept of “international convergence.” The objective is to develop guidance to accompany IFAC’s Statements of Membership Obligations (SMOs), which form the basis of the IFAC Member Body Compliance Program. The IFAC Member Body Compliance Program, in which the ICAI is an active participant, is directly related to a third initiative of IFAC’s: encouraging quality performance by the international profession and encouraging firms’ and member bodies ’ to ensure that appropriate quality control mechanisms are in place. This program supports the development of high quality auditing, accounting, ethical, educational and related quality assurance and disciplinary standards in IFAC member bodies throughout the world. The program is intended to guide Page 11 of 17 accounting institutes in the full spectrum of their professional responsibilities, to demonstrate a shared commitment to our profession’s values of integrity, transparency and expertise. We know that India shares this commitment to these values and that it, too, through its most recent Professionals Act, is continuing to provide for greater transparency and accountability on the part of the profession. Phase 1 of the Compliance Program, a fact-based questionnaire to assess the regulatory and standard-setting frameworks of IFAC member bodies, is now complete. Responses from more than 90 member bodies, including the response from the Institute of Chartered Accountants of India, have been posted on the IFAC website. The goal is to have all responses posted as soon as reviews are completed. Part 2, the SMO Self-Assessment questionnaire, was distributed to member bodies for completion at the end of November and responses will be posted to the IFAC website next year. The responses from these questionnaires are important for several reasons: they provide a global snapshot of the accountancy profession from both a regulatory and standards perspective. Additionally, they can be used to help IFAC gauge where it needs to focus its efforts to support the development of the profession and to work to achieve convergence. Lastly, but perhaps most importantly, the responses to the questionnaires demonstrate the international accountancy profession’s willingness to be accountable for its actions to meet high standards, to deliver quality and to protect the public interest – all of which contribute to building confidence in the profession. Page 12 of 17 As we look to the future, we see that the global economy will continue to challenge the international accountancy profession, regulators, standards setters, and business leaders to compete and to deliver quality. In anticipation of these challenges, and in recognition that we must never waiver in our commitment to build public trust, IFAC’s Board has recently agreed to lead a new study on enhancing the quality of the financial reporting supply chain. The project will identify investor expectations and needs and include practical suggestions for enhancements that the global accountancy profession can provide by direct action and those where it will need to engage with others to create change. Among the issues to be considered in the new study are corporate management and governance, regulatory developments, auditor independence and rotation, and the expectations in respect of the board’s and the auditor’s responsibilities for the detection of fraud. IFAC has also focused on promoting strong corporate governance, an area that your country is also successfully addressing. Your new Corporate Governance Rules, embraced in Clause 49 of the Securities and Exchange Board of India’s (SEBI) Listing Agreement, which establishes new corporate governance requirements, including audit committees and independent directors on boards, is a model that other countries can look to and demonstrates your country’s commitment to putting the public interest first. Page 13 of 17 IFAC’s focus on corporate governance is best expressed in an independent report it commissioned – Rebuilding Public Confidence in Financial Reporting – developed two years ago under the leadership of John Crow, former governor of the Bank of Canada. The report emphasized that a wide range of actions, by a wide range of entities, must be taken to strengthen corporate governance. For example, corporate management must place greater emphasis on the effectiveness of financial management and controls, corporate ethics codes need to be in place and effectively monitored and threats to auditor independence need to be given greater attention in corporate governance. The report’s findings and recommendations provided much impetus to IFAC’s Professional Accountants in Business (PAIB) Committee, as well as to other international groups. The PAIB Committee is in the process of finalizing a document on corporate codes of conduct which, among other things, highlights the role of the professional accountant in business in developing, monitoring and adhering to such a code. This IFAC committee has also turned its attention to how best to improve the performance of organizations, and thus to ensure wider prosperity for all. In 2004, our Professional Accountants in Business Committee, working with The Chartered Institute of Management Accountants (CIMA), issued a report on corporate governance best practices entitled, Enterprise Governance – Getting the Balance Right. The joint group conducted an in-depth analysis of corporate successes and failures in 27 case studies from 10 countries. Among the report’s Page 14 of 17 findings were that there are four key determinants of corporate success and failure: the culture and tone at the top, the chief executive, the board of directors and the internal control system. The report also revealed that good governance on its own cannot make a company successful. Companies need to balance conformance with performance. To quote: “Unlike the conformance dimension, there are no dedicated oversight mechanisms, such as audit committees, in the arena of strategy. … There is a danger that in the laudable attempt to improve standards of control and ethics, insufficient attention is paid to the need for companies to create wealth and to ensure that they are pursuing the right strategies to achieve this.” The study examined ‘enterprise governance,’ an emerging concept in the new global economy. Enterprise governance has two equal parts: probity and profitability. I would suggest that one without the other isn’t worth having. Businesses that have the highest ideals but go bankrupt through poor strategic choices are as disastrous to shareholders, to other stakeholders and to public confidence as are businesses that fail because of ethical lapses. Profitable businesses that are run with little regard for the public interest, the law, regulation, employees or shareholders, should not be in business and, ultimately, will not be in business. Page 15 of 17 IFAC is committed to ensuring that all professional accountants, in every country of the world, both developed and developing, have the tools they need to face the challenges of the new global economy IFAC is a global organization of more than 160 member organizations in 119 countries, representing 2.5 million accountants worldwide. Because we are a global organization, and because it is predicted that 95% of the world’s population growth will occur in developing nations, we have made strengthening the profession in those nations a key objective. Our position is this: we have a fundamental role and responsibility to play in fostering progress in the developing world, in eradicating poverty and in building prosperity. Establishing a sound and viable accountancy profession is a critical step in building a sound financial infrastructure and addressing these issues. IFAC’s goal is to have a member body with an established accountancy profession in every country around the globe. There is no doubt that this is a lofty goal, but as we look ahead and see that the growth of the world’s population will largely be in developing economies, I am more and more certain that this goal is one that we cannot compromise or forsake. To achieve this goal, IFAC’s Developing Nations Committee is involved in extensive outreach to developing nations and has prepared new guidance, with the input of IFAC members, to assist developing nations in establishing an accountancy body and where an accountancy body already exists, to further develop and enhance it. The guidance may be downloaded from the IFAC website and CD ROMs have been sent to every IFAC member body. Please take Page 16 of 17 a look at the guidance and let us know if you have any input or need for additional information. The guidance is one part of a comprehensive program designed to help IFAC achieve the goal of creating an accountancy organization in every country. In so doing, we can help to build strong financial architectures around the globe – architectures that are supported by strong ethical standards, high professional standards, and an unwavering commitment to act transparently and to be accountable. Through adherence to high ethical standards we can, together, bring about social stability and good governance in business. Through convergence to international standards we can, together, deliver on our promise to quality. And through acting in the public interest, we can, together, build public trust and sound economies that support a better quality of life for all. I am proud to continue to work with the profession in India, both institutionally and personally, in IFAC’s drive to generate economic growth and stability in every country of the world. Thank you very much for your attention. Page 17 of 17