Improve Internal Audit Methodology
Improve Internal Audit Methodology
Improve Internal Audit Methodology
Thesis
25.11.2016
Author Nguyen Thi Hong Trang
Title Internal Audit Methodology – Improve Internal Audit Methodology
in the Case Company
Number of Pages 32 pages + 4 appendices
Date 24 November 2016
The purpose of this study was to identify improvement areas in the internal audit methodol-
ogy used by the Internal Audit team at the case company which is the local subsidiary of a
global financial group. The Internal Audit activity of the case company has been recently
evaluated by the Institute of Internal Auditors. The overall quality assessment concludes that
the Internal Audit activity has a charter, policies and processes that are in conformance with
the Mandatory Guidance of the International Professional Practices Framework on Internal
Auditing. However, the quality auditors have identified an issue related to traceability among
audit documents. This study is aimed to identify root causes for the problem identified by the
quality auditors and then suggest improvements to solve the problem.
The qualitative research methodology was utilized in this study. The study started with a
thorough analysis of the current internal audit methodology and practice. Next, best prac-
tices on the areas of problem were gathered and analyzed based on a literature review and
on the author’s previous experience as a consultant of a global leading auditing and con-
sulting company. Based on the results of the best practices review and considering also the
objectives of the Internal Audit function and the International Professional Practices Frame-
work, solutions to the problem were constructed.
The author recommends the Internal Audit management apply a risk-based approach in
planning the internal audit jobs through performing a process risk analysis. The process risk
analysis helps refine the audit objectives set in the Internal Audit activity plan and identify
other significant areas of concern which need more internal auditors’ efforts. In other words,
it helps drive the internal audit engagement execution in a more effective and efficient way.
It is recommended that the Internal Audit methodology manual express and emphasize more
clearly on the risk-based internal auditing approach and that the strategic objectives, asso-
ciated risks and risk responses act as a central point connecting documents created through-
out an audit cycle.
It is also recommended that the Internal Audit methodology manual underline requirements
and/or criteria on traceability among audit documents as well as provide specific instructions
on how audit documents should be documented to ensure a positive link among them.
1 INTRODUCTION 1
2 RESEARCH STRUCTURE 6
3 AS-IS ANALYSIS 7
4 BEST PRACTICES 19
5 RECOMMENDATIONS 27
6 CONCLUSIONS 31
REFERENCES 33
APPENDICES
Appendix 1. Overview of IPPF’s Standards and Recommended Guidance
Appendix 2. IPPF’s Standards 2201, 2210 and Related Practice Advisories
Appendix 3. The Case Company’s Risk Matrix Example
Appendix 4. The Case Company’s Audit Plan Document Template
1
1 INTRODUCTION
The internal auditing had its origins in ancient times (McNamee, 1995 and Chun in Cas-
tanheira at al, 2009). However, the internal auditing role only began to become significant
in the management of an organization in the 1940s (Jin’e and Dunjia; Dittenhofer in Cas-
tanheira at al, 2009). It was also in 1941 that the Institute of Internal Auditors (IIA), which
currently is the most internationally recognized professional association on internal au-
diting, was founded (Theiia.org, 2016a). The IIA sets international standards for the pro-
fession, acts as the principal researcher and educator of the profession, and is the only
one provides globally accepted internal audit certifications.
According to Brink (1991), the internal auditing practice earlier than 1941 had a low or-
ganizational status and was part of the accounting function in the organization. Since
then, with the improvements in audit methods and services, application of technology as
well as strengthens in capabilities, internal auditing has gained a higher status in the
organization (Brink, 1991). The head of an Internal Audit function is nowadays often a
member of the organization’s management team and the Internal Audit (IA) function is
no longer part of the accounting function, rather it is a separate function independent
from the rest of the organization.
Current internal audit practice has a significant role in supporting an organization achieve
its objectives through the risk-based audit approach. Starting from the organization’s
strategies and objectives, internal auditors first identify and evaluate risks that may occur
and prevent the organization from reaching its objectives, then verify how well the man-
agement is responding to those risks and finally provide objective and independent opin-
ions on how things should be done or could be done better.
The IA function of the case company in this thesis also applies a risk-based audit ap-
proach for its activity. The function has recently gone through the first quality assessment
by the IIA on the road to complete the IIA’s Quality Assurance Review certification. The
overall assessment concludes that the Internal Audit activity is generally in conformance
with the Mandatory Guidance of the International Professional Practice Framework on
Internal Auditing (IPPF) (IIA, 2016). However, the IIA auditors have identified a tracea-
bility issue between audit planning document, risk & control assessment, work program
and work papers in responding to the IPPF’s Standards 2201 and 2210.
2
The purpose of this thesis is to find out root causes to the identified issue by analyzing
the IA methodology currently practiced by the IA function together with exploring best
practices on internal auditing, finally to suggest solutions to solve the issue.
The definition states three fundamental aspects of internal auditing: its purpose of help-
ing an organization achieve its objectives, its nature of independence and objectivity and
its scope covering the effectiveness and efficiency of risk management, control and gov-
ernance processes.
The Mandatory Guidance includes Core Principles, Definition of Internal Auditing, Code
of Ethics and Standards. Integrity, objectivity, confidentiality and competency are princi-
ples of code of ethics as well as core principles of the internal auditing. The Standards
category states “fundamental requirements for the professional practice of internal au-
diting and for evaluating the effectiveness of the internal audit performance” (Theiia.org,
2016b).
3
Conformance with the principles established in the Mandatory Guidance is crucial for the
internal auditing practice.
1.1.3 Description of the case company and its Internal Audit function
The case company in this thesis research is a financial institution that is preferred to stay
anonymous. The company is the local subsidiary of a global financial group (the Group).
The Group has a long established Internal Audit division (Group IAD) while the local
Internal Audit (IA) team of the case company (the Company) has just been set up three
years ago to meet the local regulations.
According the Internal Audit Corporate Framework (Group IAD, 2015: 3) adopted by the
local company as Internal Audit Policy or Charter and the Company’s Governance and
Internal Control Policy (The Company, 2016: 20), the IA function in the case company is
a permanent function that is independent of any other function or unit in the case com-
pany. The IA function reports directly to the Company’s Board of Directors or its Audit
4
Committee and administratively reports to the Chief Executive Officer for day-to-day mat-
ters (The Company, 2016). The Head of IA and all internal audit staff have no decision-
making power in the Company except those relating to the IA function. This restriction
also includes that internal auditors shall not take part into day-to-day functioning of the
Company.
provide the Company’s Board of Directors and senior management with inde-
pendent assurance about the quality and effectiveness of the processes and
systems of internal control, risk management (current or emerging) and govern-
ance, thus helping to safeguard the value of the organization, its solvency and
reputation (Group IAD, 2015: 3).
To accomplish the mission, the IA function assesses the effectiveness and efficiency of
the aforementioned processes and systems, their compliance with applicable laws and
regulations, the reliability and integrity of financial and operational information, and asset
integrity (Group IAD, 2015: 3).
Figure 2 below illustrates the independence of Internal Audit function in the case com-
pany and Figure 3 explains the relationship between the Group Internal Audit division
and the local Internal Audit team of the case company. As seen in Figure 3, the local
Internal Audit has also a functional reporting to the Group Internal Audit division in addi-
tion to the functional reporting to the local Audit Committee and the local Board of Direc-
tors, as required in the Internal Audit Corporate Framework (Group IAD, 2015: 6).
Figure 3. The Group Internal Audit division and local Internal Audit units
(Group IAD, 2015a: 5)
The Group IAD considers as mandatory the compliance of the Definition of Internal Au-
diting, the Code of Ethics and the Standards included in the IPPF issued by the IIA (refer
to section 1.1.1 and 1.1.2 above). As a result, adherence to the IPPF is one of operating
principles defined in the Internal Audit Corporate Framework.
According to the Framework, the Group IAD is responsible for establishing Corporate
Internal Audit Framework, Internal Audit Methodology and Quality Management System
as well as coordinating and supervising of local Internal Audit units (The IAD, 2015b: 5-
6).
Recently, the Internal Audit activity of the case company has been evaluated by the IIA.
The overall quality assessment concludes that “the Internal Audit activity has a charter,
policies and processes that are in conformance with the IPPF’s Mandatory Guidance”
(IIA, 2016). However, the IIA auditors have identified an issue related to documentation
of audit planning and working paper in responding to the IPPF’s Standards 2201 - Plan-
ning Considerations and 2210 - Engagement Objectives (see Appendix 2 for full details
on the two Standards).
The IIA auditors identify that a planning memorandum is used to indicate audit objectives
for the audited unit and a work program is adapted to the actual situation being analyzed.
6
However, the documentation of audit planning and working paper does not give an ex-
plicit and simple documentary evidence of traceability between the audit objectives, rel-
evant and significant risks observed for the audited unit and established controls to mit-
igate these risks, and the tests in the adapted work program that are carried out to
achieve the established audit objectives.
This thesis is aimed to review again the case company’s IA methodology and then sug-
gest improvement opportunities to solve the problem identified by the IIA auditors.
2 RESEARCH STRUCTURE
This chapter describes the process used to answer the research question.
As illustrated in Figure 4 below, the process starts with a thorough analysis of the current
IA methodology and practice to identify possible root causes to the problem. The key
input for this As - Is analysis is the Audit Methodology Manual including appendices and
templates. In the following step, best practices on the areas identified with the problem
will be gathered and analyzed. The pool of best practices will be based on a combination
of literature review and the author’s previous experience with a global leading auditing
and consulting company. Based on the results of the best practices review, solutions to
the problem will be constructed and suggested considering the Company’s objectives
set for the IA activity and the IPPF. The process ends with a summary of the research
project, its results and further steps to get the recommendations implemented.
7
3 AS-IS ANALYSIS
In order to perform its functions and responsibilities, the Internal Audit function follows
an Audit Cycle set by the Group Internal Audit division as shown in Figure 5 below. The
Audit Cycle follows a risk-driven approach to determine the priorities of the internal audit
activity, which is in line with the IPPF’s Standards 2010 on Planning.
Risk Assessment
The Risk Assessment exercise is performed at both Corporate and Local level using the
AudiNet tool. The result of the risk assessment is the residual risks upon which the An-
nual Audit Plan is based.
The Group’s Audit Methodology Manual (Group IAD, 2016: 103) indicates that risk as-
sessment methodology has been recently developed to adapt to international risk man-
agement standards, covering elements of inherent risk and the control environment as
well as impact and probability factors.
Following the IPPF’s Practice Advisory 2010-1 (IIA, 2009), in developing the IA activity’s
audit plan, the Group has first developed and updated at least annually the audit uni-
verse, which is “a list of all the possible audits that could be performed” (IIA, 2009). In
determining the audit universe, extensive and rigorous information has been obtained
from various sources. Currently, within each of the geographies in which the IAD is
present (Group IAD, 2016: 103), the audit universe consist of three elements: company
group (legal companies that are regularly audited jointly), activities/businesses within
each company group and processes associated with each activity/business.
The Group is exposed to various risks inherent from the activities/businesses and pro-
cesses it conducts. The general approach for risk assessment in the annual audit plan-
ning is based on the consideration of events that, if occurring, can negatively impact the
Group's capacity to achieve its objectives and as a consequence negatively impact its
profits and thereby affect its net worth and solvency (Group IAD, 2016: 13).
There are 10 risk classifications identified as associated with the Group’s activities/busi-
nesses and processes (Group IAD, 2016: 14) e.g. Financial Information Risk, Credit Risk
and Operational Risk.
The risk assessment exercise reflects the auditor's perception of the level of risk existing
in the activity/business or process evaluated. The exercise is performed with the use of
AudiNet application, one of applications in the informational system used by the Group
IA globally. AudiNet has a module that allows objectively and uniformly scoring and pri-
oritizing the auditable universe.
9
.
Inherent risk
Inherent risk is risk that the entity faces without taking into consideration internal controls
established to mitigate it (Group IAD, 2016: 104). Colbert and Alderman (1995) share
the same view that the auditor do not consider internal controls when evaluating inherent
risk. Moller (2013: 66), in other words, defines inherent risk is the risk that the entity is
not able to manage or transfer completely or in other words, there will be always some
risk inherent in all levels of operations and processes.
According to the IA methodology, different approaches are used to evaluate inherent risk
to processes, to the company group and to activities/business as explained below.
When evaluating inherent risk to processes, two following factors shall be taken into
consideration (Group IAD, 2016: 104):
The assessment of impact and probability is performed using a risk events catalogue
defined for each risk that is associated with a process (e.g. 12 risk events defined for
credit risk, 9 risk events for market risk). Events are actual occurrences of a risk that lead
10
to a negative impact or loss. A level of impact, which reflects the criticality if an event
actually occurred, has been pre-assigned in the risk events catalogue. Probability of oc-
currence is higher when there are more likely risk events occurring in a process (Group
IAD, 2016: 104-105).
The methodology established for evaluating company groups seeks to measure their risk
through relative importance and, therefore, criticality of the group based on business and
operations in a specific geography (Group IAD, 2016: 106). A series of quantitative (e.g.
profit, income volume, asset volume) and qualitative criteria (e.g. significant organiza-
tional changes, special focus by regulators) has been used to obtain a score for each
group.
The Audit Methodology Manual (The Group IAD, 2016: 107) states that risks associated
with activities/businesses are measured by their relative importance and therefore, criti-
cality of the activity based on business and operations in a specific geography. A ques-
tionnaire is, therefore, used for risk assessment of each activity, which covers the follow-
ing aspects:
Residual risk
Next, the residual risk for each activity/business and process is determined by subtract-
ing control environment from the inherent risk as shown in Figure 6 below.
The assessment of control environment consider the past 3 years’ audit ratings which is
also the Audit Cycle period, recommendations and their status of implementation in ad-
dition to possible opinions from internal and external parties, annual compliance report,
regulators’ assessment, units’ self-assessment on risk and controls. If no audit rating
exists, whether as a result of audits performed without ratings or no audits performed
during the last three-year cycle, the control environment rating is set in the mid-level
scale, representing a neutral control environment (Group IAD, 2016:109-112).
Finally, a risk matrix is created as the final output of the risk assessment (see Appendix
3 for the risk matrix sample extracted from the AudiNet tool).
The Annual Audit Plan is the result of both the bottom-up analysis and the top-down
analysis as presented Figure 7, which is in line with the IPPF’s Practice Advisory 2010-
1 (IIA, 2009). In addition to inclusion of jobs that are shown in the risk assessment, the
Annual Audit Plan includes all jobs that the IA function must carry out to comply with
specific regulatory or supervisory requirements. Furthermore, jobs that arise as require-
ments by the Board of Directors or Audit Committee will be included in the Audit Plan as
well as jobs suggested by the Company’s senior management in the various communi-
cation forums and that the IA function considers suitable.
12
Jobs in the audit plan are proposed based on the priorities showed in the risk matrix. For
example, if the residual risk result is “Cause for concern”, the audit of that activity/busi-
ness or process must be carried out within the next 12 months as shown in Table 1.
One can see in the Annual Audit Plan document which activity/business or process and
associated risks will be audited throughout the year but not details on the scope of work
for each audit. Detailed scope of work is determined later when the job starts and docu-
mented in the Audit Engagement Plan document (see section 3.1.2 below).
The AudiNet tool has a planning module that enables planning all audit jobs that will be
conducted during the year, considering the risks matrix results and available staff re-
sources.
13
Execute Audits
Once the Annual Audit Plan is finalized and approved, audit jobs will be conducted within
the estimated timeline. Modifications (e.g. change in execution date or cancellation) to
the Annual Audit Plan is possible but written justifications are required and certaine
changes needs appropriate level of approval (Group IAD, 2016: 22).
TeamMate EWP is an audit software program that is used for filing Audit Engagement
Plan document, work program, work papers and evidence found during an audit.
Monitoring of Recommendations
As defined in the Audit Methodology Manual (Group IAD, 2016: 23), this phase deals
with monitoring of all actions identified by the internal auditors to correct relevant defi-
ciencies or weaknesses in the Company's governance, risk management or internal con-
trol system. The cycle will close when a new audit for the same unit takes place or when
the level of implementation is concluded as satisfactory.
AudiNet has s a module that indicates the level of implementation of each recommenda-
tion and automatically retrieves reports about the degree of compliance and percentage
of implementation of a specific business, unit, risk, etc (Group IAD, 2016: 153).
Reporting
This activity per the methodology (Group IAD, 2016: 23) refers to frequent reporting to
the Board or its Audit Committee on the execution of annual audit plan including changes
to the plan, the most significant findings from the audit jobs and escalation of recommen-
dations that are not implemented by the agreed date.
14
This section analyses current processes to execute individual audit jobs (or audit en-
gagements) determined in the Annual Audit Plan.
Figure 8 below is an overview of processes together with their inputs, activities and out-
puts.
An audit job starts with the planning and scoping process with Audit Engagement Plan
document as the output.
Planning is important for conducting audit work and for managing the job. The planning
document is also helpful for the preparation of the audit report in the later process. Man-
datory contents of an Audit Engagement Plan document include (more details in Appen-
dix 4):
- Audit objectives: what the audit aims to achieve.
- Scope of work: the magnitude and boundaries of activities, objectives, and expo-
sures to be reviewed.
- Approach: the nature of the work to be performed.
- Risks to be reviewed.
15
- Limitation of scope.
- Work program and rating model to be used.
- Audit team, reviewer (s) and distribution of tasks.
- Duration: estimated timeline for the completion of the audit.
- Analysis of relevant information: e.g. brief on activity/business or process to be
audited, previous audit results, external reviews
- Audit deliverables: describes the type of reporting to be provided.
According to the Audit Methodology Manual (Group IAD, 2016: 25), purpose of planning
for individual audit jobs is to become familiar with the activity and other essential aspects
of the audited activity beforehand and thereby identify the risks that it exposes to and
existing controls to mitigate those risks. This aim is in line with the IPPF’s Standard 2201
(see Appendix 2 for the contents of the Standard). In fact, risks and controls associated
with the activity/business and process have been preliminarily evaluated in the annual
audit planning. But there is no indication in the methodology manual that risks identified
in the audit engagement planning shall be linked to risks identified earlier in the annual
audit planning. There is also no specific requirements in the methodology manual on
setting audit objectives, whether they shall be reflected the results of risk and control
assessment in accordance with the IPPF’s Standard 2210 (see Appendix 2 for the con-
tents of the Standard). Specific instructions on analyzing associated risks and controls
in the audit engagement planning are especially necessary, as there may be jobs in the
Annual Audit Plan that are determined based on management requirements (refer to
Figure 7 above).
Regarding the work program, the Group Internal Audit division has created various work
programs to audit different activities/areas in the Group e.g. credit risk management and
finance. In general, the local IA team is able to find one relevant work program from the
standard work program inventory in order to cover audit objectives of the job with possi-
bility of modifications based on the particularities of the unit. If the local team does not
use that standard work program or use it with modifications, reasons for such option
must be adequately justified. The standard work programs have pre-defined objectives
and test procedures to be performed to achieve these objectives. The standard work
programs are all very extensive as they are supposed to cover a full scope audit. There-
fore, the methodology (Group IAD, 2016: 29) allows the team leader to decide which test
procedures that are not performed with justification of not being applicable in every case.
Additional tests in addition to standard work program are also possible.
16
However, there is no indication in the methodology manual that there shall be a link
between audit objectives determined in the Audit Engagement Plan document and those
defined in the work program. Therefore, there were cases that a standard work program
was selected without considering modifications of pre-defined audit objectives to match
with audit objectives defined in the Audit Engagement Plan.
Fieldwork
After the audit engagement planning is completed, auditors will perform their assigned
tests in the selected or adapted work program.
Work programs are structured by assigning specific risk(s) covered by each audit test
and the risk factor in which the conclusion must be evaluated. This structuring helps the
auditor better assess the direction of each test, facilitating a subsequent determination
of the audit rating in the later phase (see section “Conclusion & Reporting” below). For
example, the associated risk and rating factor are assigned as below for one test in the
work program on Financial Management:
Test #4. Obtain the latest independent audit and supervisory body reports and an-
alyze the most relevant aspects highlighted in these reports and potential issues
detected, checking their current status
As instructed in the Audit Methodology Manual (Group IAD, 2016: 29-30), if the test result
is unsatisfactory, the auditor should report any detected issues to the team leader, who
may require additional testing or increase the sample. The auditors shall also discuss
the detected issues with the audited units and objectively assess the received comments.
The comments obtained in this manner shall be included in the work papers, if appropri-
ate. The purpose of these discussions and prior reviews is to provide the audited unit an
opportunity to clarify and express their points of view on the findings, to corroborate the
accuracy of information used and findings obtained as well as to analyze the need to
perform additional tests.
17
The application of audit tests and the findings obtained shall be reflected in the auditors’
work papers. Work papers are a permanent expression of the work conducted by mem-
bers of the audit team and required actions on which their findings are based. Work
papers are considered sufficient if they meet the following criteria (Group IAD, 2016: 30):
Once all tests in the work program are completed and documented, auditors will perform
the audit rating and prepare audit deliverables. Rating for the audit is carried out using
the rating model identified in the Audit Engagement Plan document.
A rating model is built together with the related work program by the Group Internal Audit
division. The model is built in a flexible in the way that it permits adaptation to the variety
of existing audit approaches (Group IAD, 2016: 41). Certain factors, or even risks, may
be rated as inapplicable in some audits, and new models may be created (if necessary)
to handle new approaches but should be always in accordance with the implemented
work methodology.
The rating model pre-defines assessment factors to the activity or the process that is
being evaluated. As the methodology explains (Group IAD, 2016: 43), these factors are
indicated in relevant tests of the work program (see “Fieldwork” section above), so that
the auditor easily identifies if there are related weaknesses and makes an assessment.
The methodology manual (Group IAD, 2016: 62) emphasizes that recommendations
monitoring is an essential process in the audit cycle that seeks to demonstrate proper
commitments by audited unit(s) on improving the internal control system. Auditors will
evaluate the adequacy of created action plan, monitor each of the established milestones
18
in the plan and support audited units to achieve desired objectives, without carrying out
actions that could compromise its independence. Monitoring activities & status of recom-
mendations need to be recorded in an appropriate manner.
Figure 9 below visualizes all documents created along the IA function’s Audit Cycle men-
tioned in section 3.1 above together with audit tools used to prepare and store those
documents. The documents, which starts with the risk assessment documentation and
ends with the report of IA activity are stitched together to express the opinion how well
the organization is responding to risks that may occur and prevent it from achieving strat-
egies and objectives. Risks associated with the organization’s strategies and objectives
and risk responses are, therefore, the central point of all those documents. However, this
central point is not clearly traced in the audit engagement plan, work program and work
papers, marked in Figure 9 below.
Even though the IA function adopts a risk-based audit approach in accordance with the
IPPF, the approach is not explicitly introduced at the beginning and further explained in
the methodology manual. Indeed, the term “risk-based” is mentioned only once in a later
chapter on quality management system (Chapter 5). Strategic objectives, associated
risks and risk responses as the central point connecting documents created throughout
the Audit Cycle is not, therefore, underlined.
4 BEST PRACTICES
This chapter is aimed to identify and analyze best practices on the internal audit meth-
odology with a focus on areas identified with the problem in the case company. The pool
of best practices has been gathered mainly based on the author’s previous experience
as a consultant of a global leading auditing and consulting company and on a literature
review.
The IPPF’s Standards 2100 positions the internal audit activity’s nature of work as sys-
tematic, disciplined, and risk-based approach. Risk-based approach shall be applied in
planning for the IA activity (Standards 2010) and planning for audit engagements (Stand-
ards 2201 and 2210). This means that various risks shall be evaluated during the plan-
ning stages (Colbert and Alderman: 1995), those risks that prevent the organization and
its business processes from achieving the established objectives.
Several studies show that the adoption of a risk-based approach is positively correlated
to the accomplishment of the internal audit activity’s objectives, which are to help the
organization improve its effectiveness of risk management, control, and governance pro-
cesses (see Definition of Internal Auditing in section 1.1.1 above). Colbert and Alderman
(1995) explain as the risk-based or risk-driven approach focuses the internal auditor’s
efforts on high risk areas, it is generally more effective (i.e. in identifying errors) and more
efficient (i.e. efforts put on high risk areas). McNamee (1997) claims that the way internal
auditors focus on risk, broaden their perspective to include all risk management tech-
niques and then assess the auditable areas in an environment of risk adds more value
to the organization. Bechara and Kapoor (2012) view that the internal auditors’ systemic
and risk-based approach of viewing risks through the spectrum of strategic objectives
supports a more targeted and efficient audit.
Allot (in Castanheira at al. 2009) specifically identifies that risk-based internal auditing
has increasingly made significant contributions to effective risk management. After re-
cent economic happenings, Bechara and Kapoor (2012) notice that companies around
the world increasingly rely on internal auditors for their business understanding and ap-
proach in risk identification and risk mitigation measures.
20
A study by Castanheira at al. (2009) concludes that the number of organizations applying
risk-based approach for planning is generally high in the financial industry. Za´rate (in
Castanheira at al. 2009) argues that as the financial industry is more advanced in terms
of risk management, due to regulatory requirements, so there are more organizations in
the financial industry that apply the risk-based internal auditing approach.
As explained in section 4.1 above, risk-based internal auditing involves performing risk
assessments in the audit planning stages. According to McNamee (1997), in planning
for the IA activity (macro level), risk assessment shall be performed to identify, measure,
and prioritize risks so that focus is placed on the areas that are threaten by higher degree
of risks. In planning individual audit engagements (micro level), risk assessment is used
again to helps identify the most significant audit areas, based on that the auditors design
a work program that “tests the most important controls, or to test the controls at greater
depth or with more thoroughness” (McNamee, 1997). Indeed, a study of internal auditing
practices in Ireland by the IIA – UK and Ireland and KPMG Ireland (in Castanheira et al.
2009), found that 89 percent of internal audit departments uses the risk-based approach
when planning annual internal audit activity and 93 percent uses a risk-based approach
in their audit engagements.
The risk assessment at the macro level is also called “enterprise risk assessment” in
some organizations’ methodologies. In enterprise risk assessment, strategic risks related
to the whole organization’s strategies and objectives are identified and assessed. Also
key processes that mitigate strategic risks are identified. In other words, the enterprise
risk assessment focuses on the organization’s “as is” strategic risk profile and drives the
development of an internal audit plan.
During the risk assessment processes, interviews are often conducted with management
personnel to obtain information regarding: the organization’s vision and strategies; sig-
nificant business processes and their objectives; key risks which impact the achievement
of vision, strategy, and/or objectives; risk impact and likelihood to the organization; and
management’s assessment of the effectiveness of the processes and controls the com-
pany has established to manage those risks. A significant process is any process that is
21
associated with and manages a strategic risk to the organization’s objectives. The busi-
ness processes included in the internal audit plan, in general, are those processes that
the organization has established to manage the most significant risks to the organization.
Other inputs for enterprise risk assessment include business and industry knowledge
and information from the previous internal audit, if available.
The identified risks are then ranked according to the pre-defined criteria. Information is
collected on management’s perceptions regarding:
• Gross risk - The significant risks to the organization’s objectives that must be
managed well to support the achievement of those objectives, regardless of the
effectiveness of the processes and controls implemented to address those risks.
• Residual risk - The remaining level of risk to the organization’s objectives once
the effects of existing business processes and controls are considered.
Next, the areas and business processes to be audited are determined and prioritized
based on the perceived risk (either gross/inherent or residual/exposure).
Process level risk analysis may be performed as part of the enterprise risk assessment
to either gain further understanding of a significant process or business unit or later per-
formed as part of the internal audit execution, to assist in the scoping of a particular
internal audit engagement. For example, as a result of the enterprise risk assessment,
the financial reporting process may have been identified as a high risk area for the or-
ganization. In order to better understand what areas of financial reporting process are
the higher risk areas, further risk analysis at the process level may be necessary.
Documentation for the process risk analysis often includes narrative description of pro-
cess with flowcharts, strategic risks that the process is associated with, process level
risks and established internal controls, process risk matrix which shows the relationship
between the impact and the likelihood of the occurrence of the identified process risks
and their relative significance.
22
Finally, the IA Plan is developed based on the outcomes of the risk assessment exercise
or the enterprise risk assessment. In addition to the business processes identified during
the risk assessment exercise, other processes/projects may be selected for inclusion in
the IA Plan. These internal audit projects may be identified through specific requests
from the organization’s management and/or the audit committee based on issues they
believe are important to the organization, follow-up reviews associated with a prior inter-
nal audit projects, and any other areas of concern discovered over time that are approved
by the audit committee for addition to the IA Plan.
In conclusion, inputs to the internal audit planning could typically include a combination
of the following:
• Outcomes of a risk assessment (enterprise and process risk), including key risks
and associated internal controls.
• Requirements from management and/or audit committee.
• Industry information.
• Results from external audits and reviews.
• Previous internal audit results.
When using an enterprise risk assessment to develop the IA Plan, the number of strate-
gic and/or process risks may be relatively large, generating an extensive list of audit
projects for potential inclusion in the IA Plan. Internal auditors then consider the results
of risk assessments, process analyses and other information with professional judgment
in scoping the audit projects to be included in the IA Plan.
The internal audit plan, even once approved by the audit committee, is inherently dy-
namic and may need modifications over time as various factors associated with the or-
ganization’s internal and external environment evolve and impact the organization’s busi-
ness. Therefore, it is industry practice to develop a strategic internal audit plan of two to
three years with a detailed internal audit plan for 12 months that is subject to at least an
annual update. The audit engagement teams should monitor the relevance of the ap-
proved IA Plan and suggest necessary updates to reflect the evolving risk profile of the
organization. The IA Plan maintenance process may be also formally carried out through
formally revisiting the enterprise risk assessment and resulting internal audit projects
23
periodically through the year. Many organizations establish a quarterly process, typically
coinciding with quarterly audit committee meetings, for reviewing internal audit progress
for the quarter, discussing significant issues identified during that quarter, and evaluating
proposed modifications to the IA Plan for the remaining period of the year. In any case,
regardless of the specific timing and nature of the update process, open lines of commu-
nication should be maintained and available between key internal audit stakeholders
when events arise requiring decision-making in periodic audit committee meetings.
Once the IA Plan is approved, internal audit engagement execution, including develop-
ment of an engagement plan, a work program and test procedures, is carried out. Internal
audit activities are performed in this process based on the understanding gained through
enterprise risk assessment, internal audit planning and process risk analysis, if any. Dur-
ing this phase of the Audit Cycle, internal auditors according the audit methodology focus
on providing findings and performance improvement opportunities to the organization.
The following activities by order are normally conducted during the internal audit execu-
tion phase:
A process risk analysis performed at the beginning of the execution phase is aimed to
serve as a risk-based scoping exercise for the development of an effective and efficient
work program which focuses work efforts on key areas to the business process. The
extent of work performed for the process risk analysis is dependent upon the level of
work performed during the enterprise risk assessment. If the risk assessment for plan-
ning the IA activity is developed without some form of process-level analysis, the IA Plan
will be more general in nature and will tend to be focused on gross risks at the strategic
24
level. In that situation, additional work will be required during the planning and scoping
stage of each engagement in order to develop an effective and efficient work program.
A process risk analysis is an important tool for determining the scope of an internal audit
engagement. Similar to the enterprise risk assessment, this is commonly performed
through interviews and discussions. These interviews and discussions are typically con-
ducted with those individuals who are familiar with the process, such as process owners
or control owners. The process risk analysis is often briefly described with workflows.
The analysis will provide the basis for scoping individual audit jobs.
When performing process risk analysis, internal auditors analyze how the process is
managed against leading practices, e.g. industry standards and guidelines, regulator’s
expectations and other published leading practice information. Ultimately, the appropri-
ate practice to the organization will be the one that supports the organization achieve its
strategic objectives within the context of its processes and structure.
The work program designs test procedures to be carried out to assist internal auditors in
assessing the organization’s existence and effectiveness of internal controls established
to mitigate risks.
To build the internal audit work program for an audit engagement, internal auditors
should be aware of risks and controls associated with the activity in review. As this un-
derstanding will help determine the focus areas for testing. The work program will focus
on testing of internal controls that associated with the prioritized risks identified. But if
control the design of a control is found not good or the control is not operating, it may not
be necessary to test internal controls.
Table 2 below shows simplified examples of how test procedures of a work program can
be determined based on the process risk analysis.
25
Risk ID Process Control Strength of Process risk Considerations for test procedures
risk - control design – Residual
Gross
1 High A Strong Low Test if control is operating and ef-
fective as designed.
2 High B Weak High Control inadequacy issue is noted.
Reevaluation of control design is
recommended.
3 Medium C Strong Low Test if control is operating and ef-
fective as designed. Risk may be
over controlled. Consider a cost-
benefit analysis.
4 Low D Strong Low Not a focus.
For example, control A that moves risk #1 from an unacceptable level to an acceptable
low level. Normally in this case, test procedure is to test if the control is operating effec-
tively as designed. Regarding risk #2, control design is assessed as weak, so it is nec-
essary to reevaluate the control design.
Test procedures in the program should be created with flexibility so that they can be
modified using auditors’ professional judgement but at the same with sufficient guidance
for the auditors to understand and follow. Test procedures should be also effectively
designed so that sufficient evidence can obtain to meet audit objectives while least efforts
are made. The effectiveness of an internal control should be assessed in two perspec-
tives, its consistent operation and the outcome of the control.
• Tests of design are associated with the internal control design and is primarily
performed during the process risk analysis.
• Tests of effectiveness confirm whether key internal controls identified during
process risk analysis are in existence and are operating effectively as intended.
26
All test procedures should be referenced to the work papers. In the internal auditing
practice, internal auditors are required to document work papers adequately and suffi-
ciently with traceability. Especially, test evidence should be clearly documented in the
work papers so another person is able to draw the same conclusions when reviewing it.
In addition, work papers should be signed and dated by the preparer and the reviewer.
Finally, there should be a positive link between the test procedures with the scope de-
fined in the audit engagement plan.
4.2.7 Reporting
An audit report is the means to communicate internal audit activity’s results. Regarding
the report content, it is important that the reported results are adequately and clearly
supported with the work papers. Findings in Internal audit report should agree to findings
in the work papers, which in turn should agree to the supporting evidence.
When applied thoroughly, reporting under the risk-based internal audit methodology pro-
vide the management with information if there are areas that are identified as having
unacceptable residual risk, or areas that can be better optimized to effectively manage
the strategic and process risks.
Regarding the traceability among different documents throughout the Audit Cycle,
McNamee (1997) emphasizes there should be a clear link between the audit objectives,
the objectives of the audited unit, and the organization's strategies and objectives. The
audit objective should be “related to the risks faced by the auditable unit in its effort to
meet its established objectives” (McNamee, 1997). An effective risk-based audit plan
should start with the organization’s strategic objectives because risks are only relevant
in the context of these objectives (Bechara and Kapoor, 2012). Audit tests in the work
program are then designed to obtain sufficient evidence supporting the audit objectives.
27
5 RECOMMENDATIONS
The analysis of best practices in chapter 4 shows that the case company’s current IA
methodology is largely aligned with the professional standards (i.e. IPPF) and practice
in general and with the financial services industry practice in particular.
Firstly, the IA function applies a three-year Audit Cycle with a detailed annual audit plan
that is subject to the annual review and update.
Thirdly, the IA activity plan is based on both bottom-up analysis (risk assessment) and
top-down analysis (by considering requirements from management, audit committee and
regulatory environment). The IA activity plan is flexible which means modifications, sub-
ject to appropriate approval, are possible when various factors associated with the or-
ganization’s internal and external environment evolve and impact the organization’s busi-
ness.
Finally, the execution of individual audit jobs determined in the IA activity plan follows
steps similar to those observed in the industry which are scoping, work program building,
work program execution and reporting. The IA methodology also includes templates e.g.
audit engagement plan and establishes criteria on certain documentation e.g. sufficiency
criteria for work papers.
28
However, the author has identified some aspects in the methodology and documentation
templates that could be considered for improvements in order to meet the IPPF’s Stand-
ards 2201 and 2210. The following sections will discuss on these aspects together the
improvement proposals.
As described in section 3.1.1 above on the Audit Cycle applied in the case IA function,
the risk assessment performed for planning the IA activity is developed with some form
of process-level risk analysis. For each auditable entity, it is established in the audit
methodology that inherent risk shall be assessed for all three elements that make up the
audit universe: process, company group, and activity/business. Assessment of inherent
risk to processes is calculated based on applicable risks to them (from a list of 10 risks
mentioned in section 3.1.1) and, for each risk, based on impact and probability of risk
events occurring. Then, the residual risk of each process is determined by subtracting
control environment from inherent risk. Whether a process will be included in the Annual
Audit Plan or to be audited within 24 months or 36 months of the three-year Audit Cycle
depends on its residual risk scoring result.
The assessment of process risk at this level under the current IA methodology helps
identify and prioritize processes that carry higher risk in the audit universe to be included
in the IA activity plan. But it does not well indicate which areas in the process are of
significant concern. Applying a standard work program to execute the audit, a require-
ment established in the current IA methodology, without an audit focus therefore can be
a challenge to the audit team as all standard work programs are massively designed.
A process risk analysis with an aim to gain a deep understanding of process helps re-
solve this constraint. It analyzes essential aspects of a process including process objec-
tives, critical success factors (CFS), key performance indicators (KPI), inputs, outputs,
activities together with the associated risks and internal controls. It is a normal practice
that such process risk analysis is performed at the beginning of an audit to help internal
auditors identify significant areas of the process that need an audit focus and then build
a right work program that effectively and efficiently achieve audit objectives. The analy-
sis of process objectives, means by which the process controls its performance (e.g.
CFS, KPI), significant risks to the process and means to keep them to an acceptable
29
level, are also requirements set by the IPPF’s Standards 2201 on Planning Considera-
tions and Standards 2210 on Engagement Objectives (refer to Appendix 2 for details of
two Standards).
Considering the benefits of process risk analysis analyzed above, the author proposes
to apply also a risk-based approach in planning audit engagements using a process risk
analysis. This is risk-based approach at the so-called “micro level” (Castanheira et al,
2009) in addition to the risk-based approach at the macro level performed earlier to de-
termine the IA activity plan.
The process risk analysis will be part of the Audit Engagement Plan document. Instruc-
tions on how to perform the analysis can be an additional annex to the manual. The
analysis can be conducted through interviews and discussions with those individuals
who are familiar with the process. “The more respondents interviewed, the more com-
prehensive and in depth the insights will be” (Bechara & Kapoor, 2012). Internal auditors
can also conduct a survey to get more understanding on the process activities, risks and
associated controls, and to invite comments and suggestions from the auditees accord-
ing to the IPPF’s Practice Advisory 2210.A1-1 (see Appendix 2 for details). Manage-
ment’s own assessment of risks associated with the activity under review could be con-
sidered as well according the same Practice Advisory. Another possible consideration is
to establish a line of communication with the company’s risk team in order to receive
information about risks and remediation activities on a regular basis which will be used
as inputs to planning an audit engagement. Investing in such relationships is one of 5
bold steps to transform internal audit image according to Chambers (2014):
The most critical component of "trusted advisor" is trust, and trust depends on a
solid relationship. The CAE cannot alone build and sustain relationships. The entire
internal audit team must be invested in the process.
Finally, when the risk-based internal auditing is applied, it is the strategic objectives, their
associated risks and risk responses that act as a central point connecting documents
created throughout an Audit Cycle. For that reason, the risk-based approach and this
central point should be clearly and consistently expressed and emphasized throughout
the IA methodology manual.
30
In order for the Audit Engagement Plan to be connected with the IA Plan, there is a need
to underline in the IA methodology that the audit objectives should be aligned with those
preliminarily determined during the planning phase of the IA activity. There is also a need
to highlight that the process risk analysis is aimed to further refine the initial audit objec-
tives set in the IA activity plan and to identify other significant areas of concern. These
aspects are recommended by the IPPF’s Practice Advisory 2210-1 on Engagement Ob-
jectives (see Appendix 2 for details of the Practice Advisory). The final audit objectives
should be related to the “risks faced by the auditable unit in its effort to meet its estab-
lished objectives” (McNamee, 1997). This is especially important when the audit tools
used for the IA planning (AudiNet) and for the engagement planning (MS Word for prep-
aration and TeamMate for filing) are not integrated together.
In addition, in order to ensure the traceability between the Audit Engagement Plan and
the Work Program, the IA methodology manual and its templates should underline that
the final audit objectives determined in the Audit Engagement Plan be fully reflected in
the Work Program. Test procedures in the Work Program are then designed to obtain
evidence supporting the audit objectives. The test procedures should focus on internal
controls that associated with the prioritized risks identified in the process risk analysis.
However, it may not be beneficial to test a internal controls if it is known to have sub-
stantial issues in either design or effectiveness.
When a standard Work Program is selected for the audit, the methodology should be
flexible in the way that allows the team leader to modify pre-defined audit objectives and
test procedures in the standard Work Program to match with the audit objectives defined
in the Audit Engagement Plan.
Finally, regarding the audit report, which is the outcome of an audit, it is important that
the reported results are adequately and clearly supported with the work papers. Accord-
ing to McNamee (1997), in order to demonstrate that a risk-based approach has been
used for the audit, the following three aspects should be considered in the audit report:
31
1. The scope part includes a risk assessment result with brief description of identified
risks and associated controls.
2. The findings and recommendations part is “discussed in risk terms and reference
the key risk areas in the audit scope section”.
3. The overall conclusion part is focused on “discussing risk and management's re-
sponse to risk as the primary result of the audit”.
6 CONCLUSIONS
The thesis was aimed to review again the case company’s Internal Audit methodology
and then suggest improvement opportunities to solve the problem identified during the
quality review.
The qualitative research methodology was utilized in this study. The study started with a
thorough analysis of the current internal audit methodology and practice. Next, best prac-
tices on the areas of problem were gathered and analyzed from a literature review and
from the author’s previous experience as a consultant of a global leading auditing and
consulting company. Based on the results of the best practices review and considering
also the objectives of the IA function and the IPPF, solutions to the problem were con-
structed.
It is recommended that the IA methodology manual express and emphasize more clearly
on the risk-based internal auditing approach and that the strategic objectives, associated
risks and risk responses act as a central point connecting documents created throughout
an audit cycle.
32
In order to get the improvement suggestions implemented, the author suggests the fol-
lowing steps to be carried out:
REFERENCES
Bechara, M. and Kapoor, G. (2012): “Maximizing the Value of a Risk-Based Audit Plan”,
The CPA Journal, Vol. 82, No. 3.
Brink, V.Z. (1991): "Forward from Fifty", The Internal Auditor, vol. 48, no. 3, pp. 8.
Castanheira, N., Lima Rodrigues, L. and Craig, R. (2009): “Factors associated with the
adoption of risk‐based internal auditing”, Managerial Auditing Journal, 25(1), pp. 79–98.
Chambers, R. (2014): “5 Bold Steps to Transform Internal Audit's Image”, the IIA’s Inter-
nal Auditor Magazine, [Online], Available: https://iaonline.theiia.org/5-bold-steps-to-
transform-internal-audit-image [27 October 2016].
Colbert, J. and Alderman, C. (1995): “A risk‐driven approach to the internal audit”, Managerial
Auditing Journal, 10(2), pp. 38–44.
IIA (2009): “Practice Advisory 2010-1 Linking the Audit Plan to Risk and Exposures”.
McNamee, D. (1997), “Risk-based auditing”, Internal Auditor, vol. 54, no. 4, p. 22.
Theiia.org (2016a). The IIA’s Official Website. “About the IIA”, [Online], Available:
https://na.theiia.org/about-us/Pages/About-The-Institute-of-Internal-Auditors.aspx [27
October 2016].
Theiia.org (2016b). The IIA’s Official Website. “Definition of Internal Auditing”, [Online],
Available: https://global.theiia.org/standards-guidance/mandatory-guidance/Pages/Defi-
nition-of-Internal-Auditing.aspx [09 October 2016].
Theiia.org (2016b). The IIA’s Official Website. “Standards and Guidance”, [Online], Avail-
able: https://global.theiia.org/standards-guidance/Pages/Standards-and-Guidance-
IPPF.aspx [20 October 2016].
35
APPENDICES
• The significant risks to the activity’s objectives, resources, and operations and
the means by which the potential impact of risk is kept to an acceptable level.
2. The risk assessment during the engagement’s planning phase is used to further
define the initial objectives and identify other significant areas of concern.
3. After identifying the risks, the auditor determines the procedures to be performed
and the scope (nature, timing, and extent) of those procedures. Engagement pro-
cedures performed in appropriate scope are the means to derive conclusions re-
lated to the engagement objectives.
3. If appropriate, internal auditors conduct a survey to become familiar with the ac-
tivities, risks, and controls to identify areas for engagement emphasis, and to
invite comments and suggestions from engagement clients.
41
4. Internal auditors summarize the results from the reviews of management’s as-
sessment of risk, the background information, and any survey work. The sum-
mary includes:
• Significant engagement issues and reasons for pursuing them in more
depth.
• Engagement objectives and procedures.
• Methodologies to be used, such as technology-based audit and sampling
techniques.
• Potential critical control points, control deficiencies, and/or excess controls.
• When applicable, reasons for not continuing the engagement or for signifi-
cantly modifying engagement objectives.
42
Audit Plan
43
1. AUDITED UNIT
• Identification of the audited unit, business, activity or process.
3. WORK TEAM
• Composition of all auditors assigned to the job and number of days as-
signed to each member.
6. PRELIMINARY INFORMATION
Description of all relevant aspects that contribute to knowledge of the situa-
tion, complexity, or problems of the audited unit and its activity will be in-
cluded. For example:
a. Rating and the most significant aspects of the previous audit.
b. Organizational chart, unit's business, and significant changes.
44
8. CONCLUDING DOCUMENTS:
Indicate the final audit documents established according to the methodology:
• Audit Report (with or without rating), Audit Note, Audit Certificate or Con-
sulting Note
Place, Date
(Signed)
Team Leader
Reviewed and Approved