Generally conforms?


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I am belatedly setting my objectives for the coming year, both for and at work, and also personally. It’s a good thing to stop and think about what you wish to achieve and setting measures and metrics to assess those.

Whilst I know every chief audit executive considers their audit service to be more than just themselves, there is a still a temptation for it to be seen as, and genuinely be, a reflection of the CAE leading it. This is especially so in internal audit for two reasons. First many audit services are relatively small, so the span and depth of control of the CAE is relatively all encompassing. Second because internal audit provides a principles based framework of standards and compliance, that allows quite a wide latitude to how the actual service manifests itself. Third, internal audit services are held together by their methodology. This methodology is not just the processes and documentation used by the service, but is also a view on the world, which is as much intellectual and ideological as it is practical and process based.

So that’s why, when I: set the standards for the year for my service; review the templates and processes; and when I look at the skills and needs I have for my service, I am as much as anything else, reflecting on my own development and view of the world. I take a granular interest in this things; they matter. I have said in this blog before (Radio Four or Three auditing) much like a business, internal audit has a brand. This brand is set and controlled in large part by the CAE. They set the tone, basis of engagement, style, content and method of engagement with their clients.

My current team will, no doubt, say that I am too detail focused and obsessed with format and style. Like a top restaurant or a upper class retailer, the image and the way the service is delivered is as important as the content (though in my view one must be supported with the other). This is inculcated from the methodology, the training, the leadership (in practice) from the CAE. It is enforced through quality assurance and review. Eventually in my experience the team will self edit and review with very little input from the CAE.

So what should be the bedrock for those standards? I think it should be the International Internal Audit Standards. These have, built in, the need for compliance. In particular the need for an external quality assurance assessment (EQA) by a competent third party every five years. There are many ways in which reviewers assess these standards, but the one that seems to have gained traction is the ‘fully / generally / partially / does not conform to the standards’ opinions.

When I’ve been benchmarking services, I’ve found that ‘generally conforms’ is the most given opinion. Generally conforms ‘indicates that an IA activity has a charter, policies, and processes that are judged to be in accordance with the Standards, with some opportunities for improvement’. So that sounds good. Or does it?

If we look up the word ‘conform’ it means comply. That means meeting the standard. So it is a binary judgement. That must therefore mean generally conforms also conversely means also, does not comply in parts. It seems odd to me that a profession obsessed with being ‘risk based’ would then have such a two dimensional, binary, and non risk based compliance opinion applied to itself. So is a ‘generally conforms’ service at significant or minor risk of not meeting its objectives? How impactful are the areas of non compliance? Not complying with ethics is presumably much worse than not issuing a form of opinion on an assignment level piece of work, or not immediately drawing the board’s attention to an error in an audit report? Who knows?

When I had my service’s EQA at the beginning of this year I was clear with the reviewing party that I did need the requisite badge, and yes expressed in terms of compliance, but that I was much more interested in how good that compliance was. Did my internal audit service make a difference to my client? In other words did the work of my service amount to a whole hill of beans or not?

That’s not something that is so easy to express. Particularly in terms of the Standards, as the Standards require basic compliance only. They do not require any particular measure of quality. Compliance with them neither guarantees nor prevents quality audit work being done. As an example let’s take attribute standard 1100:

Threats to independence must be managed at the individual auditor, engagement, functional and organisational levels.

Well you either do or do not manage independence at these levels. The standard does not require it to be done well, or to a low risk appetite, or high quality, merely to be done. Let’s take a performance standard:

The internal audit activity’s plan of engagements must be based on a documented risk assessment, undertaken at least annually. The input of senior management and the board must be considered in this process.

Again – there is no requirement for the risk assessment to be good or high quality. Merely for it to exist, be done annually with input from senior management and the board. So I wonder, how do so few audit services not fully comply? I consider the Standards, therefore, in terms of a risk based quality delivery, to be merely the basis and required baseline framework. I ask again how then do so few audit services obtain fully compliant?

I expect and inculcate in my audit team a methodology and set of professional standards and ethics that mean they naturally comply with the Standards, both collectively and individually. This does take time, but high quality auditors will comply with the standards without even thinking about it. I know and trust my team will comply with the standards, because they know that they should and because I, and my senior team, have inculcated good internal audit as an instinctual response. That does not mean I don’t check and review, and never have to correct the tiller individually or collectively to make sure it remains so. Nor does it mean I do not undergo an EQA as required (indeed it’s a useful process).

For those of you wondering about my EQA, my service was deemed fully compliant, as well as identifying things that I and my service could do better and more of. That’s a long way from non compliance in my view, and as internal audit has so much expectation upon it now, can any of us afford not to comply?

School’s out, Summer and audit are in


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So my team and I have just despatched our latest set of audit committee papers for our last audit committee meeting before the Summer. Producing audit committee papers, I was reflecting, is part of the rhythmic heartbeat of any auditor’s life. It’s been part of mine for nearly 20 years. The Summer break, however, got me thinking about what it would be like not to have that.

I like the Summer. Yes the longer days, the sunshine, the general positivity of being in nicer weather. I like it as an auditor, especially as it gives me a chance to do audit work without the ‘distraction’ of reporting to a committee or the senior management team, and in my current role, ministers. Sure people in the audit team are on holiday, but there are always some around at any point in time. My current team is split between London and Glasgow, so even these holiday periods are naturally staggered. Yet there just seems to be a little more quiet time to do project work. To sit, pause, think, and gather our collective thoughts.

I was asked to do a lessons learned paper about my and my team’s work this week. I think we as a team are a learning team and I am a learning individual. As a consequence sitting and doing a lessons learned thing seems alien to me as we and I learn and adapt constantly. Every audit and counter fraud investigation is a project, from which we learn, tweak, adapt and improve. Yet the stepping back, in the space that Summer affords, does strike me as a useful thing. A chance to pull together and enhancement plan, a set of lessons from the audits and counter fraud work of the year.

Summer will also be a time to reflect on my team. Where do we need to be? What does next year demand? How best will we be shaped to meet that demand? I am not one to leap to restructure, as this is often an attempt to look busy and is a lazy way of creating change. There may be some restructure, but actually I think our team collectively thinking about what the future looks like will be important.

So whilst Summer, our Q2, can appear relatively quiet, actually in audit terms it is when the fieldwork really gets done and change and enhancements to the processes and systems are able to be done. Our CEO likes to suggest or at least, post Summer share, his Summer reading. I think, for those of my team not studying (and most will have sat examinations this month) it’s a good chance to take some reading on. At present there is precious little new thinking I’ve seen in internal audit. No one is really pushing the profession on, or doing the blue sky stuff. Perhaps Summer might be a chance for us collectively to write, rather than read?

I am now also a member of three audit committees. This is a great thing for any auditor, to be the other side of the table. It’s a chance to engage with other auditors, which I think is a good thing, a chance to have a sense of what it is like to be a non executive (it’s a hard role actually). There are lots of charities, housing associations etc. that need good audit input, I would recommend all auditors do one as part of their public service as well as professional development. I will have had my first taste of these committees before Summer comes along, so Summer will be a chance to reflect on these initial experiences and then engage with the organisations fully in the next year.

So yes Summer is, for many, a chance to refresh and recharge batteries, but in audit I think it’s a crucial period for the heavy lifting that makes a real difference to the rest of the year, to be done. Yet I would not be without the rhythm of audit committee cycles. All professions have them (management accountants, IT, marketing, HR etc), they also give a real framework within which to work and organise yourself. So yes Summer, for me, is a great period of structure free reflection, which I intend to use well this year but I will look forward to the start of the new ‘term’.

So what will you be doing for your Summer?

Risk is not bad! Celebrate it!


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So I’ve been thinking about risk. I had the pleasure of attending a course on risk hosted by Norman Marks and Richard Anderson. Norman has a great blog NormanMarksBlog. Richard is a trainer and general risk guru AndersonRisk. I’ve also given my annual assurance opinion, which requires me to opine on risk management systems. We’ve also had a new head of risk start at my client organisation and all of these are making me think afresh about what good risk management looks like.

So I’ve been working hard over some period of time to advance my risk thinking with my audit team, my client organisations, and my professional audit colleagues. In particular my view that risk is simply not bad. Risk is just a description of fact. Theoretically perfect, risk management is just a 100% accurate description of the world at a point in time. If we could imagine how the perfect information world would be, we would understand the full factors impacting the uncertainty of the achievement of our objectives. This is the aim scientific risk management, quant risk management, aims for.

For most organisations outside of banking, and most risks, are not prone to cost effective mathematical modelling, so we make do with judgements. These judgements are those that the management team does every day. So what then is the difference between risk management and just management? Well I think it the difference is between the natural tendency of managers to focus on the here and now, to solve issues. Real risk management is designed to allow risks and uncertainty to be more easily foreseen and addressed, so that issues and proximate risks do not occur. So in a way, busy, issued-focused management is a failure of risk management.

So why is risk not bad if we try to avoid it so much? Well risks flow from objectives. If you or your client organisations are not sufficiently ambitious enough then they are likely to yield poorer performance. This can be financial, but could be social. So a charity campaigning for diversity and against discrimination is unlikely to be successful unless it pushes itself to challenge the status quo, to stimulate and create change. Risk is not bad then – we need risk management to be successful overall so that our objectives are achieved.

Getting organisations to see risk and its crystallisation as a good thing takes time; for all ambitious organisations take on risk, and some of it will, inevitably, crystallise. We, as auditors, are partially to blame for risk aversion. We code our risk based reports with colours equating risk as bad, ‘red’. Yet my greatest audit achievement is to get an audit committee to celebrate and endorse a red risk report. Yes risk was high, the likelihood of achieving objectives was highly uncertain, and no, I could not give positive assurance, for the outcome was so uncertain, how could I? Yet I said red was fine. Red was where the organisation wanted to be. Red came with it high costs and likelihood of failure, yet it also came with high rewards. In this case, the saving of millions of people’s lives. So it was good risk. Good risk to take.

Sure, risk at that level across the whole organisation is bad, for the whole organisation could fail. Yet how many businesses do take massive risks? Apple has the majority of its profits arising from one single product line, the iPhone. So each update carries with it massive risk. Will we look at Apple in ten years as the Blackberry of the future? Possibly. This risk could, however, be the source of their further success.

So we as auditors are not there to stop organisations taking risk. We are there to enable them to take more risk. To help and assist build risk management intelligence and capacity. We are there to make organisations more conscious and capable of handling and handing off risk. For a good risk management system surely allows more and more complex risk to be taken?

The key point for audit is to ensure that objectives, the risks that flow from those objectives, mediated through appetite, lead to a sensible allocation of risk management resource and capacity. For where any single of those elements is out of kilter, then organisational failure occurs. Our role is not to take pseudo executive responsibility for what risk is good or bad. We should point out where risks are not properly governed, well resourced to be managed, well understood or analysed. The only time, in my view, risk is bad, is if it breaks the law (the law is not a risk based judgement) or if it threatens the very existence of the client organisation you are working with.

So how will you celebrate risk with your clients?

Clearing out the wardrobe


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One of the tasks I get around to not nearly as frequently as I should, is to empty out my wardrobe. I periodically review all of my clothes and ask myself ‘Does it still fit?’ ‘Did the reason I bought this still exist and make sense?’ ‘Is it worn out?’ ‘Is it still in fashion?’ Then the killer question – ‘have a I worn this in the last six months or year?’.

I end up putting a whole section of my wardrobe in the bin or take it to the charity shop. I also rediscover items I forgot about and looks and items that I loved once, and can still see me wearing.  This then clears space for new items, new fashion, new (sadly more age-appropriate) items. This is a win, win: lots of additional space; an excuse to shop; and better and newer looks for my work and social life. It’s a great process and makes you feel great.

So if this is so good for me, why don’t I do this periodically? Well it is generally because it takes time. It takes time to sit and go through a wardrobe. It’s easier to add rather than subtract. It’s easier to buy something new when I have ‘nothing to wear’. If I don’t think about it I buy the same sorts of items and styles, because I know they are fine and comfortable. It’s a change-avoidant process.

I think internal controls in organisations are the same. Organisations rarely step back and declutter their control frameworks and actions. People continue to do stuff because it is familiar and comfortable. I’ve asked management colleagues why something is done the way it is. What’s the risk it is intended to manage or mitigate? Why do you do this manual thing when something newer and simpler could be done. Organisations have a tendency, and we as auditors can be at best collusive, and at worst encouraging, of more and more controls added.  No management team has endless resource, but yet when something goes wrong they and their organisations rush to fix it with more process, more controls, more stuff to do.

So, accepting that it is easier to add then redesign or remove controls, why don’t more organisations empty their control ‘wardrobes’? I suspect because this requires thought. It requires time. It requires clear thinking. First it requires clear objectives. A clear and granular identification and then assessment of risks arising from those objectives. Then a mapping of current activity, processes, controls and resources to those risks. Then, finally, a confidence to stop doing things, move and divert resources. More than that, this process needs to be repeated periodically, and relentlessly, to maintain the efficient operation of the organisation.

Of course, it’s a paradox that the better an organisation is at risk, the less likely to be efficient at control it is. For crisis is the mother of invention and hard working. Choices in activities, resources, controls and activities are not going to be made, I’ve noticed, unless an organisation no longer has big profits and is in crisis. One reason why startups and small organisations are so inventive is because they have to be. They have to be more efficient and effective and make choices in what they do. Large, profitable, organisations are much less likely to be forced to make difficult choices and prioritise activity.

As internal auditors we should be at the vanguard of organisational improvement and be the pressure on successful organisations to continue to be more efficient. I am unlike the normal expectation of the CAE. I am not particularly rules based, I much prefer principles focused on tangible outcomes required. So I try not to just add control, but instead ask for meaningful control. I am, however, guilty as charged in that I do generally require more control, not less, normally for good reasons but oftentimes because I simply like the order control brings.

So can I take my wardrobe emptying task to work and should I? I think the answer to both will be yes. Will you?

Fraud assurance


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In my current CAE role I also have responsibility for counter fraud. This is not unusual. Lots of CAE’s have this role and remit. Yet does my professional training prepare me for this work? Is it a sensible fit?  Having done this now for three years I think that it is, but that my preparation and ongoing support for it has been lacking.

First, I think that the counter fraud world does not have the same professional rigour and maturity as internal audit. There are some helpful and useful qualifications, for example the ACFE (though the law component is heavily US based and less helpful in an international context). There aren’t the professional standards and maturity of quality assurance processes or body of established best practice that internal audit has.

I think the real world of practice is somewhat less defined than internal audit. So counter fraud functions can vary significantly in scope, remit and quality. A lot is driven by the nature of the counter fraud task and whether the host organisation is a prosecutorial authority. Where the organisation is, the legal requirements tend to drive the form and nature of the counter fraud function.

I also think there is a lack of an obvious talent, career and training structure for counter fraud professionals. This allows quite of charlatanism with the ‘secret squirrel’ people hiding their lack of clarity about their role behind faux confidentiality requirements (in my view counter fraud work needs to emerge from the organisational shadows and be seen as a more mainstream part of organisational ecosystems). So it is difficult to identify what good talent looks like and to measure, accredit and reward it.

There is the perennial issue of second and third line responsibility. The three lines model was conceptualised for audit and assurance, and maps awkwardly to counter fraud work. Counter fraud investigations work is clearly best done in the third line – whistleblowing at its heart is meant to be independent of management (for that’s who whistleblowers are either directly or indirectly complaining about). That’s why this strand of work is, in my view not just a bedfellow of internal audit (as an independent part of the organisation) but an integral part of it. There is a need for a second line function to set policy and take risk decisions for countering fraud and to make the first and second lines collectively counter fraud. Yet the problem is that all of the professional structure, discipline, career training paths, and data sit inside the third line function.  Lots of organisations have directors of risk and assurance who straddle both the semi independent second line functions and independent third line functions. Here the three lines model starts to intellectually break down and lose its clarity and coherence. For how independent is the third line in this model?

Then there are the practical elements of the counter fraud function. What skills do you need? Well an understanding of risk, governance, audit, forensic work, finance, assurance etc. These are (or should be) found within a good internal audit function. Yet counter fraud only professionals, with their detailed, bottom up, mindset lack the necessary grip of systems, processes, controls, assurance and governance to deliver two of the three core elements of counter fraud work – proactive investigations on a risk basis and fraud assurance to prevent reoccurrence. Here internal audit skills score highly. For the record, internal audit staff also lack the scepticism, detail focus, analytics, bottom up skills that counter fraud professionals have.

So there is a real challenge here about counter fraud. Outside of those organisations that have law enforcement as their core task, the clarity of this role breaks down. I think therefore this space is nationally and internationally up for some work, some clearer and better thinking through what excellence in terms of delivery looks like. I do think the international space has set out some good markers. In the World Bank it has invested a significant sum of money in an independent  counter fraud function. This has significant resources and headcount, but does not map well across other compliance and assurance functions as a result – for example with internal audit or legal. Most UN agencies and multilateral agencies vest counter fraud alongside internal audit in one inspector general model. This feels right, and is mirrored in my organisation, under me.

So why does it feel right? Well it means that counter fraud work is fully independent of management, yet is within the organisation to be able to support and engage with it. It ensures that risk management decisions are made within the management chain (or if appropriate governance chain). It also brings to bear (or has the potential to bring to bear) the counter fraud and internal audit mindsets and creates a discipline and career structure to the counter fraud activities, not previously open to it.

So then if I as a CAE, and many others like me, take on this counter fraud role, is it about time the IIA globally begins to think about this more carefully and adopt this activity? I think so. Not just so that CAEs like me can have some structure and standards to apply to this work, but so that the work itself has a home to look to in terms of training, career and professional support.

The one percent

We are the one percent. We are the one percent of the organisation, in many cases less than one percent. Yet when we talk crises, problems, governance we are far more. For the lines of defence model we are 33 percent.  For governance we are more; for external auditors check one document to a level of materiality. We check the rest, apparently to a ‘reasonable’ level. 

Yet we as a profession are not yet having a sensible dialogue to link the one percent of resources to the excessive demands and expectations on us. These expectations are collectively, on each service, on each head of audit and on each individual auditor, excessive. 

As a CAE I feel it acutely. The pressure to deliver consultancy, to keep diverse demands of the audit committee, CEO and line management satisfied. For those of you who also have counter fraud I feel this more. For every fraud feels like a crisis and a problem. All fraud matters appear to need salving immediately. Yet we are the one percent. 

I’ve been thinking about what needs to change. I think we, more specifically our mindsets, need to. We need to stop apologising for not being management for we are different. We need to stop apologising for being generalists, for that is what senior management is. We need to stop apologising for saying difficult and unsayable things, for that is our core role. Most of all we need to stop feeling sorry for ourselves and having confidence. Internal audit is a good thing per se

We deserve more than 1 percent. More than one percent of organisational resources. More than one percent of organisational respect. More than one percent of press and public coverage. 

For if all organisations had excellent internal audit to prevent problems rather than expensive consultancy to fix problems the world would be a better place. We should demand more. Demand more pay, more airtime, more people and resources. 

I have been debating with many in our profession who are wedded to the three lines paradigm where internal audit is a small, limited, so-called strategic function; a function smaller than the CEO’s press office or planning office. We need to be bigger and do more. 

The quid pro quo for this investment has to be for us to be better.  No longer failed finance or business people, no more transitory guests on the way to promotion elsewhere in the business. We need the same talent that banking, consultancy or other much less worthy jobs attract. We need at least to have as much thinking and intellectual firepower as our business colleagues in the management team. 

That means the professional firms’ model of sending in trainee kids, propped up with remote reviews needs to change. It means our reporting needs to be consultancy standard or better. It means our thinking has to be at least three dimensional, if not multi faceted. It means our childishly simple colour coded reports need to be more honest and more complex.  We need to leave the solely compliance world behind and integrate compliance work within analysis and thinking. 

In short we need, as a profession, to remove the walls we falsely put around us and grow into the unlimited space within which our management colleagues take risk. 

Do you think the one percent is up to it in your organisation? 

Audit planning: helpful or not?


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Audit planning. It’s that time of the year when I think about my own department’s audit plan. It’s the area that seems to garner the most questions from new auditors and it seems to be the area of our profession where least agreement exists. In particular, what is risk based audit planning?

We all know what we think it is. I would argue there’s very little agreement. If we consider the ask from the standards and the Institute for a moment. It’s a performance standard – so it is about how we do things, not about us per se. So the top level standard 2010:

The chief audit executive must establish a risk-based plan to determine the priorities of the internal audit activity, consistent with the organisation’s goals.

Well this sounds fine until you unpick it a little in particular what is risk-based? So this means prioritisation of work – so we as auditors should look at some things based upon risk. But does this mean gross or net? So the areas the organisation feels it’s most exposed to (high net risk)? Or perhaps the areas where the organisation is least exposed, but works hardest to control the risk (high gross risk)? What sort of risk – financial? Organisational? Repuational? etc. For the risk profile will be very different across these. What about proximity? So the risks that are most likely to crystallise into issues?

Let’s go back to the standards:

The chief audit executive is responsible for developing a risk-based plan. The chief audit executive takes into account the organisation’s risk management framework, including using risk appetite levels set by management for the different activities or parts of the organisation.

So as CAE, the interpretation says I have a responsibility to deliver a risk based plan. This should take into account the organisation’s risk management framework and risk appetite. So take into account? Ignore, register, use, follow, agree, interpret? What? Organisation’s risk appetite. Do we mean individually or in aggregate? So if an organisation has a very high risk appetite, say like Enron, do I have to agree or work within it or provide an override? Hmmm more confusing by the minute.

Let’s go back to the standards:

If a framework does not exist, the chief audit executive uses his/her own judgment of risks after consideration of input from senior management and the board. The chief audit executive must review and adjust the plan, as necessary, in response to changes in the organisation’s business, risks, operations, programmes, systems, and controls.

So I can only use my own judgement where the framework does not exist? Or do I impose my own judgement on it? I must adjust in relation to the client organisation. Well that much seems simple, my plans must in someway work with the client. The direction, type or manner of the adjustment feels quite vague though. If a client does not want me to work in an area, should I do it anyway or work with the client?

Back to the standards:

The internal audit activity’s plan of engagements must be based on a documented risk assessment, undertaken at least annually. The input of senior management and the board must be considered in this process.

Finally – so clear direction. I must have a documented risk assessment. I must take the input of senior management and the board. Great – that’s clear. Let’s go further:

The chief audit executive must identify and consider the expectations of senior management, the board and other stakeholders for internal audit opinions and other conclusions.

I need to take into account management, board and other stakeholders’ expectations. In the real world these often clash and are contradictory. Whose expectations matter more or less? What if my independent judgement is to ignore all of these expectations, say to do the right thing or open all of their minds to something new?

Finally the standards say:

The chief audit executive should consider accepting proposed consulting engagements based on the engagement’s potential to improve management of risks, add value and improve the organisation’s operations. Accepted engagements must be included in the plan.

Consulting arrangements must be included in the plan. This seems strange since most consulting arrangements are ad hoc and arise as needed. All of this seems a little periodic and annual, not rolling or reflecting the speed at which risk and organisations seem to move.

So the standards themselves set some very high level principles and provide very few rules and little guidance. I think that is good, as the CAE should have space to do the right thing in context. It does, however, provide a problem in the real world. What should a CAE do? What is ‘right’ or ‘best’? In particular I think the most confusing and omni-meaning phrase is ‘risk based’.

So what do I call risk based audit planning?

Well on risk appetite I work with the organisation’s risk appetite both in aggregate and at business unit level. That is I report my opinions based on net risk, but decide whether this risk is good or bad depending on the management’s clearly established risk appetite. So an organisation can, in business units, or in aggregate, take high risk. As long as this is legal and is sanctioned by senior management in full consultation of the board, then I work with it. It is not my job to decide whether organisational risk is good or bad, merely to test the reality of control (where control means the adequate management of risk within a risk appetite) and report where this control is inadequate to mitigate risks within established management appetite. I caveat this with two audit overrides: in that something unethical or illegal is not deemed to be within appetite; and that excessive risk in aggregate to the organisation, such that the organisation could fail, are inappropriate. It is my job to report them. Even if the board sanctioned them – so the reporting route would be to the police or regulatory authorities.

On risk based planning I don’t believe in full risk based planning. Partly because this is a path to justifying to the most extreme level, a lack of audit resource. I’ve heard ‘oh we audit strategic risk only’ (despite the fact this statement includes strategic risk which is a  meaningless concept) to justify coverage of an organisation over 20, 40 and record-breakingly 150 year audit cycles. No, no, no. Internal audit needs better coverage if it is to be meaningful. Why? Because there is no such thing as strategic risk. For a start most organisations have no strategy. For those that do, the point at which the strategy becomes both meaningful and auditable is at the ‘set of coherent actions’ level. For most sizeable and complex organisations are such that for a risk to be strategic i.e. organisationally significant and impactful, they are too esoteric. In reality top level risks like a ‘fall in sales’ or ‘loss of competitive position’ are most likely a whole portfolio of actions and activities that need to occur for the risk to be managed or crystallise. So strategic risks have webs of risks and roots that extend into the organisation. So a strategic risk based plan must map out the detail of audit work on those roots to be truly strategic. The issue for me is one of coherence not strategic audit interventions. I do acknowledge some organisations may have the odd strategic risk, but these are few and far between, and most likely not controllable by the organisation. This means audit plans need to ignore strategic risks and map out the roots of the organisation’s web of risks into a coherent whole.

Some of the plan must be non risk based. There are various things a good audit service should do that are required that have nothing to do with risk. Coverage of finance, coverage of IT, coverage of other specialist risks. Also meeting various regulators’ requirements. These need to be accommodated. We also need to provide a periodic assurance opinion, so annual sufficiency is important. Ultimately we need to do less ‘strategic’ stuff too, otherwise the diet of assurance is too rich, for both management and the governance structures.

Should we take account of the management risk assessment? Well yes – but with caveats. First of all most risk management systems implemented by management teams are poor, or at least suboptimal. Risk mature organisations are rare indeed. If they do exist, they will always be grounded in the paradigm of management thinking. Surely a good audit service should challenge and sit outside of that. So I would think it likely that a good audit service should be challenging in its thinking and perform an independent assessment.

I want to see fewer audit services using an audit universe (I don’t like these see: Running Towards Risk or Risk Based Audit? ) I want to less thin justifications of a lack of coverage dressed up as being risk based. I want to risk based auditing actually mean understanding and looking at risks, not ordering the organisational parts by gross risk and then prioritising them. All of these two dimensional approaches to risk based planning are unhelpful.

I want to see more audit services really know and understand their clients, the real risk and the real risk exposure, and be resourced to provide a meaningful level of coverage to deliver a sensible audit response. Sure I can justify any number of plans and there is probably no right plan, but there are wrong plans. These are ones with 20 year cycles of organisational coverage, with a gross risk proxy only, or those that stick to the management risk script only (even assuming its written well). Most of all I want to see the profession do better than it does currently – so how do you plan?

Do organisations only ‘get’ internal audit when they mature?


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So I had the pleasure of attending the UK Government’s Finance and Internal Audit Conference 2016 this week. I was not convinced linking the two separate professions was massively helpful, as it seems to perpetuate a myth that all accountants are auditors and that financial audit is the same as internal audit. I would argue my audit team has more in common with general management and policy colleagues than our financial ones. Heigh ho! It was good to have a gathering of my internal audit colleagues across HM Government, so in that sense a gathering will always have some value.

So why was I there? I had been invited to argue in formal debate about the motion ‘Internal Audit can deliver more value in a risk mature organisation’. I was asked to argue against this motion. I was happy to argue against as the motion presses on a number of weak points in the increasingly global, and in my view false, current paradigm of internal audit.

So the main argument for the motion (provided by a partner from PWC who I hold in respect) was that in a risk mature organisation internal audit is more valued, more engaged with, and can deliver more value to the management team as a result. In other words risk immature organisations are too immature for internal audit. Or that internal audit does not, or cannot, deliver as much or any value to risk immature organisations.

I think this proposition is clearly false. Internal audit with its unique attributes of: independence; objectivity; and purview across, into and at the top of, organisations; should add value to any organisation. Sure risk immature organisations are very hard work. Some are very challenging indeed. This does not mean internal audit does not add value, it just means internal audit has to work harder, better and clearer with those organisations. It’s true I faced a challenge back, that risk immature organisations would not resource internal audit. That’s true, but you only really need one talented and capable internal auditor. So if you run a small audit team (and there are lots of you that do), don’t feel marginalised. When I did it I forced value on the organisation, I was truly independent and said what I thought. That was not popular or necessarily engaged with, but it made a difference. For one of my previous clients I take credit that that organisation is safer, more customer focused, has a better built environment and generally has stronger processes and systems as a result of my work, even if it was not liked, or valued at the time.

The other obvious statement is that risk immature organisations present lots to go at. Lots of systems, processes, risks, strategies, governance and control issues to get your teeth stuck into. Doctors don’t spend a majority of their time with the healthy. Similarly having some low hanging fruit (or fallen off the tree rotting in the ground fruit) is a great organisation to be involved in. Lots of chances for IA to be relevant, valued, bring to bear IA’s unique attributes etc. As a CAE I love risk immature organisations. They present both a challenge and an opportunity – save the risk mature organisation for the few years before I retire!

So back to risk mature organisations. My biggest beef against this is that it takes it is not real. It’s the Disney position. It’s not real. Let’s be honest how many really mature organisations have you seen? Where the first line of defence is well organised and thinks in controls terms; where the second line is clearly structured and professionally organised and has a genuinely semi independent role from management; and a proportionately and sensibly resourced third line, which is 100% respected and listened to. No, me either.

That’s because this whole three lines of defence paradigm is nonsense. It describes a world the professional services firms would like to see, as it justifies their systems only, light-touch approach to audit (they don’t really distinguish between internal or financial statements audit – for surely risks only impact financial controls?!).

Yet real internal audit (and yes it has to be internal) needs to understand the culture and totems of the organisation. It needs to have a deep and rich understanding of how the organisation really works. For all organisations are not controlled by systems and processes. They might be in part, but the really significant risks are controlled by senior people, mostly using intuition (labelled as experience) and there is no real law or right and wrong objective knowledge in management. For why would we globally pay senior management so many times more than the average employee if organisations were just bags of systems? It’s because organisations are not bags of systems. They are complex, messy, human, full of people. So internal audit needs to audit systems and processes and controls, but it also needs to understand incentives, culture, politics (both capital and lower case ‘p’) to provide real and meaningful assurance.

So, if we take it back to the dominant paradigm of the three lines of defence. Clearly the three lines of defence is nonsense. It’s a model. Models are used to help us humans to simplify and understand more complex reality. They occasionally provide a basis for us to predict outcomes or causality. The very best provide an ideal that, if applied, will lead to success. Yet the three lines model does none of this. It is not predictive. It is not even clearly understood, outside of the banking sector where is it mandated. It is, therefore, neither law, nor observable fact. So I see it more like the Pirates’ Code in the Pirates of the Caribbean – ‘guidance’ not rules. I see it has a religious quality. You have to make a leap of faith to believe in it. Indeed I’ve even been told it’s some people’s Bible. It does have a cultist element to it. At best, its a typology of organisational activity. It tells us nothing about the detail of what goes on in each typological segment and gives no sense of the relative strengths, size, resourcing or value provided by each.

So let’s all move on and treat it as the basic typology it is please. For this three lines model, taken out of context, is what causes the motion such as this to even be talked about in relation to internal audit. It is this idealised model of a fake Disney reality of a pyramidal organisation with a big first line, smaller independent second line and tiny third line IA that limits IA. It limits IA to doing nothing. So when IA does any real analysis or consultancy or asks difficult questions it prompts the clarion call – ‘oh that’s a second line activity’. Nonsense – internal audit is very well placed to do proper consultancy. Not the imposing consultants usually do that is limited by management in scope and buried if it is not the preferred answer, but real consultancy that asks the right questions and provides the right answers that have to be dealt with.

It is the three lines model that limits IA in most organisations to overseeing the sausage machine, occasionally tasting the odd sausage, but assuming that risks are all ‘aggregatable’ to the top level of an organisation and testing those ‘strategic’ risks (they are not – risks are complex webs of detail, not one liners at a board level). It is this model and ideal paradigmatic approach we all are increasingly buying into that makes IA functions tiny. Would Volkswagen have doubled its IA resource to avoid its current woes? – I would argue yes and that it should.

IA is part of an eco system. It can and should be larger and better resourced in all organisations. It should do second line functions – or at least review in more detail further down organisational detail from an independent perspective. Most second line functions are weak and unclearly structured anyway – so some overlap is needed. Internal audit can and should add value to all organisations and I would argue good IA will add more value to risk immature organisations as we have access to the governance of the organisation to unblock the constipation that most risk immature organisations face.

For remember, at the end of the day when something goes wrong – this model we all buy into falls apart – no CEO ever asks ‘where was my first and second lines of defence’ they ask ‘when was it last audited and why did you not tell me’. 

2016 – a time to come out?

I am at that time of year when I think about the year that’s been and the year coming. I ask myself in relation to this blog – is it still doing what I wanted it to do when I started it in 2011? Am I still able to find the time and energy to do it? Should I continue to keep it semi-anonymous.

I started this blog as a place to debate, think, and discuss my changing and developing professional views of internal audit. Since 2011 I have been lucky to have two roles that have made it possible to grow and develop and, most importantly, to put my ideas into practice.

I also decided that I should make the blog anonymous. Not because I didn’t want to be held accountable for my views, but rather I did not want my background or personality to interfere in how my writing was perceived and my thoughts were considered by the blog’s readers. I am aware it is only semi-anonymous as it broadcasts via my Twitter and Linkedin accounts. Even so, I have been clear to make the blog generic, anonymous and accessible.

I think on this second point my views have changed. I am now working in an international role, for a respected client organisation, I have now had my service undergo a recent EQA, which, for the early draft report, has been very positive. I believe I have now had a chance to implement my ideas of internal audit at scale and proven, in practice, that my approach to internal audit does work. This has been with the fantastic support, engagement and  hard work of my team.

I think now, 2016, is the time to engage with my international colleagues and audience. I am also now turning my creative attention and energy to the other side of my responsibilities, counter fraud. I have successfully combined the two, but want to engage my international counter fraud colleagues in the debate and discussion about this work as well.

So – I am Anthony Garnett. I work as the Head of Internal Audit and Counter Fraud for the UK Government’s Department for International Development. I deliver audit and counter fraud services for the over £10bn the UK Government spends each year across the globe bilaterally and multilaterally (through the UN, World Bank and other development partners) to tackle poverty, instability and support fragile and conflict-affected states. My views on audit in this blog are, of course, mine, not my employer’s.

On balance the blog does still provide me a place to write about the challenges and thoughts I have. I still benefit from the opportunity to write about the challenges and thoughts I have about them. Writing is both cathartic and useful for me and I hope you, the reader, as you follow my journey.

The blog is still useful to chart my changing views. I still find working as a chief audit executive continues to provide me with new and varied challenges. This provokes me to think and grow, professionally and personally. So the blog is a good space to do this and I will keep going with it.

I think my need to engage with the international community and my international colleagues makes this blog a useful tool. I shall begin to express what I am learning from working globally and what it is telling me about internal audit across the globe.

The other thing I wanted to do it to deliver a platform to challenge internal audit orthodoxy. I wanted with this blog to put right the things I saw as nonsensical, bizarre or unchallenging woolly and poor thinking in internal audit. I think the internal audit profession still lacks this challenge and thought leadership in internal audit is thin on the ground. So I want to, in my own small way, to address this deficiency. I hope my blog has done this so far, but will focus on this more in 2016.

Finally on the energy point. I do find my current role immensely challenging and draining of my time and energy. I also moved from Scotland to London and am now London based, this was a tiring move and transition. I have an incredible team, a great deputy and senior management team. So I hope to be able to blog more in 2016 than I have done in 2015.

Thank you, as a reader of my blog, for following and continuing to follow my professional journey. I wish you all a happy new year and look forward to debating and discussing the finer points of this during 2016.

EQA happiness?


So it’s that time in every CAE’s life where their audit service gets its external quality assurance (EQA) review. Although I’ve been a CAE for over 10 years now, it’s the first formal contracted out EQA I’ve undergone (as a consequence of other processes being in place or timing with client organisations). In previous roles I had annual EQA reviews by peers. This time it is a full fully arm’s length assessment.

I think I have been relaxed about it. Not because I am insanely overconfident or arrogant, but because I have a constant hope that I can genuinely learn and improve what I do and how I do it. I am actually looking forward to someone wanting to engage with my thoughts, my world, my challenges, my views, and the future.

I am certain not everything is perfect, or that there are things that could be improved. I am however very comfortable with the building blocks of my service, the people that work with me. They are a motivated and hard working team. A team committed collectively and individually to being better and the best. Part of that is because we work for an organisation that tries to help and change the world. Part of it I would like to think is because I demand, and hopefully inspire, the best in all of my team.

I had the extreme pleasure to see another two members of my team qualify as a professional internal auditors. They have worked hard in tough work and home contexts to achieve their qualifications. They did this not for the status and label of the postnominal letters, but for their genuine edification. Seeing their genuine happiness at qualifying got me thinking about what makes me happy?

So as I reflected on my team’s ability to tackle issues and challenges collectively and to help and motivate each other, I also reflected on what makes me happy. Don’t get me wrong, being in a leadership role can be draining, tough, challenging and, at times, dispiriting. Yet it can also be awe inspiring too; to see people really grow and develop.

So another pleasure I have is seeing the effect of an audit report really transform thinking and development of others or client organisations. A good audit report should sometimes take a client’s breath away. At first because of the sheer cheek and audacity of it, or because it says the unsayable, or because it tackles the most difficult challenges, the most painful truths, or because it is balanced and helpful, or because it has listened and brought contextual analysis to the issues and risks at hand. Then later, because it prompts growth in clients organisationally and individually in their staff.

It also makes me happy to be working in a co productive manner on assurance reports with my team. I love shaping, challenging, being challenged and then coproducing fantastic audit products. I love working with bright and stimulating colleagues. They make my day when they are excellent.  I am happy to showcase the team I work with; they’re fabulous.

What else makes me happy as a CAE? I think adding value to my client. I evaluate success as what I bring to the client and how I improve the clients I work with. For in the final analysis, if we judge quality as performance rather than conformance, it should be what difference we make to our clients.


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