2021 Transparency Report for Deloitte Africa
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2021 Transparency Report 2021 Transparency Report Our Purpose Our Brand Deloitte people are motivated by a Purpose: to make an impact How we do it – inspired by what we know to be right that matters. Our Purpose recognises that we exist because • Stand firm for doing the right thing businesses and governments respect us, capital markets trust us, people want to work with us and society benefits from the • Deliver nothing short of the best value we add. • Treat our clients and colleagues with genuine respect What we do – driven by our will to be best • Reward merit alone; encourage growth, pride and • Serve the public interest achievement for all • Seek the hardest questions as ours to answer • Behave as one • Lead the way – forge ideas that bring clarity, solutions that create • Make the world better by our actions – community tangible value and innovations that define the future by community • Help bring about our clients’ proudest moments Our Shared Values Our Shared Values underpin our culture – a culture with integrity and professional conduct at its core. This culture is reinforced from the very top of the organisation and evident in the behaviour of our professionals, not only across Africa, but around the globe. Lead Serve with Take care of Foster Collaborate for the way integrity each other inclusion measurable impact Our brand is defined by the high-quality services we deliver. Quality is the foundation of our profession and the bedrock of our strategy. Our relentless pursuit of quality Deloitte is the leading We believe in doing the We place a premium on We are committed to We approach our work professional services organisation in the right thing – always. That is the guiding force respect, fairness, and trust – working together attracting, retaining, and advancing a diverse with a collaborative mindset, teaming and commitment to advance the profession world for a reason. Our scale and scope behind every decision we make and every action we to achieve our aspirations. We recognise workforce, while fostering an inclusive culture where across businesses, industries, geographies, defines not just what we do, but who we are. is unmatched, take. By acting ethically potential, value varied our people feel a sense of and skill sets to enabling our people and with integrity, and skill sets and experience, belonging and can grow. consistently deliver to consistently serve serving as role models in reward performance, and Accelerating diversity in tangible, measurable, clients with our communities, Deloitte provide opportunities for leadership and attributable impact. We distinction and help has earned the trust of growth and leadership. strengthening our culture play a critical role in shape professional our stakeholders. We prioritise wellbeing, of inclusion requires helping clients and services for the Upholding that trust is and we empower our ongoing attention and capital markets operate future. our single most people through deliberate action, and we more effectively. important responsibility. mentorship and are steadfast in our sponsorship. commitment. B C
2021 Transparency Report 2021 Transparency Report Contents Message from our Chief Executive Officer 4 Embracing a responsible business mindset 6 Our quality journey 8 Promoting our People & Purpose agenda 14 Financial information 16 Reputational matters 17 Living our Purpose by making a positive impact for people and society 17 Appendix: Governance 20 Deloitte Africa structure 22 Africa Board and Executive Committee 24 D 1
2021 Transparency Report 2021 Transparency Report 2021 Transparency Report at a glance Key highlights Our Diversity, Equity and Inclusion strategy This 2021 Transparency Report demonstrates is monitored by a Steering our commitment to a culture of integrity, Diversity, Equity Committee comprising the professional excellence, accountability and quality. and Inclusion Africa Executive, a Board The ALL IN achievements representative and Sponsorship Wave Partner/director compensation Maintaining trust through transparent stakeholder include: members from the initiative was launched, with implementation team. The average total compensation per partner/director in the year engagement is a key priority for Deloitte Africa. Transformation 22 high performing women ended 31 May 2021 amounted to R4.5 million before tax in the programme. The (South Africa) (31 May 2020 R4.0 million before tax). All information provided in this report relates to the position of Deloitte Africa for purpose of the programme 31 May 2021 year-end unless otherwise indicated. is to accelerate women into % Gap (mean per level) senior leadership roles. 2021 White/Black * Male/Female** Black 59% 2020 White 41% Grading (FY21 number Black 59% FY21 FY20 FY21 FY20 of partners/ directors) White 41% 1-2 (199) 7% 7% 9% 6% Deloitte Africa 3-4 (118) 4% 0% 9% 5% Total number of staff 6727 5-6 (5) -43%*** -42%*** - - Total number of partners and directors 329 Respect & Inclusion Total (322) 19% 21% 18% 19% Total of skilled professionals across Africa 5 304 Engagement labs, a global initiative aimed at fostering an * White/Black % gap for partners/directors of the South Africa inclusive leadership culture, have Practice. been delivered to the full partnership ** No female representation at grading levels 5 and 6. *** Black partners’/directors’ earnings in this grading are more body across Africa. than that of their white counterparts. Gender equality ownership (Africa) Female ownership across Africa increased from 32% on 31 Ownership May 2020 to 34% on 31 May 2021, 2020 (South Africa) while South Africa increased from 33% Black 43% White 57% to 36%. 2020 2021 Female representation on the Africa Board increased from 30% on 31 2021 Male 68% Female 32% Male 66% Female 34% May 2020 to 39% on 31 May 2021. Black 43% White 57% Our commitment to quality Quality informs every aspect of our business and is the bedrock of our strategy. Our pursuit of quality is at the centre of our culture of continuous improvement and innovation. Gender equality Gender equality ownership (South Africa) (Africa) Audit & Assurance FY21 financial highlights In our Audit & Assurance business, the primary measure of quality is the outcome of external reviews by regulators. The South African regulator, the Independent Regulatory Board for Auditors (IRBA), regulates most of our audits and the results of their reviews are presented below. Revenue in R’million* 2020 2021 2020 2021 2019 2020 2021 Deloitte Africa: Male 67% Male 64% Male 49% Male 48% Female 33% Female 36% Female 51% Female 52% R6,190m Good and acceptable audit quality 100 Advisory-only clients: R2,264m 80 60 We are proud of Audit-only clients: 40 R1,373m 20 * * • Our progress towards being the audit quality leader. • 78% good/acceptable quality results. 0 Deloitte Other big 3 JSE accredited * The split between Advisory-only • Decrease in the number clients and Audit-only clients *IRBA 2021 report not available to determine comparisons represented above is for the firm’s Top 200 clients, who constitute While we made significant progress in our audit quality journey, we still have some work to do to achieve a consistent level of quality, the majority of the revenue. and we recognise that the quality benchmarks are also evolving. 2 3
2021 Transparency Report 2021 Transparency Report Message from our Chief Executive In this report, we have challenged These improvements are across both our Audit and Advisory businesses), we a firm, we are also fully committed to ourselves to go further in meeting this Audit and Advisory businesses. As a result, constantly need to balance our mandate as utilising the resources at our disposal to stated objective. We have, therefore, we have a firmwide Quality Leader whose Auditors and our duty to serve as strategic make a meaningful contribution to our redesigned the report to achieve the mandate is to determine appropriate and advisors to our clients. To maintain our societies. For this reason, we have also following: comprehensive quality measures across all independence and protect the integrity of made our Responsible Business mandate our businesses and drive execution. our business, we have very strict protocols an essential part of our decision-making • A significantly shortened report Furthermore, we undertook a to ensure that any interactions between process. This is at the core of our purpose which focuses on the key areas of re-imagination of our Audit quality process our Audit and Advisory businesses is for statement - Making an Impact that Matters. accountability we have identified. with active direction and support from the sole purpose of enhancing our audit The journey ahead • Clearly articulated key metrics per Deloitte Global and the Deloitte Africa product by availing specialist skills in key accountability areas against which we Executive Committee. areas, as part of the audit process. I have been reminded this year that, while will measure our progress and report on we might not always be prepared for As a result of this concerted effort and The ecosystem and our role in the yearly. certain events along our journey, the focus on quality, we are already beginning profession resilience and strength of our people is one • Broadening the scope of the report to see quality green shoots and we are well While addressing our internal issues, we of the most valuable assets. I strongly to cover the Africa firm and thus on our way to being the quality leader. The also recognise broader considerations that believe in the ability of our people. I also departing from a South Africa focused report highlights the strides we have made, require collaboration across the entire place a lot of faith in the fact that, through Transparency Report. Whilst we have which have led to our positive quality ecosystem. International committees, such their commitment to our Shared Values, managed to achieve this in some results. We are determined to ensure that as the Sir Donald Brydon Review, have ingenuity, innovativeness, and of our key areas, there is still work we achieve similar results across all our endeavoured to unpack the causal factors overwhelming desire to contribute towards to be done to enhance our internal businesses and regions in the future and for audit and corporate failures. In their upholding public interest, we can position systems to ensure that we can provide undertake to report on our continuous conclusion and recommendations, they this firm and our profession to continue comprehensive reporting across all our progress. emphasise a need for a holistic approach playing a meaningful role in our society. regions and businesses. Lwazi Bam The profession and our to addressing audit reforms. Therefore, the Chief Executive Officer We believe this approach provides a multidisciplinary model broader ecosystem is critical in creating an Deloitte Africa powerful foundation and will serve us well environment that enables the audit The continuous scrutiny of the profession, in prioritising the enhancement of our profession to deliver on its responsibilities whilst intense and uncomfortable, is systems to improve how we measure and to uphold the public interest. warranted. Trust is the ultimate currency report on our identified metrics. our profession trades in and when that The collaboration with clients, business The COVID-19 pandemic has been one of I, therefore, encourage you to continue to trust is under threat or diminished, we organisations, regulators and governments the toughest periods for our generation. Its hold us accountable on these measures need to act decisively. In determining a to respond to COVID-19 has served as a Lwazi Bam resultant effects on our personal lives, and highlight any other matters you wish us fitting response, we must avoid the great example of partnering with others to society, and our economies will linger for a temptation of superficial “quick fixes” and achieve more. This presents a possible Chief Executive Officer to engage on further. while. Meanwhile, a lot is still unfolding in revert to first principles. I believe these model that can be employed to fast track Deloitte Africa our profession. The last few years have Our quality journey – quality green principles are the key to addressing the audit reforms. As a firm, we are revealed significant parts of our business shoots fundamental core issues at a firm level, for committed to playing our part to advance that need to evolve to meet the times we Quality remains a key metric that we will the profession, and the broader business these conversations to develop tangible are living in and meet society’s continue to enhance and monitor. We have landscape. and sustainable solutions. expectations. been on a continuous quality improvement Our reputation matters afforded us an The reforms in the audit profession are It is against this backdrop that we publish journey to address internal deficiencies opportunity to reflect on our role and to happening at a time when the business the 2021 Africa Transparency Report. The where necessary. We have also introduced not only set ourselves on a self-correcting community is also grappling with its main objective of this report is – to be forward-looking measures meant to path but to broadly think about how we can relevance and being a net contributor to transparent and accountable on matters anticipate and address the changing nature make a meaningful contribution to society. Therefore, as we chart a way that are top of mind to our stakeholders. of our clients and capital markets, as well reforming the profession. Whilst Audit forward for the profession, it is critical that as our stated desire to act in the public’s remains central to this ambition, as a we find appropriate mechanisms to bring interest. multidisciplinary business (covering both the public along with us on the journey. As 4 5
2021 Transparency Report 2021 Transparency Report Embracing a responsible business mindset Our commitment to responsible business practices is guided by Trust in the Profession • Deloitte has been an active participant in the South African our Purpose and Shared Values. The responsible business Auditing Profession Trust Initiative (SAAPTI) since its inception in As a prominent player within our ecosystem, we believe an principles we have adopted and the commitments we have made 2018. SAAPTI is a voluntary profession-wide initiative which aims important part of being a responsible business and living our to our key stakeholders are outlined in our Responsible Business to proactively respond to the challenges faced by the auditing Shared Value of leading the way is to use our voice to advance Practices Statement. This statement provides a common profession and re-earn trust therein. A key effort of the SAAPTI is relevant matters of public policy. With audit at the heart of our understanding of what living our Purpose means in terms of the a Discussion Paper comprising 32 Considerations regarding business, we recognise the important role we play in maintaining business practices we engage in. As a firm, we respect and re-earning trust in the profession. SAAPTI undertook a trust and confidence of the capital markets. As such, restoring trust appreciate the intricate interdependencies between business and comprehensive engagement process on the Discussion Paper in the audit profession and wider business accountability society. We acknowledge the responsibilities we owe to the public. with the profession (including small, medium, and large firms) as ecosystem has been a key focus area of our public policy efforts Elevating the public interest on the leadership agenda is a priority well as other stakeholders including Townhalls and one-on-one over the last few years. We proactively and constructively engage of the firm. To this end, the firm has appointed a Managing Partner discussions with key stakeholders such as National Treasury, key stakeholders, including government and regulators to for Responsible Business and Public Policy who forms part of the South African Institute of Chartered Accountants (SAICA), contribute towards building a stronger business accountability firm’s Executive Committee. Independent Regulatory Board for Auditors (IRBA), the Auditor ecosystem that serves the public interest. General, the investor community (ASISA), Business Leadership Company we keep Deloitte Public Interest Council South Africa (BLSA), the Institute of Directors (IoDSA), the Audit A crucial step to drive responsible business is the intentional Committee Forum, the Johannesburg Stock Exchange (JSE), and The Deloitte Africa Public Interest Council was established in 2019 consideration of the company we keep as a firm – both who we others. to help the firm further understand the impact of our activities on work with and the work we do. This is assessed against our values, the public interest, through constructive engagement with • On 1 June 2021, we hosted a virtual fireside chat with Sir Donald the impact on our people, clients and society. Notable progress in individuals bringing perspectives of business, civil society, and Brydon on UK Audit Reform and the ripple effect internationally. this regard in FY21 includes the following: government. Sir Brydon is the author of the landmark 2019 Brydon Report on • Activation of the firmwide Responsible Business Decision-making The Public Interest Council is comprised by non-Deloitte individuals the quality and effectiveness of audit in the UK, submitted to the Framework: that comes from wide and varied sectors of society. These UK Secretary of State. The event was attended by key – The firm implemented a structured responsible business individuals are not remunerated for the role to enhance their stakeholders in the profession to further the conversation on an assessment across all our businesses and internal functions independence. improved corporate reporting ecosystem in South Africa. Key to help us think through the public interest impact of the takeaways from the discussion can be accessed here. Three meetings were held with the Public Interest Council in FY21 decisions we make regarding who we work with and the work • We play a critical role in shaping legislation and regulation to covering key topics for Council input including Responsible we do. support a trusted financial reporting ecosystem in South Africa Business Decision-making Framework, the firm’s response to – The establishment of the Responsible Business Committee to by actively participating in the amendment process to the COVID-19, and our public policy approach to the business adjudicate challenging responsible business matters escalated Auditing Profession Act and JSE Listing Requirements, advocating accountability ecosystem. by the business. for constitutional balance in the regulatory measures for – Notable efforts in this regard include: investigation and enforcement practices pertaining to auditors • We advanced the position on the state of the South Africa audit and for more clearly defined responsibility and accountability for profession by facilitating a public debate with key stakeholders top management with regard to the financial statements and on addressing the audit expectation gap, promoting trust and financial controls. confidence in the corporate reporting ecosystem, and ensuring due consideration of global audit developments. Key stakeholder engagement in this regard included interaction with government, regulators, professional bodies, and members of the profession. 6 7
2021 Transparency Report 2021 Transparency Report Our quality journey Quality informs every aspect of our Appointment of a Quality Leader Operational excellence Considering the company we keep We have appointed a firmwide Quality Leader to ensure consistent business and is the bedrock of our oversight and reporting across our business. • Implement a world class system of • Africa risk-sensing group supported by technology – strategy. Our pursuit of quality is at How we measure quality? quality management that supports quality, enabled risk-sensing capabilities. transformation and related operational objectives • Africa client review board to drive deliberate and the centre of our culture of continuous Given our multidisciplinary model approach, the measurement of and global consistency. consistent changed behaviours in our client acceptance improvement and innovation. quality differs across the businesses, but in all cases we identify root • Continue to evolve and support the quality and continuance process. causes of inadequate quality and implement measures to remediate and risk infrastructure for our Audit & • Improved guidance and support to drive consistent high those causes. Our reporting that follows focuses on the primary Assurance business. quality response to take on procedures and know your In previous reports, we have focused primarily on our audit quality measurements for our businesses and how we have client processes. quality journey. As part of our commitment to being a performed against those measures during the past financial year. responsible business, we have expanded our Transparency • Accelerated approach to address emerging issues and Report to include our quality journey across all our Holding ourselves to account changing stakeholder expectations. businesses. Audit • Active, visible leadership commitment. • Since inception of the Client Review Board, 320 clients have been reviewed, 12 engagements were terminated The International Auditing and Assurance Standards Board • Mindset inspired by purpose, ethics, professional due to undesirably high risk of association and enhanced (IAASB) Framework for Audit Quality acknowledges that “there In our Audit business, the primary measure of quality is the pride. risk mitigation plans were developed for a significant is no definition or analysis of [audit quality] that has achieved outcome of external reviews by regulators. Making sure audit • Dedicated audit quality monitoring and number of clients. universal recognition”. The same is true for the quality of our quality keeps pace with emerging economic, business, and measurement capability to provide a level of • 343 Client Review Boards are scheduled across Africa advisory services. Nevertheless, in our view, we deliver quality regulatory conditions, as well as technological advances is critical internal assurance to leadership. for the 2021 calendar year. 11 (6% of client review when we meet or exceed the expectations of our to the continual enhancement of our role in protecting public stakeholders, including, in particular, the public and our interest and supporting the effective functioning of the financial • Incentivise and reward commitment to quality. boards held in 2021 thus far) client relationships were clients. ecosystem. Our brand is defined by the high- quality audits • Accountability framework that defines our terminated or opportunities not pursued. delivered and by the unwavering commitment to continuous approach and response to acknowledging and To paraphrase the IAASB’s Framework for Audit improvement. remediating deficiencies at both systemic (firm) and Executing better quality audits & Quality: individual (partner) level. continuous improvement Deloitte embarked on an Audit Future-Fit project which cast a A quality service is likely to have been delivered by an spotlight on the areas within our business where intensified and • 11 partners who had poor quality history, as at • Evolving quality & risk infrastructure to achieve engagement team that: prioritised actions would allow us to significantly enhance our February 2020, are no longer with our firm. greater consistency. • Exhibited appropriate values, ethics and attitudes; overall system of quality management and drive a superior quality experience. The Deloitte Future-Fit Audit Journey Below is the results of our Audit Accountability • Continued investment in emerging technologies, • Was sufficiently knowledgeable, skilled, and experienced Framework for this year. capabilities and diversity of thought that enables the provides detail on some of the actions taken and provide a focus and had sufficient time allocated to perform the work; delivery of enhanced quality, insights & value to our on the measures we have taken to improve audit quality. Below • Applied a rigorous process and quality control procedures we outline our quality strategic objectives to continuously build 7% clients and the markets. that complied with law, regulation and applicable standards; capabilities to support the delivery of high-quality audits and 10% • Intensive focus on ways to help our professionals • Provided useful and timely reports; and make leading contributions to shape the future of the audit apply professional scepticism in practice. • Interacted appropriately with relevant stakeholders. profession. • Improved engagement team support in key areas of 83% judgement and rigorous engagement quality control This report focuses on the steps we have taken and are review response. Culture of quality implementing to further enhance quality across our • Enhanced workforce planning, skillset and capabilities businesses. • Strengthen our culture of quality and excellence, of audit professionals (now and in the future). While we made significant progress in our audit quality encourage, and support habitual behaviours that demonstrate the ethical, challenging, sceptical mindset of Good quality journey, we still have some work to do to achieve a consistent Improvement required level of quality, and we recognise that the quality benchmarks our people and pride in our profession. Significant improvement required are also evolving. Significant Audit excellence Good Improvement improvement quality required required • Build eminence with respect to the profession and South Africa 106 5 4 regulatory environment, lead and/or contribute to debates East Africa 8 2 1 that will architect the audit product of the future through West Africa 14 2 2 the lens of public interest. Southern Corridor* 12 7 5 • Generate clear market reputation that Deloitte leads * Botswana, Malawi, Mozambique, Namibia, Zambia and Zimbabwe the profession in the quality of our audits and in serving public interest. • Apply the Deloitte Way, our globally consistent approach to the execution of audits, including adoption of quality – enhancing transformation components and global technology platforms. 8 9
2021 Transparency Report 2021 Transparency Report The South African regulator, IRBA, regulates most of our audits and the results of their reviews are presented below. IRBA Individual Inspections IRBA Firm Inspection Themes Embracing external inspection results presents an opportunity to IRBA Firm Inspection Themes gain insight into potential deficiencies existing within our system of quality management and work towards solutions that drive 23 The number of types of Total number of sections continuous improvement in audit quality. IRBA performed an These reviews are performed annually, using a risk-based sections reviewed by the IRBA reviewed by the IRBA* inspection under their seventh inspection cycle from 11th January approach, with a focus on engagements and audit areas where 2021 to 16th March 2021 (2019, 2020 and 2021). deficiencies are likely and areas that if not appropriately responded Number of types of section The average number of sections to by the auditor, create a risk of an inappropriate auditor’s report reviewed that had findings reviewed by the IRBA on a file being issued. *A specific phase of the audit process, for example planning or completion, or the audit work performed over a material account balance or class of transaction. The objective of IRBA’s individual assurance engagement We are pleased with the overall improvement in the reduction of file inspections is to monitor the firm and its engagement the number of deficiencies identified on engagement files over the partners’ compliance with the International Standards on last three years, especially in the light that various engagement files As a result of the IRBA’s individual assurance engagement file inspections the following reportable Recurring deficiency themes were identified for Deloitte to remediate. theme Auditing, codes of conduct and legislation in performing inspected in 2021 were executed during the COVID-19 lockdown in assurance work of a consistent, sustainable high quality. a virtual environment. 2019 2020 2021 2019 2020 2021 Financial Statements Engagement Quality Good and acceptable audit quality Quality Control Impairment – Disclosure Control Reviews Audit Procedures Good and acceptable audit quality System of Assets Deficiencies (EQCR) – Revenue 100 100 80 17 of the 23 files had 4 of the 23 files have Inadequate review of 12 of the Inadequate 80 one or more significant reportable deficiencies financial statements engagement files procedures/ 60 60 We are We areproud proudof of deficiency reported to relating to inadequate disclosure as required reviewed have documented audit 40 40 • Our progress towards being the audit quality leader. the firm. audit evidence to by relevant accounting reportable findings in evidence to ensure 20 • Our progress towards being the audit quality leader. 20 * * * * support deviations framework. areas that are within sufficient testing of 0 •• 78% 78%good/acceptable good/acceptablequality quality results. results. from impairment of the scope of the EQCR. revenue. 0 Deloitte Other bigbig 3 3 JSE accredited Deloitte Other JSE accredited •• Decrease Decreasein inthe thenumber number assets accounting *IRBA*IRBA 2021 2021 report not available report to determine not available comparisons to determine comparisons standard (IAS 36). Our response Our response Our response Our response Our response 12 12 78% 78% 23 We have made several We continue to We have implemented We have designed and We have deployed Listed Listed entity entity group group being“good being “goodquality” quality”or “acceptablequality” “acceptable quality” or 23selected selected strategic quality investments to improve enhance our guidance and learning to ensure a proactive, consistent review process on embedded an EQCR engagement support enabling tools to the practitioners, additional 2019 2019 2020 2020 2021 2021 our quality control consistency of financial statements centre of excellence, guidance on the testing Listed clients inspection results 7th cycle inspection results practices. application and which encompasses a enhanced training and of information Listed clients inspection results 7th cycle inspection results 60 60 documentation within number of measures learning and produced by the entity 60 60 our engagement files. such as completions of implemented and have planned 50 50 50 50 the full IFRS checklist, engagement quality additional learning to 40 40 40 40 use of the firm’s IFRS control reviewer be delivered to all 30 30 30 30 team, additional assistants. practitioners relating to 20 20 20 20 reviews for listed the audit of revenue. 10 10 entities as well as 10 10 0 Good quality (no Acceptable Poor quality Fundamental 0 Good quality (no Acceptable Poor quality Fundamental specific training to 0 (referral to 0 Good (referral to Good further quality action (no quality (some Acceptable Poor quality Fundamental further action(no quality quality (some Acceptable Poor quality Fundamental practitioners. improvement investigation) improvement investigation) furtherrequired) action improvement quality (some (referral to required) further action improvement quality (some (referral to required) required) investigation) required) required) investigation) required) improvement improvement required) improvement improvement required) required) required) required) 10 11
2021 Transparency Report 2021 Transparency Report Our Consulting business effort in order to meet stakeholder primarily measures the cost of expectations. A lower cost of quality on an ongoing basis to quality is indicative of better Financial Advisory measures quality monitor quality delivery. Cost of quality processes. through internal practice reviews. The table below quality (CoQ) is a measure of actual Note: this is South Africa only, depicts our practice review outcomes for 2019 and effort required relative to planned which comprises 90%+ of our 2020*. Systems of quality Africa Consulting Revenue. Practice reviews Deloitte global Additionally, we currently focus benchmark – 3.2% Moderate cost of quality measures on larger findings findings findings A continued focus on audit quality is of paramount importance to In 2021, IRBA did not perform a firm inspection of our quality Review # engagements Minor Major the Deloitte brand. Our audit quality monitoring and measurement control processes, however the IRBA uses the results of the assignments. Even though we do period program is focused on driving: engagement file inspections as an indicator of the effectiveness of not perform CoQ for the East and the system of quality control. West Africa regions currently, we FY20 17 4 8 2 • Continuous, consistent and robust monitoring of completed do perform the required Quality We are pleased with our systems of quality results as they FY19 22 31 6 4 engagements. Assurance Reviews on showcase the power of our quality systems and the resilience of engagements. We are in the FY20 average of 0.8 findings per engagement • Fundamental understanding of deficiencies and timely execution our people while working in unprecedented times during the process of updating our systems FY19 average of 1.9 findings per engagement of corrective action. COVID-19 pandemic. 3.82% 3.22% to ensure that we able to report on • Greater transparency and consistency in reporting key measures the CoQ for all our regions in Guidance to ratings FY21 (Year-End) FY20 (Year-End) of audit quality to relevant stakeholders. 182 Engagements 114 Engagements future. 1 No exceptions 2 Minor isolated exceptions 3 Minor exceptions on more than an isolated basis/ Tax & Legal measures quality through internal practice reviews. moderate exception The appropriateness of the design, implementation, and effective operation of our system of quality control is We are proud of The table below depicts our practice review outcomes for 2019 and 2020*. 4 Exceptions on a frequent basis/major exception The results are split between compliance testing, which is adherence to monitored through two key quality monitoring policy and quality testing. • Significant improvement in the inspection processes, namely: systems of quality results. Quality Risk Advisory measures quality through Compliance Testing internal practice reviews. The table below depicts Testing – Findings • Deloitte internal inspection, overseen by an allocated – Findings Summary • Investment in monitoring systems. summary our practice review outcomes year-on-year senior audit partner from an independent Deloitte member Africawide*. # engagements • Investment in systems of quality control. Minor findings Minor findings Major findings Major findings Review period firm (Canada), as mandated by our Deloitte policies manual; We are proud of Scores are calculated based on a set of predetermined No findings No findings and Moderate Moderate questions. Each question is assigned a weight from findings findings Region • The IRBA, who conduct inspections in accordance with • in the systems of quality results. 1 to 3. Individual question scores are then summed to International Forum of Audit Regulators (“IFIAR”) Core • Investment in monitoring systems. determine the total points accumulated. A final grade Principles and as mandated by Section 47 of the APA. • Investment in systems of quality control. percentage is then calculated as a percentage of the South 25 20 4 1 - 23 - - - total points accumulated divided by the total points Southern 3 3 - - - 3 - - - available for the review. East 3 - 3 - - 3 - - - FY20 2020 practice reviews Deloitte Internal Systems of Quality Control Inspections West 9 9 - - - 9 - - - 62 21 Total 40 32 7 1 - 38 - - - Rating Average overall Total Systems of quality Level assessment number of control processes processes tested Total % 80% 18% 2% - 95% - - - grade engagements South 18 14 4 - - 17 1 - - 47 tested in the prior year Green + 99 - 100% 7 Southern 6 - - 6 - 3 - 3 - 11 257 Person-hours Green 90 - 98.99% 11 East 6 6 - - - 6 - - - FY19 (2019: 14 768 person hours) across West 13 10 - 3 1 13 - - - Yellow + 80 - 89.99% 0 23% Total 43 30 4 9 - 39 1 3 - Yellow 70 - 79.99% 0 On average 299 hours (2019: 45%) were (2019: 174 hours) were spent per needs improved Total % 70% 9% 21% - 91% 2% 7% Red 0 - 69.99% 0 29% (2019: 23%) were • Minor – failure to complete a process within the required timelines and 2019 Practice reviews acceptable with there is no absolute disregard of process or policy or where there is an 21 48% opportunities for 0% (23 partners) in South Africa (2019: (2019: 6%) inaccurate or negligent completion of a process. Rating Average overall Total (2019: 26%) enhancement 39 partners) were reviewed. • Moderate – a breach of DTTL Global Policy which is not a breach of a Level assessment number of acceptable improvement. regulatory or professional standard or non-compliance of Risk, grade engagements Independence & Legal or Tax & Legal rules process or policy. Any minor Green + 99 - 100% 7 The significant advancements and intensified, prioritised actions we have embedded in our business to accelerate quality improvement has failures where there was a complete disregard of a process or policy. The positively supported us in continually and relentlessly raising the standards of quality to serve the public interest. incident does not result in a financial loss to the member firm. Green 90 - 98.99% 14 Key observations from our systems of quality review • Major – a breach of a regulatory or professional standard and any Yellow + 80 - 89.99% 2 The quality control processes identified for continuous improvement were incorporated in the changes to our business model and audit quality incident which results in a financial loss to the member firm, investigation investments. by a Regulator or Professional body and an adverse reputational effect Yellow 70 - 79.99% 1 on Deloitte. Red 0 - 69.99% 2 12 * FY21 numbers currently still being finalised and not available at time of publication. 13
2021 Transparency Report 2021 Transparency Report Promoting our Our Diversity, Equity and People & Purpose Inclusion strategy is monitored by a Steering Diversity, Equity Committee comprising the agenda and Inclusion Africa Executive, a Board The ALL IN achievements representative and Sponsorship Wave members from the include: implementation team. initiative was launched, with 22 high performing women Transformation in the programme. The (South Africa) purpose of the programme is to accelerate women into Our commitment to promoting our People & Purpose agenda FY2021 measures 2021 Black 59% senior leadership roles. 2020 Our people and our culture are our greatest asset. We create White 41% Black 59% opportunities for graduates and experienced professionals alike White 41% to be part of a vibrant and diverse organisation, to work with Deloitte Africa people who are forward thinking, collaborative and committed Total number of staff 6727 to making a difference. We are known as an employer of choice for our commitment to diversity, equity, inclusion, development, Total number of partners and directors 329 Respect & Inclusion and wellbeing. We remain steadfast in meeting the needs that Total of skilled professionals across Africa 5 304 Engagement labs, a global people value today and into the future by delivering unparalleled initiative aimed at fostering an experiences to our professionals that allow them to enhance inclusive leadership culture, have their existing capabilities, gain new skills, explore new career been delivered to the full partnership paths, and continue delivering a multidisciplinary model of Gender equality body across Africa. services of the highest quality. ownership (Africa) We are committed to a diverse workforce and inclusive culture Ownership where our people can make an impact, individually and (South Africa) 2020 collectively. This collaborative and high-performance culture Black 43% drives us to invest in our people, giving them opportunities to White 57% grow, thrive, and achieve their professional goals. We offer a 2020 2021 We are proud to report on the following variety of internal and external learning programmes, in addition Male 68% Male 66% 2021 Transformation achievements: to development programmes and global mobility opportunities. Female 32% Female 34% Black 43% Gender equality White 57% Level 1 B-BBEE scorecard rating maintained with 108.84 points. Our commitment to Transformation, Diversity, Equity and (Africa) We maintained a Level 1 B-BBEE rating for the past 5 years. Inclusion is widely recognised Gender equality Our Transformation, Diversity, Equity & Inclusion strategy is ownership (South Africa) Black ownership in South Africa remained unchanged at 43%. underpinned by the principles of respect and inclusion. Specific Black African ownership in SA increased from 18% to 20% and Black focus areas include gender, LGBT+, Broad-based black economic African female ownership grew from 7% to 9%. empowerment (SA) and employment equity (SA). 2020 2021 Learnerships for people with Our Enterprise Supplier Development We have a number of initiatives where we hold ourselves Male 49% Male 48% disabilities Programme is developed to create audit sub-contracting accountable and have developed a set of metrics to measure Female 51% Female 52% opportunities and provide for employee time spent on training, 2020 2021 We have invested over the impact against our strategy set out. These include: coaching and mentoring engagements with the beneficiaries. • An ALL IN gender goal setting, monitoring and reporting Male 67% Female 33% Male 64% Female 36% R25 million Our High-Performance Leadership Programme in this project since our scorecard (designed to deliver exceptional experiences by has supported 44 candidates over 3 years, of which 20 participants commencement in 2016. outlining Deloitte’s commitment to diversity and inclusion have been promoted into senior leadership roles. which includes accelerating the representation of women in Our collaborative and ongoing engagement with the Department of leadership roles) Employment and Labour supports our Employment Equity • Broad-Based Black Economic Empowerment (B-BBEEE) efforts and ensures we are aligned with the latest legislative Female ownership across Africa increased developments and best practices in this space. scorecard from 32% on 31 May 2020 to 34% on 31 May 2021, • Sponsorship Wave programme for accelerated development while South Africa increased from 33% to 36%. These achievements are testimony to our commitment to of women leaders in our organisation Transformation and to achieving our 2025 goals of 48% black Female representation on the Africa Board ownership in South Africa and 40% female ownership. Our success to • Learnerships for persons with disabilities increased from 30% on 31 May 2020 to 39% on 31 May 2021. date indicates we are on the right track and encourages us to continue • GLOBE Africa committee (LGBT+ network) Making an Impact that Matters in transforming our firm. • Employment Equity consultation process, plan and reporting. 14 15
2021 Transparency Report 2021 Transparency Report Financial information Reputational As we move forward, we fully subscribe to Winston Churchill’s notion – “Never let a good crisis go to waste”. As such, we have Our financial performance reflects the success of our Partner/director performance is evaluated, beginning with the matters taken these incidents as an opportunity to reflect, self-correct and go further by sharing our experience and lessons. On African Bank, the lead Partner has committed himself to playing a pivotal role in multidisciplinary model. It drives the delivery of audit, consulting, Africa Board’s approval of the total remuneration strategy championing commitment to quality through sharing his own financial advisory, risk advisory, and tax & legal services. proposed by the Africa Executive Committee and concluding with personal reflection and lessons learnt for the benefit of the the Board’s review of the recommended profit allocation and Deloitte’s reputation has been in the spotlight on widely reported profession broadly. Virtual webinars with two universities Financial highlights grading for each individual partner/director. These outcomes are matters involving African Bank, Tongaat, Steinhoff and Eskom. Over accounting students have been held and the programme will be Deloitte Africa’s financial information has been extracted from our disclosed in full with all partners and directors. the past two years, the firm used these events as an opportunity extended to other interest groups. financial records for the financial year ended 31 May 2021 (FY21). for deep reflection to not only set itself on the self-correcting path The Remuneration Committee of the Board oversees the process, The two current outstanding matters pertain to the audits of Our revenue represents amounts recovered or recoverable from with a focus on consistent and equitable treatment. but to contribute to the profession reform initiatives. Tongaat and Steinhoff, which are both still under investigation by clients for statutory audits, audit-related services and advisory Uphold audit quality IRBA. We are fully cooperating with all investigations. As these are Partner/director compensation services during FY21 and FY20, excluding VAT. Recoverable still under the spotlight with periodical developments, we amounts reflect the fair value of the services provided, based on The average total compensation per partner/director in the year Our reflection further revealed that we place a high level of trust on the validity of information and authenticity of engagements with recognise that our brand remains at the forefront whenever the stage of completion of each client engagement, including ended 31 May 2021 amounted to R4.5 million before tax developments unfold in the media. expenses and disbursements, as at the balance sheet date. (31 May 2020 R4.0 million before tax). client management, while we could be professionally more sceptical. We acknowledge that there must be a healthy trust Remediation steps Partner/director pay gap relationship between auditors and auditees, there is equally an Deloitte Africa R’m FY21 R’m FY20 These incidents have given us an opportunity to investigate the The pay gap percentage is calculated based on the average obligation to be vigorously sceptical to a point of being “suspicious” Total revenue 6,190 6,122 as noted by Sir Donald Brydon at a virtual event hosted by Deloitte root causes, find what are the similarities, their uniqueness and remuneration per partner/director (per demographic grouping) at Top 200 clients 3,637 3,943 Africa on 1 June 2021. apply remediation where necessary. Where gaps have been each partner grading level. The pay gap figures shown in the table Advisory clients 2,264 2,402 identified, we have taken firm steps to address these as follows: * below are linked to the current demographics of the partnership, Incidents Status Audit clients * 1,373 1,541 which will gradually be corrected as we reach our transformation Area Intervention targets. We were able to lessen the overall race and gender pay Two of the four mentioned matters are now finalised. The first Non-audit related services as a percentage relates to Deloitte Consulting and Eskom. Contrary to the original Strengthening These include implementation of risk, ethics, 6.8% 7.8% gap in the past year. The widening of the race and gender gap per of audit fees at Top 200 audit clients processes compliance and anti-corruption programmes across grade arises as a consequence of the appointment of a number of view of Eskom that at the face of it, there were suspicions/ the firm, a significant increase in the Risk, * The split between Advisory clients and Audit clients represented above is for black and female partners in the grade 1 band and the promotion allegations of state capture and/or corruption, investigations by Independence & Legal (RIL) resources and budget, the firm’s Top 200 clients, who constitute the majority of the revenue. of black and female partners through the grades. This area will both parties found no evidence to substantiate the suspicions or as well as overall improvements to our operating continue to be the focus of the firm. allegations. However, the investigations did highlight that, the model – focusing on risk structures. Annually, a portion of the revenue is committed towards process had technical irregularities within Eskom’s procurement Embarking on Specifically, we have embarked on a deep and wide strengthening our risk and quality management processes. For process and also deviated from the National Treasury regulations Future-Fit review of our audit business. Known as the % Gap (mean per level) example, in audit, 3.8% of the Audit & Assurance business’ FY21 governing the State-Owned Entities. Future-Fit project, which was designed to improve White/Black * Male/Female** revenue (3.5% of FY20 revenue) was reinvested into audit quality. governance, oversight, efficiencies and improve Grading (FY21 number of Furthermore, while monetary value of the project was complex to audit quality (with immediate effect). Only 6.8 per cent of revenue earned from audit clients is made up FY21 FY20 FY21 FY20 partners/ directors) determine due to a lack of competitive proper comparison, Eskom Managing Risk Empower our leadership and employees through of non-audit services. We are confident that we have not impaired acknowledged that Deloitte Consulting was entitled to 1-2 (199) 7% 7% 9% 6% ongoing risk awareness and education sessions. our independence or objectivity by delivering these essential, compensation for the services rendered, as Eskom fully benefitted 3-4 (118) 4% 0% 9% 5% Investing in • In the last two years Deloitte has made a non-audit services to selected audit clients. and continue to benefit from the services rendered. The matter processes substantial investment (For example, in audit, 5-6 (5) -43%*** -42%*** - - Remuneration of partners/directors has since been resolved amicably with Deloitte paying an agreed 3.8% of the Audit & Assurance business’s FY21 Total (322) 19% 21% 18% 19% settlement. Deloitte took accountability for not being prudent in revenue (3.5% of FY20 revenue) was reinvested Key measures incorporated for KPI’s is around quality. into audit) in its client and engagement ensuring that all Eskom required procurement processes were * White/Black % gap for partners/directors of the South Africa Practice. onboarding processes. A partner or director’s total compensation includes salary, medical ** No female representation at grading levels 5 and 6. followed. • Improved risk-sensing and risk-assessment aid, shares in profits, retirement and group life benefits, and *** Black partners’/directors’ earnings in this grading are more than that of their resources and systems. The second matter relates to African Bank which was concluded interest on capital. Remuneration is based on a comprehensive white counterparts. Uphold audit Most importantly, we have taken a zero tolerance when the Independent Regulatory Board for Auditors’ (IRBA) issued evaluation of their individual and team contributions to achieving quality stance for behaviour that falls short of our its findings on 9 December 2020. In the ruling, one of the two the firm’s strategic objectives. Independent non-executives standards of quality. Upholding the trust of clients, Partners involved was acquitted on the only charge he faced while the regulator and the public is our foremost priority, All partners/directors are subject to partner grading, which is We pay our firm’s independent non-executives, Nikiwe Bikitsha and the other Partner was acquitted on five and found guilty on five of while we continue to hold each other accountable in reviewed annually. Each level of grade describes the skills, Ory Okolloh fees based on attendance at Africa Board meetings. the ten charges against him. The firm welcomed the outcome the ecosystem. attributes and broad performance expected of a partner/director. particularly on two of the contentious charges the Partner was Engagement Implementation of a Public Sector procurement Each level reflects a wide band of total remuneration units so that acquitted on – dishonesty and independence. Valuable lessons with Public policy – specific and stricter measures introduced relative contributions can be recognised. have been learnt on the five guilty findings related to audit Sector for taking on of public sector work. technical matters including the audit of impairments, contraventions of the relevant audit and accounting standards, Concluding Remarks insufficiency of audit evidence and inadequate audit working paper As we move forward into the audit of the future, we acknowledge documentation. Deloitte respects and accepts the ruling of the that our actions are not the end itself but a means to an end. We Disciplinary Committee. These findings highlighted that Deloitte remain committed to working tirelessly to be at the forefront of can do more to support Partners and auditing teams in the audit contributing to the reforms undertaken by the profession. We process. continue to transform our audit business by investing in firmwide Owing to the fact that the disciplinary findings referred to the audit controls, technology, and processes. We remain committed to performed as early as 2013, the firm has already effected many of playing our role in delivering change that embraces audit quality, the controls and changes that were causal factors. improves choice, and restores trust in the profession. 16 17
2021 Transparency Report 2021 Transparency Report Living our Purpose by making a positive impact for people and society What people expect of business is fundamentally changing, as is the definition of what it means to act in the public interest. In a world of uncertainty, businesses must help address society’s most pressing problems. We are building specialised expertise to contribute towards broader solutions that have wider impact on society and the environment. The pandemic increased our individual and collective stress while reducing mobility and restricting social gatherings. Socio-economic inequalities in Africa were exposed as disparities in access to quality healthcare were painfully conspicuous. The pandemic has placed strain on already struggling communities and economies making our commitment to building a better normal, and supporting our people through the disruption, even more determined. Deloitte is a purpose-driven firm that is deliberate in the choices we make, the organisational culture we foster, the solutions we create, the initiatives we support, and importantly, the company we keep, as well as the partnerships we forge. We strive to deepen our social impact through strategic partnerships with organisations that share our commitment to making a positive contribution to society. We are proud of the impact that we have made through a number of initiatives during this difficult period. However, we realise there is much work to be done to create more opportunity for more people, support recovery, build resilience, and spur economic growth. We remain steadfast in our commitment to being a positive force, and living our Purpose to drive broader and more meaningful impact on business, people and communities in Africa. To read about the positive contribution we have made to society, how we have helped our clients to realise their ambitions, and how we have capacitated our people to achieve success. Please read our detailed 2021 Deloitte Africa Impact Report here. 18 19
2021 Transparency Report 2021 Transparency Report Appendix: Governance Our commitment to ethics In addition to our Deloitte Africa Code of Professional Conduct, we The Global firm has developed an independence policy which is Global independence monitoring system (GIMS) have a number of internal policies to guide behaviour. These primarily based on the requirements of the International Ethics Our leaders see ‘doing the right thing’ as a fundamental principle, The GIMS records and monitors the personal financial interests of include Anti-corruption, Anti-harassment and Anti-discrimination, Standards Board for Accountants and the Public Company which is not just in the interest of our people and our clients, but all partners, directors and client-facing professionals of manager Anti-retaliation. Gifts and Entertainment and Consensual Personal Accounting Oversight Board. Furthermore, local requirements of also in the public interest. grade and above, including those of their immediate family Relationships. Our Anti-corruption policy was updated and country specific external audit regulators and other legislation members (spouses or spousal equivalents, and dependents). The Ethics and integrity are at the core of our business and important confirms our zero-tolerance stance on bribery and corruption in (including Companies Act requirements) have been included. The system records and monitors the personal financial interests of to the reputation of our firm. compliance with local and global anti-corruption laws and independence policy covers requirements that both the firm and about 2 000 GIMS users that fall within the brackets for quality regulations. All staff are required to complete ethics learning on an professional staff (including their immediate family members) need Our commitment to independence, ethical behaviour and monitoring. This is primarily to ensure that our client facing annual basis to ensure we drive awareness and a culture of ethics to adhere to. compliance is demonstrated by the tone set by our leaders, and is professionals and their immediate families do not hold prohibited and integrity. reinforced by carefully and consistently implementing and The independence policy has been updated in the past year based financial interest in our clients. monitoring comprehensive policies and procedures. The ‘Deloitte Speak Up’ platform provides a confidential channel on regulatory changes of the aforementioned requirements. In 2021, partners and staff were subject to financial penalties of through which ethics concerns can be raised. All reports are Further changes to the regulatory requirements are expected in Upholding ethics over R1 million across our Africa Member Firm. Most of these independently investigated, and action is taken where required. the coming months, specifically on non-assurance services and occurrences related to individuals missing deadlines to report The expectation to act with integrity in accordance with high ethical The Chief Ethics Officer presents a report on the outcome of all fees for certain audit clients – the firm’s policy will be aligned financial interests or business relationships. standards is at the core of everything we do. To this end our Global Speak Up reports to the Executive and the Board. A targeted accordingly. Any breach of independence policies is taken seriously, Code of Business Conduct (Global Code) and our Africa Code of communication strategy resulted in increased ethics awareness and may result in sanctions determined in accordance with the Business relationships monitoring system (BRMS) Professional Conduct outline the commitment we make and the and a concomitant increase in the number of Speak Up reports Deloitte Africa disciplinary framework. A dedicated Director of The BRMS records the business relationships of the firm and all standards we adhere to as Deloitte professionals. We take any over the past year. Independence is appointed to oversee firm and staff compliance staff and monitors compliance with independence policy. All breach of these commitments and standards seriously, and any with the independence requirements. Support is provided by an Deloitte Africa Independence proposed relationships require pre-approval through our BRMS, breach may result in sanctions determined in accordance with the Independence network that was established within all our and certain relationships are re-evaluated and approved on an Deloitte Africa disciplinary framework. The professional services industry took root and blossomed when businesses and regions across the Africa continent. annual basis. the capital markets determined that there was a unique, material A dedicated Chief Ethics Officer is appointed to drive our ethics Several systems of quality controls were developed by the Global value in hiring independent professionals to help protect the public Inspection and testing strategy and programme. firm to assist with the compliance and monitoring of independence interest. Today, external auditor independence continues to be requirements. These have been supplemented by the A sample of partners, directors and client-facing professionals of We strongly believe that the tone at the top is critical to our ethics vital to the public’s trust in the integrity of the financial reporting development of local systems of quality controls, where necessary. manager grade and above are selected for independence culture and as such leadership demonstrates ethical leadership ecosystem. Over the past year, these have been fully centralised across the inspection and testing annually. The individual’s personal not only in word but also in the decisions and actions. As part of Independence is the foundation of the firm’s external audit Africa regions to drive consistency. compliance with the firm’s independence policies is evaluated, the drive to ensure an ethics culture, our Chief Ethics Officer business and is the cornerstone of the Deloitte culture. It is key to including the accurate completion of their independence regularly facilitates conversations with all partners and directors on Independence declarations the firm’s success and is deeply embedded in everything we do – it declarations and GIMS and BRMS records. topical issues. In the past year the conversation centred on is a mindset and a behaviour, not merely a compliance checklist. All Electronic independence declarations are completed by all staff ‘Respect and Inclusion’ and ‘Responsible Business’. Deloitte entity search and compliance (DESC) system professional staff have an individual ongoing commitment to annually whereby they confirm that they have fully complied with A network of Ethics Champions has been established across the independence, just as much as any other professional aspect of all aspects of the firm’s independence policies over the past 12 The DESC system contains group structure information of all the Firm to assist in driving our ethics messaging throughout all fulfilling their roles at the firm. months. Similarly, each new hire completes a declaration upon firm’s audit clients. Any new proposed non-audit service for any businesses and all regions across the continent. joining the firm, confirming their understanding of the firm’s audit client or its affiliate is submitted to the relevant audit partner, Independence is however not an audit-only concern. It is a firm independence policies after receiving extensive training on these. whose role is to ensure that the scope of services complies with Our annual ethics survey confirmed that 98% of respondents concern. Our independence with respect to external audit clients is The firm also signs an annual confirmation to the Global firm, the relevant independence policies, and that it falls within the believe that Deloitte is an ethical workplace. The survey identified not negotiable and it is as key to our success as quality client confirming firm independence compliance over the past 12 scope preapproved by the entity’s audit committee. This is potential blind spots, which enables the ethics team to address service. Our firm and all its professionals personify an months. facilitated through the Service Request Monitoring (SRM) these through targeted interventions. The Chief Ethics Officer independence mindset. In practice, this means that we meet the application within DESC. The information contained in the DESC shares the survey results with all Deloitte professionals, and expectations of our regulators in everything we do collectively and system is continuously updated to ensure its accuracy and presents both the results and an action plan to the Executive and individually, from how we serve our clients to how we manage our completeness. The system also allows all staff to confirm the the Board. firm and personal financial and business relationships. permissibility of a new personal financial interest, before the acquisition is made. 20 21
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