Guide to using ISRS4400 for Volunteer - Observer Engagements EXPRESSION OF INTEREST FOR TRAINING PROVIDERS TO PROVIDE APPROVED TRAITO SAICA ...
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Guide to using ISRS4400 for Volunteer Observer Engagements EXPRESSION OF INTEREST FOR TRAINING PROVIDERS TO PROVIDE APPROVED TRAITO SAICA MEMBERS SOUTHERN AFRICAN INSTITUTE FOR BUSINESS ACCOUNTANTS 1
The Southern African Institute for Business Accountants 3 Bauhinia Street No 2 Oxford Office Park Centurion 0046 For further information on this guide, please email technical@saiba.org.za. Registered SAIBA members in good standing may download this publication from the SAIBA website: http://www.saiba.org.za. The mission of The Southern African Institute for Business Accountants (SAIBA) is to serve the public interest, strengthen the accountancy profession in Southern Africa and contribute to the development of a strong regional economy by establishing and promoting adherence to high-quality professional standards, furthering co-operation on such standards and speaking out on public interest issues where the profession’s expertise is most relevant. This will enable SAIBA to deliver trusted advisors to Southern African small business and support staff to big business. Publication copyright© April 2019 by the Southern African Institute for Business Accountants (SAIBA). All rights reserved. Permission is granted to make copies of this work provided that such copies are for use in academic classrooms or for personal use and are not sold or disseminated and provided that each copy bears the following credit line: “Publication copyright © April 2019 by Southern African Institute for Business Accountants. All rights reserved. Used with permission.” Otherwise, written permission from SAIBA is required to reproduce, store or transmit this document, except as permitted by law. SAIBA assumes no liability or guarantee whatsoever for damages of any type, including and without limitation for direct, special, indirect, or consequential damages associated with the use of this publication. This publication does not constitute legal advice. Users of this document should obtain their own legal advice before applying the content of this document.
GUIDE TO USING ISRS 4400 FOR VOLUNTEER OBSERVER ENGAGEMENTS (This guide is effective) Table of Contents Introduction ........................................................................................................................... 4 Political partiucipation for disabled persons ............................................................................ 4 Observer status ...................................................................................................................... 5 The focus of the SAIBA observations in the 2019 elections....................................................... 6 How to use the Guide ............................................................................................................. 6 Objective of an Agreed-Upon Procedures Engagement ............................................................ 7 General Principles of an Agreed-Upon Procedures Engagement ............................................... 7 Defining the Terms of the Engagement ................................................................................... 8 Planning ................................................................................................................................. 8 Documentation....................................................................................................................... 8 Procedures and Evidence ........................................................................................................ 9 Reporting ............................................................................................................................... 9 Appendix 1 – Illustrated Report............................................................................................. 11 Appendix 2 – Checklist .......................................................................................................... 15
Introduction 1. Citizen observers are world-wide becoming a widely accepted practice. As a civil society organization serving and protecting the South African public we wish to observe the electoral process and present an assessment after election day on the accessibility of polling stations to the disabled community. It is a very specific observer task we have set ourselves but one that contributes to ensuring elections are free and fair to all citizens. 2. Although we plan to focus on a specific aspect of the election process and realize that our efforts are only one part of the citizen-based promotion of election integrity, we do believe that our professional skills can be utilized to give a voice to a marginalized community and help their voice be heard. We will continue to advocate for reforms throughout the inter- election period, and continue to monitor the degree to which they have been considered and implemented prior to the next election. 3. SAIBA is a controlling body for accountants, accounting officers and independent reviewers in South Africa and Namibia. SAIBA has been authorized by statute to regulate these professionals in providing professional assurance services to the general business community. 4. SAIBA protects the public interest by ensuring our members perform their work in terms of International quality control standards, ethical code of conduct and assurance standards. 5. Our members are experts in issuing assurance and non-assurance reports on whether systems or processes operate in terms of set criteria for example: a. Performing limited assurance engagements to confirm whether the financial statements of a company is prepared in terms of a financial reporting standard, b. Performing factual findings on financial and non-financial information to ensure that governance and compliance processes are complied with. 6. We now wish to utilize our collective expertise as professional body and individual professional members to ensure free and fair elections, specifically as it pertains to people with disabilities. Political participation for disabled persons 7. According to the International Foundation for Electoral Systems (IFES)1 “one out of every seven people in the world has a disability, yet citizens with disabilities remain under- represented in political and public life. Participation of persons with disabilities in the 1 https://eaccess.s3.amazonaws.com/media/attachments/resources_mainresource/57 0/Election_access_observation_toolkit_accessible.pdf
electoral process provides the basis for mainstreaming their inclusion in all aspects of society by breaking down social stigmas and increasing the accountability of elected representatives. 8. Persons with disabilities encounter barriers as they participate in elections as voters, observers, candidates, election officials, and in other ways. 9. Election observation provides the opportunity to collect data on the barriers that persons with disabilities encounter so that recommendations can be made to election management bodies (EMBs), political parties, and others to make processes more inclusive. 10. According to IFES example of barriers include: • Physical barriers to the polling station, • Lack of assistive devices such as tactile ballot guides, • Lack of voter education materials in accessible formats such as sign language, • Legal barriers that disenfranchise people with intellectual and psychosocial disabilities, • Lack of engagement by political parties, including not providing political campaign materials in accessible formats, and • Social stigma that discourages candidates with disabilities from running for office. 11. The UN Committee on the Rights of Persons with Disabilities issued guidelines on article 14 of the Convention on the Rights of Persons with Disabilities (CRPD) which was adopted during the Committee’s 14th session, held in September 2015. The CRPD contains the most comprehensive description of the political rights of people with disabilities. The treaty’s definition of disability includes women and men who have physical, visual, auditory, intellectual and psychosocial disabilities. Observer status 12. During April 2019 SAIBA applied for observer status with the Electoral Commission of South Africa (IEC) and requested members to volunteer their expert services and perform factual findings pertaining to the accessibility of election polling stations for people with disabilities. 13. According to the IEC “observers, both domestic and international, play a crucial role in ensuring that the elections are transparent, free and fair, and that the outcome is accepted by voters, political parties and candidates. Observers keep an eye on the voting process at voting stations, the counting of votes, and the final counting, determination and declaration of results”.
The focus of the SAIBA observations in the 2019 elections 1. Election observations can be calssified as either Standalone or Mainstream 2. Standalone observations are focused on election access and observers use checklists that include questions limited to accessibility and inclusion. Under a Mainstream approach observers would also consider long-term observations of political parties and conduct towards disabled persons gathering “data related to access throughout the electoral cycle, which forms the foundation for recommendations to improve electoral processes”. 2. For the 2019 elections SAIBA will focus only on Standalone observations. The checklist of observations to be conducted is included in the Guide. How to use the Guide 3. This SAIBA Guide to Using ISRS4400 for Volunteer Observer Engagements (the Guide) provides Small Medium Practices with instructions on how to apply the International Standard on Related Services 4400: Report on Factual Findings (Agreed-Upon- Procedures) to their work as Volunteer Observers. 4. The Guide is an adaptation from the International Standard on Related Services 4400 (ISRS4400). It incorporates the ISRS 4400 text verbatim but makes amendments as appropriate to the requirements pertaining to Volunteer Observers. 5. These requirements are: a. The mandatory Regulations on the Accreditation of Observers, 1999 published under GN R362 in GG 19857 of 17 March 1999, Schedule A, and b. The voluntarily adopted Election Access Observation Toolkit issued by the International Foundation for Electoral Systems. 6. BAP(SA) members will use the Guide to perform factual findings related to the accessibility of polling stations to people with disabilities, and submit their findings to SAIBA. SAIBA will collate the findings and present a ISRS4400 report to the IEC, legislators and other stakeholders to improve accessibility for the disabled in future elections. 7. Although ISRS 4400 is directed towards engagements regarding financial information. It provides useful guidance for engagements regarding non-financial information, such as election observation, provided the BAP(SA) has adequate knowledge of the subject matter in question and reasonable criteria exist on which to base findings. 2Pg34 https://eaccess.s3.amazonaws.com/media/attachments/resources_mainresource/570/Election_access_observation _toolkit_accessible.pdf
Objective of an Agreed-Upon Procedures Engagement 8. The objective of an agreed-upon procedures engagement is for the BAP(SA) to carry out procedures of an audit nature to which the BAP(SA) and the entity and any appropriate third parties have agreed and to report on factual findings. 9. In this case the parties involved are: the BAP(SA), SAIBA and the IEC. 10. After collecting the findings from the BAP(SA) that performed the actual observation at the polling station, SAIBA will prepare a report of the factual findings of agreed-upon procedures. The report will not express an assurance on the election or the accessibility to the polling station. Instead, users of the report assess for themselves the procedures and findings reported by SAIBA and the BAP(SA) and draw their own conclusions from the work performed. 11. The report is restricted to those parties that have agreed to the procedures to be performed since others, unaware of the reasons for the procedures, may misinterpret the results. General Principles of an Agreed-Upon Procedures Engagement 12. The BAP(SA) should comply with the Code of Ethics for Professional Accountants issued by the International Ethics Standards Board for Accountants (the IESBA Code). Ethical principles governing the BAP(SA)’s professional responsibilities for this type of engagement are: a. Integrity; b. Objectivity; c. Professional competence and due care; d. Confidentiality; e. Professional behavior; f. Technical standards; and g. Independence 13. Independence is not normally a requirement for agreed-upon procedures engagements; however, as the governing body of all BAP(SA)s SAIBA requires that all BAP(SA)s must comply with the independence requirements of the IESBA Code. Where the BAP(SA) is not independent, a statement to that effect would be made in the report of factual findings. 14. The BAP(SA) should comply with the International Standards of Quality Control (ISQC1) as issued by the International Auditing and Accounting Standards Board (IAASB) as applicable to ISRS 4400 engagements. 15. The BAP(SA) should conduct an agreed-upon procedures engagement in accordance with ISRS 4400 and the terms of the engagement.
Defining the Terms of the Engagement 16. The BAP(SA) should ensure with representatives of the entity and, ordinarily, other specified parties who will receive copies of the report of factual findings, that there is a clear understanding regarding the agreed procedures and the conditions of the engagement. Matters to be agreed include the following: • Nature of the engagement including the fact that the procedures performed will not constitute an audit or a review and that accordingly no assurance will be expressed. • Stated purpose for the engagement. • Identification of the information to which the agreed-upon procedures will be applied. • Nature, timing and extent of the specific procedures to be applied. • Anticipated form of the report of factual findings. • Limitations on distribution of the report of factual findings. When such limitation would be in conflict with the legal requirements, if any, the BAP(SA) would not accept the engagement. 17. In certain circumstances, for example, when the procedures have been agreed to between the regulator, industry representatives and representatives of the accounting profession, the BAP(SA) may not be able to discuss the procedures with all the parties who will receive the report. In such cases, the BAP(SA) may consider, for example, discussing the procedures to be applied with appropriate representatives of the parties involved, reviewing relevant correspondence from such parties or sending them a draft of the type of report that will be issued. 18. Based on the nature of the engagement in that SAIBA and the BAP(SA) work together on issuing a single ISRS4400 report to the IEC a traditional engagement letter is not required between the BAP(SA) and the IEC. SAIBA has been arwarded observer status and this replaces the engagement letter. Planning 19. The BAP(SA) should plan the work so that an effective engagement will be performed. The planning in this instance relate to readin the Regulations, the IFES Toolkit, this Guide and viewing the SAIBA webinar training iro Volunteer Observer duties. Documentation 20. The BAP(SA) should document matters which are important in providing evidence to support the report of factual findings, and evidence that the engagement was carried out
in accordance with this ISRS and the terms of the engagement. This documentation should be done using the checklist provided in the Guide. Procedures and Evidence 21. The BAP(SA) should carry out the procedures agreed upon and use the evidence obtained as the basis for the report of factual findings. 22. The procedures applied in an engagement to perform agreed-upon procedures may include the following: • Inquiry and analysis. • Recomputation, comparison and other clerical accuracy checks. • Observation. • Inspection. • Obtaining confirmations. Appendix 2 to this ISRS is an example report which contains an illustrative list of procedures which may be used as one part of a typical agreed-upon procedures engagement. Reporting 23. The report that SAIBA will issue on an agreed-upon procedures engagement needs to describe the purpose and the agreed-upon procedures of the engagement in sufficient detail to enable the reader to understand the nature and the extent of the work performed. 24. The SAIBA report of factual findings will contain: a. Title; b. Addressee; c. Identification of specific non-financial information to which the agreed-upon procedures have been applied; d. A statement that the procedures performed were those agreed upon with the relevant parties; e. A statement that the engagement was performed in accordance with the International Standard on Related Services applicable to agreed-upon procedures engagements, or with relevant national standards or practices; f. When relevant a statement that the report provider is not independent of the entity; g. Identification of the purpose for which the agreed-upon procedures were performed; h. A listing of the specific procedures performed; i. A description of the reoprt providers factual findings including sufficient details of errors and exceptions found;
j. Statement that the procedures performed do not constitute either an audit or a review and, as such, no assurance is expressed; k. A statement that had the report provider performed additional procedures, an audit or a review, other matters might have come to light that would have been reported; l. A statement that the report is restricted to those parties that have agreed to the procedures to be performed or the conditions under which the report will be made available to a wider audience; m. A statement (when applicable) that the report relates only to the elements, accounts, items or non-financial information specified and that it does not extend beyond those items; n. Date of the report; o. BAP(SA)’s address; and p. BAP(SA)’s signature. 25. Appendix 1 to this ISRS contains an example of a report of factual findings issued in connection with an engagement to perform agreed-upon procedures regarding non- financial information.
Appendix 1 – Illustrated Report Illustration of a Report of Factual Findings in Connection with Accredited Observers for the National Elections in South Africa sheduled for 8 May 2019 using the Standalone approach for short term observations as illustrated in the Election Access Observation Toolkit issued by the International Foundation for Electoral Systems. (Letter head of SAIBA) For attention Representative individual Business entity name Contact details REPORT OF FACTUAL FINDINGS OF THE SOUTHERN AFRICAN INSTITUTE FOR BUSINESS ACCOUNTANTS TO THE ELECTORAL COMMISSION OF SOUTH AFRICA (IEC) ON THE STANDALONE SHORT- TERM OBSERVATIONS OF THE SOUTH-AFRICAN NATIONAL ELECTIONS HELD ON 8 MAY 2019 We have performed the procedures agreed with you and enumerated below with respect to our accredited observation status in terms of: • Regulations on the Accreditation of Observers, 1999 published under GN R362 in GG 19857 of 17 March 1999, Schedule A, and • The voluntarily adopted Election Access Observation Toolkit issued by the International Foundation for Electoral Systems (IFES) relevant to short term standalone engagements. Our engagement was undertaken in accordance with the International Standard on Related Services (ISRS) 4400, the Code of Ethics for Professional Accountants and the International Standard of quality Control. The procedures were performed solely to assist the IEC, Disabled People Organisations (DPO), and legislators to become aware of barriers to participation found at election polling stations that was observed by SAIBA.
Procedures We used the IFES disabled persons access checklist and compared it to observations made at selected number of polling stations. Our findings are based on observations only. The procedures are shown in appendix 1 to this report. We report our findings below: Access to the Polling Center on Election Day 1. With respect to item 1 we found that [all/not all] polling stations was on the ground. 2. With respect to item 2 we found that there [were/were not] ramps available for voters with disabilities. 3. With respect to item 3 we found that polling centers [have/does not have] toilets or washrooms that could be used by persons with disabilities. 4. With respect to item 4 we found that polling centers [have/does not have] enough accessible seating for each person who requires accessible seating. 5. With respect to item 5 we found that polling centers [have/does not have] enough space for wheelchair-users to move around easily. 6. With respect to item 6 we found that polling centers [have/does not have] hallways that are clear of obstacles, both on the ground and hanging from above. 7. With respect to item 7 we found that polling centers [have/does not have] voting area free of obstacles. 8. With respect to item 8 we found that polling centers [have/does not have] wide entrances and exits. 9. With respect to item 9 we found that polling centers [have/does not have], for voters with disabilities that arrive by car, parking space close to an accessible entrance. 10. With respect to item 10 we found that polling centers [have/does not have] an accessible route provided from the parking space to the entrance of the building. 11. With respect to item 11 we found that polling centers [have/does not have] paths to the voting area free of obstacles that would prevent voters with disabilities from accessing the voting area. 12. With respect to item 12 we found that polling centers [have/does not have] a desk at the polling station to provide assistance to persons with disabilities? 13. With respect to item 13 we found that polling centers [have/does not have] any poll workers that appear to have a disability. 14. With respect to item 14 we found that poll workers [have been/have not been] trained to support voters with disabilities. 15. With respect to item 15 we found that persons with disabilities [were/were not] allowed
to be assisted by a person of their choice in order to vote. 16. With respect to item 16 we [did/did not] observe that an assistant or poll worker intimidated or otherwise unduly influenced a voter with disability. 17. With respect to item 17 we observed [_____number of people] with disability received assistance of which [_________ were women]. Election Access Questions Targeting Persons with Different Types of Disabilities Visual Disability: Number of persons observed__________ 18. With respect to item 18 we found that polling centers [have/does not have] a voting guide in braille or in an audio format? 19. With respect to item 19 we found that polling centers [have/does not have] a voting guide in large font? 20. With respect to item 20 we found that polling centers [have/does not have] magnifying glasses or sheets for reading ballots. 21. With respect to item 21 we found that polling centers [have/does not have] tactile ballot guides or ballot marking guides. 22. With respect to item 22 we found that polling centers [have/does not have] sufficient light in the voting area. Physical Disability: Number of persons observed__________ 23. With respect to item 23 we found that the writing surface in the voting booth [is/is not] low enough for all voters to reach. 24. With respect to item 24 we found that there [is/is not] enough space for voters who use assistance devices to be able to get into the voting booth to vote. 25. With respect to item 25 we found that voters with disabilities [are/are not] able to reach the ballot box when depositing their ballot. 26. With respect to item 26 we found that ther [are/are not] any assistive devices available to assist with dexterity issues, such as large grip pens or alternative voting methods. Auditory Disability: Number of persons observed__________ 27. With respect to item 26 we found that poll workers [are/are not] offering communication to support Deaf voters. 28. With respect to item 27 we found that polling staff providing information on the voting process to voters who are hard-of-hearing are speaking slowly and with a clear expression. 29. With respect to item 28 we found that there [were/were not] professional sign language interpreters assisting Deaf voters to communicate with the poll workers.
Intellectual or Psychosocial Disability: Number of persons observed__________ 30. With respect to item 30 we found that voters with intellectual disabilities appear to [have/does not have] difficulty understanding the words on the ballot paper. 31. With respect to item 31 we found that voters with intellectual disabilities appear to [be certain/not certain] about how to vote? 32. With respect to item 32 we found that voters with psychosocial disabilities [were/were not] offered a quiet place to wait to vote. 33. With respect to item 33 we found that voters with intellectual or psychosocial disabilities [were/were not] denied access to vote based on their disability. 34. With respect to item 34 we found that the ballot paper [is/is not] easy to understand for a person with an intellectual disability. Because the above procedures do not constitute an assurance engagement in accordance with International Standards on Assurance Engagements 3000 (ISAE3000): Assurance on non- financial information (or relevant national standards or practices), we do not express any assurance on the findings made. Had we performed additional procedures or had we performed an assurance engagement of accessibility to polling stations/centers other matters might have come to our attention that would have been reported to you. Our report is solely for the purpose set forth in the first paragraph of this report and for your information and is not to be used for any other purpose or to be distributed to any other parties. We will however proviude a summarised version of our findings to the relevant staekholders such as election officials, political parties, parliament, and the media for the purpose of creating awareness of accessibility issues during elections. This report relates only to the accounts and items specified above and does not extend to any other long-term mainstream election observations. SAIBA Date Address
Appendix 2 – Checklist Access to the polling station on election day: 1. Is the polling station on the ground floor? 2. If there are steps into the polling station, is there a ramp available for voters with disabilities to use? 3. Does the polling center have toilets or washrooms that could be used by persons with disabilities? 4. Does the polling center have enough accessible seating for each person who requires accessible seating? 5. Does the polling center have enough space for wheelchair-users to move around easily? 6. Does the polling center have hallways that are clear of obstacles, both on the ground and hanging from above? 7. Does the polling center have voting area free of obstacles? 8. Does the polling center have wide entrances and exits? 9. For voters with disabilities that arrive by car, are they provided a parking space close to an accessible entrance? 10. Is there an accessible route provided from the parking space to the entrance of the building? 11. Are paths to the voting area free of obstacles that would prevent voters with disabilities from accessing the voting area? 12. Is there a desk at the polling station to provide assistance to persons with disabilities? 13. Are there any poll workers that appear to have a disability? 14. Have poll workers been trained to support voters with disabilities? 15. Were persons with disabilities allowed to be assisted by a person of their choice in order to vote? 16. Did an assistant or poll worker intimidate or otherwise unduly influence a voter with disability? 17. In total, how many disabled voters received assistance? How many were women? Election Access Questions Targeting Persons with Different Types of Disabilities Visual Disability 18. Does the polling station have a voting guide in braille or in an audio format? 19. Does the polling station have a voting guide in large font? 20. Are magnifying glasses or sheets for reading ballots provided? 21. Are tactile ballot guides or ballot marking guides provided? 22. Is there sufficient light in the voting area?
Physical Disability 23. Is the writing surface in the voting booth low enough for all voters to reach? 24. Is there enough space for voters who use assistance devices to be able to get into the voting booth to vote? 25. Are voters with disabilities able to reach the ballot box when depositing their ballot? 26. Are any assistive devices available to assist with dexterity issues, such as large grip pens or alternative voting methods? Auditory Disability 27. Are poll workers offering communication to support Deaf voters? For example, are they using sign language or writing information down? 28. Are polling staff providing information on the voting process to voters who are hard-of- hearing by speaking slowly and with a clear expression? 29. Are there professional sign language interpreters assisting Deaf voters to communicate with the poll workers? Intellectual or Psychosocial Disability 30. Do voters with intellectual disabilities appear to have difficulty understanding the words on the ballot paper? 31. Do voters with intellectual disabilities appear to be uncertain about how to vote? 32. Were voters with psychosocial disabilities offered a quiet place to wait to vote? 33. Were any voters with intellectual or psychosocial disabilities denied access to vote based on their disability? 34. Is the ballot paper easy to understand for a person with an intellectual disability? For example, did it include pictures of candidates or images from each party?
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