The impact of recent global trends - April 2021 - ECIIA

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ECIIA

The impact
of recent global
trends
ON INTERNAL AUDITING IN THE
INSURANCE INDUSTRY

                         April 2021
0
Introduction about ECIIA 05
                                                        1
                                                 Introduction 07
                                                   07   Use of Technology
                                                   07   Workforce
                                                   07   ESG, Sustainability
                                                   07   Topics covered by this paper

          2
Impact of Macro Trends 09
                                                                                                  3
                                                                               Reaffirming the purpose 13
                                                                                                                                                                 4
                                                                                                                                              Impact of the new ways of 16
 09 Impact on the global environment and on Insurance Companies                of Internal Audit                                              working
 10 Reactions of Insurance Companies
                                                                                   13 Judgement at the core of audit assurance                   16   Medium-term Impact on the Working Environment
 10 Immediate reactions of Audit Departments to the crisis
                                                                                                                                                 16   Opportunities of a Remote Working Environment
                                                                                                                                                 16   Risks of an entire shift to Remote Working
                                                                                                                                                 18   Impacts of Remote Working on Companies
                                                                                                                                                 20   Impact on the Internal Control System

                5
    Remote Auditing 22
                                                                                                  6
                                                                                       Future of Audit Work 27
                                                                                                                                                                                  7
                                                                                                                                                                            Conclusions 31
      22 Opportunities of Remote Working for Internal Audit                              27 Beyond the immediate, frameworks should not fundamentally change
      23 Audit needs                                                                     27 Building on the right mix of physical and remote working
      23 The limits of remote working for auditors
ABOUT ECIIA

                   The European Confederation of In-
                   stitutes of Internal Auditing (ECIIA) is
                   the professional representative body
                   of 34 national institutes of internal
                   audit in the wider geographic area of
                   Europe and the Mediterranean basin.
                   The mission of ECIIA is to be the con-
                   solidated voice for the profession of

0
                   internal auditing in Europe by dealing
                   with the European Union, its Parlia-
                   ment and Commission and any other
                   appropriate institutions of influence.
                   The primary objective is to further the
                   development of corporate governance
                   and internal audit through knowledge
                   sharing, key relationships and regula-
                   tory environment oversight.

                                                                                   ABOUT ECIIA INSURANCE COMMITTEE

                                                                                   ECIIA set up an Insurance Commit-
                                                                                   tee1 in 2012 with Chief Audit Execu-
                                                                                   tives of the largest European Insur-
                                                                                   ance companies. The mission of the
                                                                                   ECIIA Insurance Committee is: “To be
                                                                                   the consolidated voice for the profes-
                                                                                   sion of Internal Audit in the Insurance
                                                                                   sector in Europe by dealing with the
                                                                                   Regulators and any other appropriate
                                                                                   institutions of influence at European
                                                                                   level and to represent and develop
                                                                                   the Internal Audit profession as part
                                                                                   of good corporate governance across
                                                                                   the Insurance Sector in Europe ». ECI-
                                                                                   IA represents around 47.000 internal

    Introduction                                                                   auditors and around 12.000 are ac-
                                                                                   tive in the insurance sector. The paper

     about ECIIA
                                                                                   describes the results of discussions
                                                                                   amongst the Committee members and
                                                                                   we want to thank the Committee mem-
                                                                                   bers for their input and James Fisher,
                                                                                   Global Head of Audit Practice at AXA
                   1 Stephen Licence (Legal & General) and Committee Chair,
                   Amaury De Warenghien (Axa), Nora Guertler (Generali),           and Antonella Loffredo, Audit Manag-
                   Ann-Marie Andtback Beckman (Sampo Group), Martin                er at Assicurazioni Generali for their
                   Studer (Zurich), María Luisa Gordillo Gutierrez (MAPFRE),
                   Andréa Joham (Uniqa Group), Dr Jeannine Bartmann (Alli-         collaboration.
                                 anz Group), Astrid Langeveld-Vos (Achmea).

                                                                               5
The Covid-19 pandemic has been the               ning of being understood. A new com-
                   most significant disruptive event for            prehension is emerging for what di-
                   decades, impacting the political, social         versity and inclusion can really mean,
                   and economic environment of insur-               and what the opportunities of a truly
                   ance companies for years to come. It             diverse and inclusive workforce can
                   has been a catalyst for several dis-             bring both to the business and individ-
                   tinct pre-existing macro trends which            uals. Beyond equality of opportunity,
                   are described in the following.                  appreciation is growing for the bene-
                                                                    fits of having varied frames of refer-
                                                                    ence and different points of view.

1
                   USE OF TECHNOLOGY

                   Disruption to business also stems                ESG, SUSTAINABILITY
                   from technological advances which
                   enable location-independent working.             Concern is increasing on global en-
                   The Covid-19 pandemic has acceler-               vironmental and societal conditions,
                   ated almost universally the adoption             with the role industries play and are
                   of technological solutions as coping             expected to play in actively contribut-
                   mechanisms for lockdowns and travel              ing gaining attention.
                   restrictions.

                   Advances in data analytics and the
                   consequent impact on auditing (as                TOPICS COVERED BY THIS PAPER
                   well as on insurance business) are not
                                                                    This paper addresses the following
                   covered in detail in this paper, since
                                                                    topics:
                   they are covered in the forthcoming
                   ECIIA Guidance Paper on unlocking                Impact of macro trends: on insurance
                   the value of Internal Audit functions            and Internal Audit, focusing on those
                   by implementing Data Analytics / Sci-            directly resulting from the Covid-19
                   ence.                                            pandemic1;

                                                                    Reaffirming the Purpose of Internal
                                                                    Audit: Judgement at the Core of Audit
                   WORKFORCE
                                                                    Assurance;
                   With a significant part of employees in
                                                                    Impact of the New Ways of Working:
                   remote working from one day to the
                                                                    Environment and risks;
                   other and for at least one year, the

    Introduction   Covid-19 pandemic has triggered a
                   revolution in the daily life of white-col-
                                                                    Remote Auditing: Opportunities, Audit
                                                                    needs and limits;
                   lar workers. Impacts on performance,
                   results, collaboration, teams, leader-           Future of Audit Work in the light of pro-
                   ship, people development and man-                cess automation and remote working.
                   agement, professional threats and
                   opportunities are just at the begin-

                                                                    1 The specific considerations for Internal Audit resulting
                                                                    from the workforce and climate macro trends are includ-
                                                                    ed in a separate paper addressing ESG (Environment, So-
                                                                                                   cial, Governance) matters.

                                                                7
IMPACT ON THE GLOBAL ENVIRON-                                      • Pressure on insurers from govern-
                   MENT AND ON INSURANCE COMPA-                                       ments, regulators, the consumer pro-
                   NIES                                                               tection bodies and public to share the
                                                                                      consequential costs of the pandemic
                   The impact of the Covid-19 pandemic                                and to compensate customers above
                   on the global environment of insur-                                and beyond contractually agreed lim-
                   ance companies includes, inter alia,                               its.
                   the following measures and subse-
                   quent effects, in a context of a general                           • Calls by the ECB, EIOPA and most
                   increase in political instability2:                                European national supervisory au-

2
                                                                                      thorities for insurers to suspend or
                   • Lockdowns lasting several months                                 defer dividend payments.
                   in many countries and returning in
                   waves, complete or partial closure                                 The key impacts of the Covid-19 pan-
                   of borders, obstacles to shipping                                  demic on the business and risks to in-
                   of goods and travel, shift to remote                               surance companies are as of today3:
                   working for a significant part of the
                   population.                                                        • Increase in financial risk (incl. im-
                                                                                      pairments of assets) due to market
                   • Impacts on urban structures with                                 volatility and low interest rates.
                   cities starting to change, affecting
                   also Real Estate.                                                  • Increase in liquidity risks as well as
                                                                                      credit risks.
                   • Drop in GDP in most countries as a
                   result of contraction in many indus-                               • Increase in operational risks: IT
                   tries (e.g. aviation, tourism, manufac-                            and security risks (e.g. functionality
                   turing) and increase in insolvencies,                              of IT and corporate processes during
                   with the risk of recession, increase in                            lockdown; cyberrisks due to a combi-
                   credit defaults and another financial                              nation of an increased external threat
                   crisis.                                                            potential and employees working from
                                                                                      home) and Fraud risks.
                   • Massive financial aid package by the
                   EU and measures taken by the ECB to
                                                                                      • Significant increase in financial
                   stabilize the economy, and other eco-
                                                                                      losses and underwriting risks for
                   nomic policies introduced outside the
                                                                                      corporate business, depending on the
                   EU; subsequent expansion and exten-
                                                                                      portfolio and the underlying terms
                   sion of the low interest rate environ-
                                                                                      and conditions (massive increase in
                   ment across the globe.
                                                                                      claims for business interruption and

       Impact of   • Increased volatility on global equity
                   markets: dramatic falls on equity mar-
                                                                                      event cancellation).

    macro trends
                                                                                      • Increase in legal risks and compli-
                   kets in March/April 2020 followed by
                                                                                      ance risks (e.g. requests to insurers
                   a period of recovery and potential re-
                                                                                      to share in the consequential costs
                   peats of the cycle as further waves or
                                                                                      of the pandemic; legal rulings in the
                   the economic impact of the pandemic
                                                                                      event of unclear or disputed terms in
                   materialize.
                                                                                      insurance policies).

                   2 For more details refer to the Joint Committee report on
                   risks and vulnerabilities in the EU financial system (EIOPA,       3 These and further risks are published for example by
                                                                    ESMA, EBA)                                   EIOPA in its Risk Dashboard..

                                                                                  9
• Increased understanding of the op-            Regulators have contributed to the        cusing on outcomes (quality and pro-
portunities and benefits of a globally          debate on how to help citizens to deal    ductivity) rather than time spend, and
connected workforce and reduced                 with Covid-19 impacts. EIOPA for in-      heightened focus on communication,
need for corporate real estate.                 stance, in a statement on actions,        team management and support.
                                                launched a call to action for insurers
                                                and intermediaries to mitigate the im-
                                                pact of Covid-19 on consumers.
REACTIONS OF INSURANCE COMPA-
NIES

                                                IMMEDIATE REACTIONS OF AUDIT
Most insurance companies have tak-              DEPARTMENTS TO THE CRISIS
en the following measures to face the
crisis:                                         In view of the crisis and the shift to
                                                remote work, many Internal Audit de-
                                                partments have taken one or more of
• Activation of Business Continuity             the following ad hoc measures in re-
Plans;                                          sponse to the Spring 2020 lockdowns:
• Shift of large parts of their staff to        • Updating the audit risk assessment
remote work;
                                                • Reviewing audit planning and ad-
• Significant enhancement of IT in-             justment of plan timeframes
frastructure, network capacities and
digital tools;                                  • Presentation to and approval of the
                                                Audit Committee of envisaged chang-
• Finance: Liquidity and cash man-              es of the audit risk assessment, the
agement, updates of business plans;             audit plan and potentially of audit op-
                                                erations
• Underwriting: Review of contract
conditions, removal of silent covers            • Extension of the planned implemen-
(e.g. pandemics, cyber);                        tation dates of all or some outstand-
                                                ing corrective actions
• Product: Innovation and/or revamp
of insurance products in order to               • Flexibility with the deadlines estab-
meet clients’ needs and protect the             lished for answering draft reports
company from accumulation of risks;             and providing action plans
• Managing the impact on business               • Providing temporary support to oth-
and operations in various ways (cus-            er business areas during the acute
tomer services, claims management,              phase of the crisis
impact on underwriting, etc.);
                                                Moreover, Internal Audit has experi-
• Steps towards digitalization of dis-          enced the same adoption of remote
tribution activities, claims manage-            working as other departments, with a
ment and other client interactions              variety of consequences, for instance
points.                                         a resultant further shift towards fo-

                                           10
JUDGEMENT AT THE CORE OF AUDIT                                 Moreover, the International Stan-
                      ASSURANCE                                                      dards for the Professional Practice
                                                                                     of Internal Auditing, define the assur-
                      The Institute of Internal Auditors (IIA)                       ance provided by Internal Audit as fol-
                      sets the purpose of internal auditing                          lows: “Assurance services involve the
                      as: an independent, objective assur-                           internal auditor’s objective assess-
                      ance and consulting activity designed                          ment of evidence to provide opinions
                      to add value and improve an organi-                            or conclusions regarding an entity,
                      sation’s operations. It helps an or-                           operation, function, process, system,
                      ganization accomplish its objectives                           or other subject matters. The nature

3
                      by bringing a systematic, disciplined                          and scope of an assurance engage-
                      approach to evaluate and improve                               ment are determined by the internal
                      the effectiveness of risk management,                          auditor”. Further insight and require-
                      control, and governance processes4.                            ments on Audit work can be found in
                                                                                     the ECIIA Guidance Paper on Internal
                      The IIA has further defined the core
                                                                                     Audit5.
                      principles that Internal Audit should
                      exhibit to be effective in achieving this                      In the pandemic context of significant
                      purpose:                                                       change and accelerating trends, any
                                                                                     impact of the situation on Internal Au-
                      • Demonstrates integrity
                                                                                     dit’s purpose needs to be considered.
                      • Demonstrates competence and due
                                                                                     Both the purpose and principles
                      professional care
                                                                                     hold true and already include for-
                      • Is objective and free from undue in-                         ward-looking focus on improving
                      fluence (independent)                                          the company’s management of risks,
                                                                                     whatever these risks may be and their
                      • Aligns with the strategies, objectives                       rate of change. In the pandemic sit-
                      and risks of the organization                                  uation caused by Covid-19, there is
                                                                                     even more need for Internal Audit to
                      • Is appropriately positioned and ad-                          provide assurance, to be insightful,
                      equately resourced                                             proactive and future focused, and to
                                                                                     promote organizational improvement.
                      • Demonstrates quality and continu-                            Generally, the core principles have
                      ous improvement                                                historically been managed “on site” in-
                                                                                     volving a degree of physical proximity
                      • Communicates effectively
                                                                                     with management. Therefore, the spe-
                                                                                     cific impacts of the shifts in company
       Reaffirming
                      • Provides risk-based assurance
                                                                                     operations and the way auditors work
                      • Is insightful, proactive and fu-                             resulting from the pandemic, which

    the Purpose of    ture-focused                                                   limit this contact, further strengthen
                                                                                     the need for effective communication,
                      • Promotes organizational improve-                             and the principle of aligning with strat-
     Internal Audit   ment                                                           egy, objectives and risks is particular-
                                                                                     ly relevant. To be truly future focused

                      4 https://na.theiia.org/standards-guidance/mandato-            5 https://www.eciia.eu/wp-content/uploads/2019/06/
                       ry-guidance/Pages/Definition-of-Internal-Auditing.aspx                                    ECIIA-Display-8th-draft.pdf

                                                                                13
requires strong relationships with
management to have a continuous di-
alogue, i.e. not limited to individual as-
signments, planning discussions and
committees.

The assurance which Internal Audit
provides as the core of their services
requires an objective assessment of
evidence. In order to align to the com-

                                                  4
pany’s priorities and risks, and to pro-
vide useful, sound assurance, Profes-
sional judgement, based on relevant
information, remains a key require-
ment for internal auditors. Although
professional judgement can be built
on a variety of inputs and sources,
the availability and accessibility of
relevant information may be affected
by the change companies are going
through in response to the pandemic
situation. The Covid pandemic mere-
ly serves to reinforce the importance
for Internal Audit to be forward-look-
ing, and that requires regular interac-
tion and deep knowledge which can be
limited where staff work excessively
remotely. This is explored further in
the sections 5 and 6 on Remote Audit-
ing and the Future of Audit Work re-
spectively.

                                                      Impact of the
                                                       New Ways of
                                                          Working

                                             14
MEDIUM-TERM IMPACT           ON   THE          and short-term assignments. Obvi-            bracket the working day, the distinc-             in a paperless environment. In most
WORKING ENVIRONMENT                            ously, the knowledge of the local situ-      tion between work and home life can               cases, employees do not have a sepa-
                                               ation, regulation and language needs         become blurred. Without encourag-                 rate office at home which can result in
In the lockdown phases of the pan-             to be ensured.                               ing staff to switch off, overwork can             the following unintended consequenc-
demic, remote working has become                                                            become as real a risk as managers                 es:
standard for white collar workers.             As for the abovementioned short-             not realizing that some staff may be
Some companies envisage operating              term expense reductions for compa-           underworked, but with a greater per-              • Access by third parties – people not
wholly through remote work, seeing             nies as a consequence of large-scale         sonal toll. Inadequate home office en-            working for the company can access
the benefits of global connections,            remote working, these need to be bal-        vironments can compound the effect,               company records and information,
and using virtual conferencing tools           anced against medium-term impacts            particularly where staff had to make              even unintentionally, and materials.
to compensate the loss of physical in-         including the risks mentioned in the         the emergency switch over in ear-
teraction. With increasing pressure            section below. At the current stage,                                                           • Eavesdropping – with people work-
                                                                                            ly 2020. Adequate and healthy home
on revenues resulting from the strain          this trade-off is difficult to assess, but                                                     ing from home, phone calls and video
                                                                                            working arrangements, such as pro-
placed on economies and populations            will become clearer in the following                                                           conferences might be overheard by
                                                                                            viding monitors and chairs, can be
come new initiatives on reducing               months and years.                                                                              friends, family members, neighbours
                                                                                            managed for longer-term working
business travel, expenses and even                                                                                                            and/or staff such as the cleaner.
                                                                                            from home arrangements. Howev-
company premises. It remains to be                                                          er, there will always be limits in some           • Unsecure data storage – com-
seen to what extent the temporarily                                                         cases, such as not having a dedicated
                                               RISKS OF AN ENTIRE SHIFT TO RE-                                                                pounded by the potential increase in
imposed switch from human contact                                                           room separate from other household
                                               MOTE WORKING                                                                                   use of private storage devices in the
to a virtual environment will contin-                                                       activities.                                       absence of proper office infrastruc-
ue once the political restrictions have        TO STAFF: WELL-BEING, PHYSICAL AND MENTAL
                                                                                                                                              ture. For instance, without scanners
been lifted. After having experienced          HEALTH                                       Clearly, new rules are needed and
                                                                                                                                              provided by the company, confiden-
significant cost reductions during                                                          will require agreement with workers’
                                               Staff that work entirely from home                                                             tial documents can be stored, pos-
lockdown phases, many companies                                                             unions. In the first instance, clarity is
                                               can suffer from increased stress, de-                                                          sibly temporarily, on mobile phones
will not return to previous levels and                                                      needed on what is meant by “Smart
                                               pending on personal circumstances.                                                             and uploaded to weakly-protected
instead point at sustainably lower ex-                                                      working”, what this package precisely
                                               Where living alone, the loss of contact                                                        private cloud storage. Where private
penses. The temptation to cut trav-                                                         includes and how this is distinguished
                                               and particularly informal interactions,                                                        cloud services are used, particularly
el significantly needs to be tempered                                                       from the merely logistical questions of
                                               can result in isolation and disconnec-                                                         to transfer data, the location of these
with a discretionary need to travel and                                                     “remote working”.
                                               tion, real or perceived. Moreover,                                                             data is not always managed, and pri-
meet in person. Nonetheless, a degree
                                               during the most severe forms of lock-        TO ORGANISATIONS: CONFIDENTIALITY AND SE-         vacy regulations may not be respect-
of remote working is here to stay.
                                               down such as those seen in Spring            CURITY                                            ed. Securing data storage is a mat-
                                               2020, schools and childcare centres                                                            ter of IT management and not strictly
                                                                                            Without the physical security of the              linked to remote working; neverthe-
                                               were shut resulting in staff juggling
OPPORTUNITIES OF A           REMOTE                                                         office, confidentiality can be more of            less, the abrupt switch from company
                                               work with teaching or looking after
WORKING ENVIRONMENT                                                                         a problem, for example when video                 premises to private locations has ex-
                                               children. Although such an extreme
                                                                                            or phone calls take place either from             acerbated this peril.
                                               situation is unlikely to become perma-
The opportunities of a largely remote                                                       home or from public places. More-
                                               nent, a workforce which is substan-
workforce include that geographical                                                         over, company information is likely to            • Insufficiently protected networks
                                               tially working from home exacerbates
resourcing becomes less important.                                                          be generated and managed outside                  – private routers generally provide
                                               the need for flexibility and for employ-
The skills of a global workforce can                                                        the office, which calls into question             less secure connections than those
                                               ers the need to understand the spe-
be more easily leveraged to optimize                                                        the boundaries of what constitutes                managed by professional security
                                               cific personal circumstances of each
resourcing, and indeed hiring, beyond                                                       the company, when storing, accessing              staff. However, companies unused to
                                               member of staff to prevent psychoso-
the confines of a particular location                                                       or managing hard documents occurs                 massive remote working or unwilling
                                               cial risks.
(office, country or even continent).                                                        in a decentralized way. This concern              to accept the cost may not have suf-
This can be beneficial for both long-          Without the “convenient” commute to          also applies, in a slightly different way,        ficient technical capacity to support

                                          16                                                                                             17
systematic use of secure connections                            have remained also in times of remote                       across the workforce is a challenge              ing tools for upskilling, reskilling and
such as through Virtual Private Net-                            working, informal information flows                         as the sense of belonging may be im-             continuous learning, will be better po-
works (VPN).                                                    “at the coffee machine” have been sig-                      pacted while companies adjust to the             sitioned to retain their top talent and
                                                                nificantly reduced. Casually meeting                        new ways of working with less phys-              create future-ready leaders. Howev-
• Potential tax, labour law and other                           many people at the same time in the of-                     ical contact. Even recognizing that a            er, the benefits of digital learning need
regulatory risks – the virtual world                            fice, also spontaneously, seeing their                      company is more than just its walls,             to be distinguished from on-the-job
blurs borders and what may consti-                              faces and deciding ad hoc whether to                        successfully onboarding joiners in               learning, observing colleagues and
tute cross-border operations, sales                             talk to someone has disappeared in a                        a situation where they may not meet              leaders, and the onboarding of new
and working may result in new dimen-                            remote world. Participation in infor-                       their teammates in person for poten-             joiners as explored further below.
sions to various regulatory frame-                              mation flows happens on invitation,                         tially an extended period of time is dif-        In general, companies need strong
works designed when market and en-                              increasing the siloes between differ-                       ficult. The consequences on individual           training plans in a remote world, in
tity borders were more enforced.                                ent areas of the company and even                           development need to be considered,               order to consciously compensate the
                                                                people in different departments. The                        particularly for junior staff acquiring          above-mentioned effects.
• Control of employees in critical ar-
                                                                “3-minute elevator chat” has become                         professional experience. Less cohe-
eas – there are first observations that
                                                                rare. Those in the company who are                          sion and a weakened company culture              IMPACT ON PRODUCTIVITY
extensive remote working can pres-
                                                                already strong and well connected                           will adversely affect a company’s sus-
ent a significant risk for companies in                                                                                                                                      Some research highlights that remote
                                                                are becoming even stronger, others                          tainable development in many dimen-
areas where a defined level of control                                                                                                                                       working does not result in a reduc-
                                                                risk being left behind.                                     sions, e.g. as a consequence of less
is key, for instance regarding market                                                                                                                                        tion in productivity. Companies that
                                                                                                                            impactful informal information flows,
abuse in fund management activities6.                           Only time will show the impacts of                                                                           were already collaborating effectively
                                                                                                                            staff less willing to go the extra mile
                                                                these developments on the quality of                                                                         and working productively before the
                                                                                                                            and difficulties to retain talent.
                                                                decision making, when even leaders                                                                           pandemic have remained productive
                                                                might have a less complete view on                          The already existing trend towards so-           during lockdowns and other disrup-
Furthermore, the threat from criminal
                                                                the overall situation when taking their                     cial media driven digital interactions           tions. Stay-at-home orders freed-up
agents has increased during the pan-
                                                                decisions.                                                  puts companies in an environment                 time previously spent commuting and
demic as certain groups try to take
                                                                                                                            of faster changing teams when peo-               created flexibility in work schedules,
advantage of the slackened security
                                                                COMPANY CULTURE AND COHESION OF TEAMS                       ple group together according to their            enabling many employees to devote
enjoyed by employees, with an uptick
                                                                                                                            current topics of interests. In com-             additional time to their jobs.
in e.g. phishing attacks and attempts                           As an impact of remote working, pro-
to install malware via cyber-attacks.                                                                                       bination with the impact on company
                                                                fessional interaction is becoming more                                                                       On the other hand, a contributor to the
                                                                                                                            culture and the cohesion of “classical”
                                                                transaction-based, with a reduction in                                                                       increase in productivity is the tenden-
                                                                                                                            teams described above, this may re-
                                                                the relational part. In the short term                                                                       cy to overwork in a lockdown situa-
                                                                                                                            sult in the need to rethink corporate
IMPACTS OF REMOTE WORKING ON                                    this has increased productivity in                                                                           tion. In addition, productivity at home
                                                                                                                            organization in the medium and long
COMPANIES                                                       many areas, whereas in the medium                                                                            depends on the precise conditions
                                                                                                                            term.
                                                                and long term, neglecting relation-                                                                          there, which is outside the sphere of
INFORMATION FLOWS AND DECISION MAKING                           ships will take its toll. After almost                      LEARNING AND PROFESSIONAL DEVELOPMENT            influence of an employer. Whilst some
                                                                one year of extensive remote working                                                                         employees benefit from a fully-fledged
The shift to remote working has re-                             in place, many companies observe a                          The new ways of learning and de-                 home-office including a quiet and con-
inforced the already visible trend to                           drop in the engagement of their em-                         veloping professionally have moved               centrated atmosphere, others will find
shift part of a company’s informa-                              ployees. The risk of a decrease in em-                      trainings from the classroom to vir-             it difficult to concentrate when sitting
tion flows to virtual communities. In                           ployees’ identification with the compa-                     tual platforms. The Covid-19 outbreak            at the kitchen table, with their partner
some cases it is not yet clear how and                          ny and of their motivation in a remote                      has emphasized the potential of dig-             doing phone calls in another room and
whether they are managed and who                                or hybrid working environment needs                         ital learning due to the constraints             the children requesting the attention
should participate. Whilst the classi-                          to be well understood and managed7.                         imposed on social distancing, travel             they can rightfully expect.
cal information flows defined by the                                                                                        and events. Organisations investing
company’s hierarchical structures                               Creating and maintaining cohesion                           or planning to invest in digital learn-

6 Financial Times, February 15, 2021: “Homeworking              7 Il Sole 24 Ore: “Lo Smart Working sta riducendo la ca-
               sparks red flag alerts over market abuse”                                    pacità di creare innovazione”

                                                           18                                                                                                           19
Moreover, the productivity levels ob-                            independently of where people are
served so far also benefit from per-                             working from. An assessment of their
sonal relations established in the                               functioning then consists in a “me-
past. Therefore, it should be observed                           ta-control” verifying that the entire
attentively how productivity develops                            system of controls is working well,
over time, when an increasing num-                               which on the one hand can be done re-
ber of people is working together al-                            motely, on the other hand it adds value
though they have never met in person.                            to talk to the people having designed
There is certainly a risk of a decline in                        and maintaining it - not only remotely,
productivity in the medium and long                              but also in person.

                                                                                                           5
term, depending on the specific tasks,
the duration,    and the conditions of
remote working.
                                                                 An increased threat potential from
IMPACT ON CREATIVITY AND INNOVATION8                             cyberattacks of all types, and the now
                                                                 absolute reliance on IT infrastruc-
In a fast-changing environment, cre-                             ture, require a significant reinforce-
ativity and innovation are crucial for                           ment of the Internal Control System
companies to survive. Infrequent                                 in these areas. Here, as discussed
physical presence in the office reduc-                           above, remote working contributes
es the occasions to work together on                             to the necessity to reinforce controls
less formal and more creative activi-                            and increases the inherent risks re-
ties, i.e. those which create innovation,                        garding the lack of confidentiality and
in different business areas and on dif-                          cyber threats.
ferent topics. Video calls are often too
“cold”, too structured, too focused on
the content to be discussed and too
                                                                 Finally, how the impact of remote work-
little on relationships and emotions.
                                                                 ing with its reduction or absence of
Since these phenomena are difficult
                                                                 physical interaction on company cul-
to measure, at least at short notice,
                                                                 ture, learning, and professional devel-
there is a risk of taking them into con-
                                                                 opment affects internal controls still
sideration too late.
                                                                 needs to be assessed. It is likely that
                                                                 threats in these dimensions translate
                                                                 into weaknesses in the Internal Con-
IMPACT ON THE INTERNAL CONTROL                                   trol System and consequently need
SYSTEM                                                           to be mitigated. In particular, such
                                                                 threats will have a significant impact

                                                                                                               Remote
It is not easy to assess the compre-                             on control over non-standard or ad
hensive impact of remote working on                              hoc decisions, and potentially less on
the Internal Control System. The un-                             standardised, routine transactions.
derlying trend of digitalization moves
many standard controls into technical
                                                                 In general, a response to these en-
                                                                 hanced requirements on the Internal
                                                                                                               Auditing
systems, where the controls them-                                Control Systems can consist in rein-
selves can be checked automatically.                             forcing controls at the basics follow-
Such digital processes are working                               ing a “security by design” logic.

8 Il Sole 24 Ore: “Lo Smart Working sta riducendo la ca-
                            pacità di creare innovazione”

                                                            20
OPPORTUNITIES OF REMOTE WORK-                   suit of technical or soft skills. Since     ways be a need to talk to the opera-             processes and audit techniques, but
ING FOR INTERNAL AUDIT                          the world is not politically and demo-      tors developing or using the digital             also of the competencies to demon-
                                                graphically uniform, location will con-     tools, which in some cases can be                strate authority, credibility, and eth-
Sophisticated and widely available              tinue to be a significant differentiator    done remotely, in some cases not.                ical conduct which is essential for
digital tools are now a reality and en-         irrespectively of digital connections.      Care in testing is still needed to make          valuable internal audit activity. This is
able collaborative working in virtu-            Auditors need to be able to factor this     sure that complete and accurate data             not taught in a traditional classroom
al teams. Remote auditing can offer             into their audit plans and work.            is being provided from the source sys-           context but developed through ob-
valuable opportunities to Internal Au-                                                      tem(s).                                          serving others and working together
dit to manage costs more flexibly and                                                                                                        in person. Working in close contact
reduce its travel expenses and opti-                                                        UNDERSTANDING STAKEHOLDER NEEDS                  with experienced colleagues enables
mize how audit skills are deployed.             AUDIT NEEDS
                                                                                                                                             junior staff to learn the everyday be-
A better use of skills in the most ap-                                                      Internal Audit should always consider
                                                                                                                                             haviours which lead to successful
propriate ways and areas will lead to
                                                MAINTAINING AUDIT EFFECTIVENESS             the needs of its stakeholders, wheth-
                                                                                                                                             auditing. Such exposure is curtailed
a better coverage of the associated                                                         er external, boards and non-execu-
                                                The effectiveness of Internal Audit                                                          when working solely remotely since
risks by audit activities. Some audits,                                                     tive management, or executive man-
                                                and the need to maintain the quality                                                         all interactions are planned to some
and some parts of audits (such as da-                                                       agement. It should be considered
                                                of its work and to unearth root caus-                                                        extent; there is a limited opportunity
ta-intensive analysis) can be managed                                                       whether these needs are changing or
                                                es is a prerequisite of all further con-                                                     to truly shadow someone or observe
without the need for extended physical                                                      have evolved during or further to the
                                                siderations. Since companies change                                                          firsthand working practices.
interaction with auditees. If these au-                                                     Covid-19 pandemic, as well as and the
                                                at a quick pace, also Internal Audit
dit activities are adequately identified                                                    resulting changes to business opera-
                                                needs to adapt to make sure that its
and planned, they can offer increased                                                       tions and audit work.
                                                approach and techniques remain
value-for-investment when being less                                                                                                         THE LIMITS OF REMOTE WORKING
                                                relevant to produce outcomes in line        DIVERSIFYING SKILLS IN THE AUDIT FUNCTION
bound by the time constraints of tradi-                                                                                                      FOR AUDITORS
                                                with audit objectives. On the one hand      AND DATA-DRIVEN ASSURANCE
tional onsite auditing.                         this means catching the opportunities                                                        GENERAL LIMITATIONS: RELATIONSHIPS, SPON-
                                                in times of change, on the other hand       In an increasingly digital world, Inter-         TANEITY AND CONFIDENTIALITY
Sustained remote work, with the re-                                                         nal Audit needs to diversify its skills,
                                                recognizing existing limits so that they
duction in commuting and travel times                                                       hiring IT auditors, data scientists and          Working through the pandemic has
                                                can be taken into consideration and
to distant locations, can also repre-                                                       those coming from related profes-                demonstrated that a switch to full re-
                                                their impact minimized. Particularly
sent a significant saving of time, po-                                                      sions. A corresponding shift to da-              mote auditing is manageable in the
                                                in a situation where spontaneous ac-
tentially translating into increased ef-                                                    ta-driven assurance is not the core              short term. However, it relied to an ex-
                                                cess to people and information is lim-
ficiency and productivity as explored                                                       topic of this document but treated in            tent on staff already having built rela-
                                                ited, there is a high risk of not being
above. This needs to be balanced with                                                       a different forthcoming ECIIA paper.             tionships and already having a certain
                                                fully aware of what is happening in the
the more difficult and potentially re-                                                      This trend is less influenced by remote          amount of knowledge, carried along
                                                company and hence missing changes
duced access to information when                                                            working and hence is more robustly               by momentum. As the initial reference
                                                in its risk profile.
working mainly remotely.                                                                    aligned to different working models.             point recedes further into the past,
                                                CHECKING THE INTEGRITY OF INFORMATION                                                        the continuing ability of audit teams to
When the workforce is primarily loca-                                                       LEARNING ON THE JOB                              sustain effective auditing in the face of
tion-independent and works in a sig-            The need to check the integrity of in-                                                       staff turnover in business areas and
nificantly remote environment, com-             formation is not new, but it continues      More than other professions, due to
                                                                                                                                             in audit teams should be regularly ex-
munication structures and channels              to be relevant despite the shifts to dig-   reliance on professional judgement,
                                                                                                                                             amined. New ways of managing dura-
can evolve. However, knowledge of               italization and working from home. A        Internal Audit leverages on on-the-job
                                                                                                                                             ble knowledge and information flows
local operating environments (mar-              majority of business processes being        learning as a primary lever for indi-
                                                                                                                                             will need to be developed.
ket, customs, competition, language,            managed digitally does not mean that        vidual development, particularly for
specific regulatory requirements and            a computer is the only tool needed to       those just starting out. This is because
expectations) should not be underes-            audit those processes. There will al-       becoming a good auditor requires
timated and balanced against the pur-                                                       not only deep knowledge of business

                                           22                                                                                           23
RAPPORT, INTERACTION AND ACCESS TO INFOR-        talking over each other. More gener-        heavily reliant on paper documents               IMPACT ON THE ADVISORY ROLE OF AUDIT
MATION NOT SPECIFICALLY SOUGHT
                                                 ally, all meetings needed for assess-       and other manual activities can only
                                                 ing and understanding the auditable         be transferred to home office to a very          Since extensive remote working is in-
Conducting audits relying solely on                                                                                                           creasing the siloes, making personal
digital contact can limit audit effec-           scope (particularly in considering new      limited extent, often with significant
                                                 or emerging risks and avoiding “blind       losses of efficiency. Moreover, the              relationships and informal informa-
tiveness, despite the improvements                                                                                                            tion flows more difficult and present-
in video calling technologies which              spots” through missed interactions          move can have been made in emergen-
                                                 with senior business management)            cy circumstances potentially disrupt-            ing new challenges to stakeholder
continue to receive regular updates                                                                                                           management, also the Advisory Role
and enhancements to features. It is              are more effective in person.               ing the effectiveness of the process
                                                                                             (for example where certain steps re-             of internal audit can be negatively im-
more difficult to read body language,                                                                                                         pacted.
                                                 Moreover, where the vast majority of        liant on access to documents that are
establish tone, and build rapport and
                                                 communications across the compa-            no longer easily available are missed).
relationships with auditees and the
                                                 ny are managed through electronic           The same is true for any associated
business at large. It is also harder to
                                                 means, the fact that it is possible that    controls: matching paper documents
derive insights that normally result
                                                 any or all might be retained on record      is a logistical challenge where docu-
from in-person walkthroughs. A ben-
                                                 may result in more guarded discus-          ments can no longer be accessed or
efit of face-to-face interactions is that
                                                 sions, less spontaneity and important       are dispersed throughout the homes
they naturally create more opportu-
                                                 bits of information untold. Taken in        of various members of staff. For such
nities to spend time developing a re-
                                                 combination, this can further impair        processes and controls, the impact
lationship beyond the immediate en-
                                                 auditors in building rapport and run-       on the ability of Internal Audit to ef-
gagement, which is important in being
                                                 ning effective interviews.                  fectively undertake a review is severe
a trusted partner to the business. This
is because auditors are more likely to           LIMITATIONS OF TECHNOLOGY
                                                                                             and this follows through to corporate
spend time on non-work-related con-                                                          governance and the liabilities of se-
versation at the start or close of face-         Depending on the location of the au-        nior management.
to-face meetings, whereas “getting               ditee and technology used, one of the
                                                                                             IMPACT ON JUDGEMENT AND AUDITABLE AREAS
straight down to business” is more               main challenges organizations can
likely with electronic interactions, as          run into is logistics. The reliability of   Overall, the elements auditors rely on
is asking fewer questions. Moreover,             network connections may vary by             to exercise their professional judge-
face-to-face interactions tend to pro-           location, which can cause interrup-         ment are limited when parties work
duce more dialogue and a richer dis-             tions in interviews and other meet-         entirely remotely. The extent of the
cussion, particularly where the par-             ings. Technology challenges can also        limitation will depend on the specifics
ticipants do not know each other well            impede document sharing, for exam-          of the company and the scope of busi-
as is often the case during audits.              ple if auditees have difficulty access-     ness activities.
                                                 ing the VPN to show evidence. Solving
Fluid dialogue, during audits and out-           network and application issues can          Specific examples of audit activities
side audits, is a key requirement for            be time-consuming and frustrating,          that may be limited when conducted
auditors to exercise reasonable judge-           especially when employees are work-         remotely are walkthrough test (you
ment. Over-reliance on data without              ing from home. Technical issues will        only see what you are shown), audit-
contextual interaction is inherently             hence result in a loss of productivity,     ing certain activities (e.g. real estate,
limited as the data represents what              and in worse cases a decrease in reli-      facilities management, secure areas
the company already “knows”. Some                ability of information and therefore in     such as call centres or trading floors)
meetings with the business which                 the quality of assurance given by in-       or on new/unclear processes or in-
are more easily managed in physical              ternal audit.                               volving counterparts with a complex
proximity, such as delicate audit clos-                                                      relationship.
ing meetings where body language                 In cases where a company has a low
is key, and video can result in people           degree of automation, process steps

                                            24                                                                                           25
BEYOND THE IMMEDIATE, FRAMEWORKS SHOULD        Although in times of acute crisis, In-
                 NOT FUNDAMENTALLY CHANGE                       ternal Auditors should be permitted
                                                                to support the business on critical ac-
                 Despite the changes introduced in              tivities, once normality (which may be
                 reaction to the Covid-19 pandemic,             different from the preceding normali-
                 in most cases Internal Audit’s activ-          ty) resumes, this should be limited. In-
                 ities have resettled. The framework            dependence from operations is a key
                 around reporting indicators (e.g. plan         tenet of Internal Audit which enables
                 progress, business responsiveness              objectivity and needs to be preserved;
                 to audits and remediation of issues)           any activity which could create a con-
                 should not fundamentally change in a

6
                                                                flict of interest should be carefully
                 remote working environment. That is,           managed and the pandemic does not
                 although for example the target dates          change this requirement.
                 on certain issues may be legitimately
                 changed in order to take into account          Internal Audit’s organizational chart
                 the crisis or the new emerging prior-          generally reflects business opera-
                 ities, the way those changes are han-          tions or is at least reactive to how
                 dled should be treated and reported in         business operations evolve. As a re-
                 the normal manner with the legitima-           sult, structural impacts of the chang-
                 cy validated case-by-case rather than          es the business is going through with
                 applied by default.                            its own handling of remote working
                                                                and increases in automation may be
                 Audit plans should continue to be              greater in the long term.
                 flexed to account for changing circum-
                 stances such that it is demonstrably
                 always “the right plan”. The degree of
                 that flexing may increase during times         BUILDING ON THE RIGHT MIX OF PHYSICAL AND

                 of acute change or stress such as              REMOTE WORKING

                 those introduced as the effects of the
                                                                Internal Audit should maximize the
                 Covid-19 pandemic and related public
                                                                opportunities of remote working, but
                 health policy changes come into force.
                                                                at the same time manage its limits,
                 Nonetheless, it remains important
                                                                balancing the remote and the onsite
                 to set and monitor a plan of work to
                                                                work in order to maintain audit effec-
                 provide a baseline that can be under-
                                                                tiveness. Auditors should make the
                 stood and challenged, and to which
                                                                most of digital tools. As remote work-
                 Internal Audit can be held account-
                                                                ing can result in the loss of occasions
                 able for its coverage, production and
                                                                for small talk or quick checks, digital
                 decisions. These decisions may result

     Future of
                                                                tools offer a way of “chatting” which
                 in enhanced focus on particular ar-
                                                                can be particularly useful as senior
                 eas of the business and less attention
                                                                members of staff become used to be-

    Audit Work
                 on others; the impact of such shifts
                                                                ing contacted in this way as it involves
                 needs to be transparent and justified
                                                                less formality than booking a meeting
                 such as to be approved by the compe-
                                                                and preparing an agenda. However, if
                 tent corporate bodies.
                                                                possible, in order to prevent impover-
                                                                ishing the relationship with the busi-

                                                           27
ness, the main meetings with the busi-
ness should be managed in person,
where possible, to maintain the op-
portunity for less formal interaction.

Using agile techniques, that have
proven beneficial when teams are
physically together, can compensate
the limitations of fully remote work
and are compatible with virtual col-
laboration. The increased stakehold-
er engagement and communications
(both within and outside Internal Au-
dit) should enable teams to make the
most of the flexibilities and opportuni-
ties represented by remote work, par-
ticularly as companies in general are
adapting to remote work at the same
time as Internal Audit does. It also
means that both audit teams and busi-
ness stakeholders are better able to
manage their time flexibly focusing on
the areas of the audit with most value.

Where remote auditing is the chosen
approach for an assignment, the au-
dit team should consider making sure
that existing data analytics are antic-
ipated so they can complement the
remote interviews and identify areas
of particular focus during scoping ac-
tivities. The right investment of effort
needs to be considered so that data
can be effectively sourced and ana-
lyzed in time to contribute to the audit
work supporting the conclusions.

                                           28
CONCLUSIONS

                 It is not easy to predict to which de-
                 gree remote working will become per-
                 manent, either generally or, in partic-
                 ular, for Internal Audit. It is likely that
                 a balanced (“hybrid”) model between
                 physical and remote working, possibly
                 with greater geographic dispersion,
                 will prevail in the near future, as com-
                 panies are beginning to understand

7
                 the benefits and limits the new work-
                 ing models.

                 Internal Audit will consequently adapt
                 its way of working to best suit the mod-
                 el deployed by management. Internal
                 Audit should not be pre-empting such
                 changes, instead being sufficient-
                 ly flexible to accommodate chang-
                 ing circumstances, while remaining
                 closely associated with stakeholders.
                 Precise and timely information is key
                 for auditors, especially for punctual
                 high-quality risk assessments, an ap-
                 proach of prevention and the advisory
                 role. In-person interactions are and
                 will continue to be a key part of audit
                 work and of building fruitful relation-
                 ships, both needed to provide effective
                 assurance and add value.

    Conclusion

                                                               31
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