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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