Transparency Report 2018 - EY Nigeria - Transparency Report 2019

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Transparency Report 2018 - EY Nigeria - Transparency Report 2019
Transparency
Report 2018
EY Nigeria
Transparency Report 2018 - EY Nigeria - Transparency Report 2019
Contents

          Message from the Country Managing Partner and the EY Nigeria Assurance Leader................3

          About us..............................................................................................................................4
          •   Legal structure, ownership and governance........................................................................4
          •   Network arrangements......................................................................................................5

          Commitment to quality.........................................................................................................7
          •   Infrastructure supporting quality........................................................................................7
          •   Instilled professional values...............................................................................................8
          •   Internal quality control system...........................................................................................9
          •   Client acceptance and continuance...................................................................................10
          •   Performance of audits.....................................................................................................11
          •   Review and consultation..................................................................................................12
          •   Audit partner rotation.....................................................................................................13
          •   Audit quality reviews.......................................................................................................13
          •   External quality assurance review.....................................................................................14
          •   Compliance with legal requirements.................................................................................14

          Independence practices......................................................................................................16

          Continuing education of audit professionals.........................................................................18

          Revenue and remuneration.................................................................................................19
          •   Financial information......................................................................................................19
          •   Partner remuneration......................................................................................................19

          Appendix 1.........................................................................................................................21

          Appendix 2.........................................................................................................................22

More information about EY can be found at ey.com.
Transparency Report 2018 - EY Nigeria - Transparency Report 2019
Message from the Country Managing Partner and
the EY Nigeria Assurance Leader

 Henry Egbiki                        Jamiu Olakisan
 Managing Partner | EY Nigeria       Assurance Leader   | EY Nigeria

Welcome to the 2018 Transparency Report of Ernst & Young (EY Nigeria). We believe that how we advance audit quality,
manage risk and maintain our independence as auditors should be transparent to our stakeholders. We value regular
dialogue, and this report is one of the ways in which we advise our stakeholders on what we are doing in each of these
areas.
Executing high-quality audits continues to be our top priority and is at the heart of our commitment to serve the public
interest. It enables us to grow the global EY network successfully and responsibly, while achieving our purpose of building
a better working world. Auditors play a vital role in the functioning of capital markets by promoting transparency and
supporting investor confidence. Companies, regulators and other stakeholders count on us to deliver excellence in every
engagement.
We are focused on investing in tools to improve what we do, creating the highest-performing teams, and building trust and
confidence in the audits we perform.
EY Nigeria’s reputation is based on and grounded in providing high-quality professional audit services objectively and
ethically to every company we audit.
We continue to embrace the transparency objectives of the European Union’s 8th Company Law Directive, which requires
Nigeria statutory auditors of public interest entities (PIEs) to publish annual transparency reports.
The 2018 EY Nigeria Transparency Report complies with the Directive and covers the financial year ended 30 June 2018.
In this report, you can learn more about our internal quality control system: how we instill professional values, how we
perform an audit, our review and consultation processes, our approach to audit quality reviews, and our independence
practices.
EY Nigeria is focused on enhancing audit quality and upholding our independence, informed by several matters including
external and internal inspection results. Continuous improvement of audit quality requires us to challenge approaches to
audit execution, and we focus on this by evaluating all inspection findings and taking responsive actions.
We encourage all our stakeholders — including our clients and their investors, audit committee members and regulators — to
continue to engage with us on our strategy as well as any of the matters covered in this report.

Henry Egbiki                                                                                        Jamiu Olakisan
Managing Partner                                                                                    Assurance Leader
EY Nigeria                                                                                          EY Nigeria

EY’s purpose: building a better working world
EY is committed to doing its part in building a better
working world.
The insights and quality services we deliver help build trust and confidence
in the capital markets and in economies the world over. We develop
outstanding leaders who team to deliver on our promises to stakeholders.
In so doing, we play a critical role in building a better working world for our
people, our clients and our communities.
Transparency Report 2018 - EY Nigeria - Transparency Report 2019
About us
Legal structure, ownership and governance

Ernst & Young is a Partnership            The Areas comprise a number of          elected as Presiding Partner of the
organized in Nigeria and is a member      Regions, which consist of member        RPF also serves as the Region’s
firm of Ernst & Young Global Limited,     firms or sections of those firms.       representative on the Global
a UK company limited by guarantee                                                 Governance Council (see page 5).
                                          EY Nigeria is part of the EMEIA Area,
(EYG). In this report, we refer to        which comprises EYG member firms
ourselves as “EY Nigeria,” “we,” “us”     in 98 countries in Europe, the Middle
or “our.” EY refers collectively to the   East, India and Africa. Within the
global organization of the member         EMEIA Area, there were 11 Regions,
firms of EYG.                             and from 1 July 2018 the number has
EY Nigeria is governed by an              reduced to 10. EY Nigeria is part of
executive committee of partners           the Africa Region (West cluster).
headed by the Managing Partner,           Ernst & Young (EMEIA) Limited
Henry Egbiki. He is supported by the      (“EMEIA Limited”), an English
other four service line leaders and the   company limited by guarantee, is
COO who together provide leadership       the principal coordinating entity for
to the four business lines: Advisory,     the EYG member firms in the EMEIA
Assurance, Transaction Advisory and       Area. EMEIA Limited facilitates the
Tax Services.                             coordination of these firms and
The firm has its head office in Lagos     cooperation between them, but it
and other offices in Abuja and Port       does not control them. EMEIA Limited
Harcourt. EY Nigeria has 24 partners,     is a member firm of EYG, has no
15 directors (Executive and associate)    financial operations and does not
and over 400 professional staff.          provide any professional services.
EYG member firms are grouped into         Each Region elects a Regional Partner
four geographic Areas: Americas;          Forum (RPF), whose representatives
Asia-Pacific; Europe, Middle East,        advise and act as a sounding board
India and Africa (EMEIA); and Japan.      to Regional leadership. The partner

Transparency Report 2018: EY Nigeria                                                                                    4
Transparency Report 2018 - EY Nigeria - Transparency Report 2019
Network arrangements (1/2)
EY is a global leader in assurance, tax,   among them. EYG does not provide         operates on a Regional level within
transaction and advisory services.         services, but its objectives include     the Areas. This operating model
Worldwide, over 250,000 people             the promotion of exceptional high-       allows for greater stakeholder focus
in member firms in more than 150           quality client service by member firms   in the 27 Regions, permitting member
countries share a commitment to            worldwide.                               firms to build stronger relationships
building a better working world,                                                    with clients and others in each
                                           Each member firm is a legally
united by shared values and an                                                      country, and be more responsive to
                                           distinct entity. Their obligations and
unwavering commitment to quality,                                                   local needs.
                                           responsibilities as members of EYG
integrity and professional skepticism.
                                           are governed by the regulations of       Global Governance Council
In today’s global market, the
                                           EYG and various other agreements.
integrated EY approach is particularly                                              The Global Governance Council
important in the delivery of high-         The structure and principal bodies       (GGC) is the main oversight body
quality multinational audits, which        of the global organization during        of EYG. It comprises one or more
can span nearly every country in the       the year ended 30 June 2018              representatives from each Region,
world.                                     are described below. They reflect        other member firm partners as
                                           the principle that EY, as a global       at-large representatives and up to
This integrated approach enables
                                           organization, has a common shared        six independent non-executives
EY member firms to develop and
                                           strategy.                                (INEs). The Regional representatives,
draw upon the range and depth of
                                                                                    who otherwise do not hold senior
experience required to perform such        The Executive includes the Global
                                                                                    management roles, are elected by
diverse and complex audits.                Executive (GE), its committees and
                                                                                    their RPFs for a three-year term,
                                           teams, and the leadership of the four
EYG coordinates the member                                                          with provision for one successive
                                           Areas. At the same time, the network
firms and promotes cooperation                                                      reappointment. The GGC advises

Transparency Report 2018: EY Nigeria                                                                                        5
Transparency Report 2018 - EY Nigeria - Transparency Report 2019
Network arrangements                                                         (2/2)
EYG on policies, strategies and the        GE also approves appointments of             This group brings together the
public interest aspects of its decision—   Global Vice Chairs. The GGC ratifies         members of the GE, GE committees,
making. The approval of the GGC is         the appointments of any Global Vice          Regional leaders and sector leaders.
required for a number of significant       Chair who serves as a member of the          The Global Practice Group seeks to
matters that could affect EY.              GE.                                          promote a common understanding
                                                                                        of EY’s strategic objectives and helps
Independent Non-Executives                 The GE’s responsibilities include the
                                                                                        drive consistency of execution across
                                           promotion of global objectives and the
Up to six Independent Non-Executives                                                    the organization.
                                           development, approval, and, where
(INEs) are appointed from outside
                                           relevant, implementation of:                 EYG member firms
EY. The INEs are senior leaders from
both the public and private sectors,       •   Global strategies and plans              Under the regulations of EYG,
and reflect diverse geographic and                                                      member firms commit themselves
                                           •   Common standards, methodologies
professional backgrounds. They                                                          to pursue EY’s objectives, such as
                                               and policies to be promoted within
bring to the global organization, and                                                   the provision of high-quality service
                                               member firms
the GGC, the significant benefit of                                                     worldwide. To that end, the member
their varied perspectives and depth        •   People initiatives, including criteria   firms undertake the implementation
of knowledge. The INEs also form               and processes for admission,             of global strategies and plans, and
a majority of the Public Interest              evaluation, development, reward          work to maintain the prescribed scope
Sub-Committee of the GGC, which                and retirement of partners               of service capability. They are required
addresses public interest matters,                                                      to comply with common standards,
                                           •   Quality improvement and protection
including public interest aspects                                                       methodologies and policies, including
                                               programs
of decision-making, issues raised                                                       those regarding audit methodology,
under whistleblowing policies              •   Proposals regarding regulatory           quality and risk management,
and procedures, perspectives on                matters and public policy                independence, knowledge sharing,
stakeholder views and engagement                                                        human resources, and technology.
                                           •   Policies and guidance relating
in quality and risk management
                                               to member firms’ service of              Above all, EYG member firms
discussions. The INEs are nominated
                                               international clients, business          commit to conducting their
by a dedicated committee.
                                               development, markets and                 professional practices in accordance
Global Executive                               branding                                 with applicable professional and
                                                                                        ethical standards, and all applicable
The Global Executive (GE) brings           •   EY’s development funds and
                                                                                        requirements of law. This commitment
together EY’s leadership functions,            investment priorities
                                                                                        to integrity and doing the right thing
services and geographies. It is chaired
                                           •   EYG’s annual financial reports and       is underpinned by the EY Global Code
by the Chairman and CEO of EYG, and
                                               budgets                                  of Conduct and EY values (see page
includes its Global Managing Partners
                                           •   GGC recommendations                      9).
of Client Service and Business
Enablement; the Area Managing              The GE also has the power to mediate         Besides adopting the regulations
Partners; the global functional            and adjudicate disputes between              of EYG, member firms enter into
leadership for Talent and Finance;         member firms.                                several other agreements covering
the leaders of the global service                                                       aspects of their membership in the EY
lines — Assurance, Advisory, Tax and       GE committees                                organization, such as the right and
Transaction Advisory Services; the         Established by the GE and bringing           obligation to use the EY name, and
Global Leader for Public Policy; and       together representatives from the            the sharing of knowledge.
one EYG member firm partner on             four Areas, the GE committees                Member firms are subject to reviews
rotation.                                  are responsible for making                   that evaluate their adherence to EYG
The GE also includes the Chair of          recommendations to the GE.                   requirements and policies governing
the Global Accounts Committee and          In addition to the Global Audit              issues such as independence,
the Chair of the Emerging Markets          Committee, there are committees              quality and risk management, audit
Committee, as well as a representative     for Global Markets and Investments,          methodology, and human resources.
from the Emerging Markets practices.       Global Accounts, Emerging Markets,           Member firms unable to meet the
                                           Talent, Risk Management, Assurance,          quality commitments and other EYG
The GE and the GGC approve                 Advisory, Tax, and Transaction               membership requirements may be
nominations for the Chairman and           Advisory Services.                           subject to separation from the EY
CEO of EYG, and ratify appointments
                                           Global Practice Group                        organization.
of the Global Managing Partners. The

Transparency Report 2018: EY Nigeria                                                                                               6
Transparency Report 2018 - EY Nigeria - Transparency Report 2019
Commitment to quality                                                    (1/9)
Infrastructure supporting quality

Quality in our service lines             Leader. This helps provide greater       •   Event-specific issues involving
                                         assurance as to the objectivity              areas of civil and political unrest;
Vision 2020+, which sets out EY’s
                                         of audit quality and consultation            or sovereign debt and related
purpose, ambition and strategy, calls
                                         processes.                                   accounting, auditing, reporting and
for EYG member firms to provide
                                                                                      disclosure implications
exceptional client service worldwide.    The Global PPD also leads and
This is supported by an unwavering       oversees the Global Professional         •   General engagement issues and
commitment to quality and service        Practice group. This is a global             how to work effectively with audit
that is professionally and globally      network of technical subject matter          committees
consistent, and means service that       specialists in accounting and auditing   Risk management
is based on objectivity, professional    standards, who consult on accounting,
skepticism, and adherence to EY and      auditing and financial reporting         Responsibility for high-quality
professional standards.                  matters, and perform various practice    service and ownership of the risks
                                         monitoring and risk management           associated with quality is placed with
EYG member firms and their service
                                         activities.                              the member firms and their service
lines are accountable for delivering                                              lines. Among other things, the Global
quality engagements. EY service lines    The Global PPD oversees development      Risk Management Leader helps
manage the overall process for quality   of the EY Global Audit Methodology       oversee the management of these
reviews of completed engagements         (EY GAM) and related technologies        risks by the member firms, as well as
and input for the quality of in-         so that they are consistent with         other risks across the organization as
process engagements, which helps         relevant professional standards and      part of the broader Enterprise Risk
achieve compliance with professional     regulatory requirements. The Global      Management framework.
standards and EY policies.               Professional Practice group also
                                         oversees the development of the          Member firm partners are appointed
Vision 2020+ has reinforced
                                         guidance, training and monitoring        to lead risk management initiatives
the ownership of quality by the
                                         programs and processes used by           in both the service lines and member
service lines, including audit. It has
                                         member firm professionals to execute     firms, supported by other staff
also resulted in increased clarity
                                         audits consistently and effectively.     and professionals. The Global Risk
around the role of risk management
                                         The Global, Area and Region PPDs,        Management Leader is responsible
in policies and practices that support
                                         together with other professionals who    for establishing globally consistent
and improve audit quality.
                                         work with them in each member firm,      risk management execution
The Global Vice Chair of Assurance       are knowledgeable about EY people,       priorities and enterprise—wide risk
coordinates member firms’                clients and processes, and they are      management. These priorities
compliance with EY policies and          readily accessible for consultation      cascade to member firms, and their
procedures for assurance services.       with audit engagement teams.             execution is monitored through
                                                                                  an Enterprise Risk Management
Professional Practice                    Additional resources often augment       program.
The Global Vice Chair of Professional    the Global Professional Practice
Practice, referred to as the Global      group, including networks of
Professional Practice Director (PPD),    professionals focused on:
is overseen by the Global Vice Chair     •   Internal—control reporting and
of Assurance and works to establish          related aspects of the EY audit
global audit quality control policies        methodology
and procedures. Each of the Area
PPDs is overseen by the Global PPD       •   Accounting, auditing and risk
                                             issues for specific industries and
and the related Area Assurance
                                             sectors

Transparency Report 2018: EY Nigeria                                                                                         7
Commitment to quality                                                     (2/9)

Global confidentiality policy             Global Code of Conduct and their           Each member firm that makes up
                                          commitment to abide by them and            our global structure is committed
Protecting confidential information
                                          to participate in an annual security       to providing high-quality audits.
is ingrained in the everyday activities
                                          awareness learning activity. There are     In 2015, we launched the SAQ
of EYG member firms. Respect for
                                          various policies outlining the due care    initiative throughout our Assurance
intellectual capital and all other
                                          that must be taken with technology         practices. SAQ establishes a
sensitive and restricted information
                                          and data, including but not limited        governance structure and is focused
is required by the EY Global Code of
                                          to the Global Information Security         on continuously improving our audit
Conduct, which provides a clear set
                                          Policy, and a global policy around the     process.
of principles to guide the behaviors
                                          Acceptable Use of Technology. EY
expected of all EY people. The                                                       We use the word “sustainable” in
                                          cybersecurity policies and processes
Global Confidentiality Policy further                                                SAQ to demonstrate that this is not a
                                          recognize the importance of timely
details this approach to protecting                                                  one-off, short-term initiative, but an
                                          communication. EY people receive
information and reflects the ever-                                                   ongoing process of improvement. EY
                                          regular and periodic communications
increasing use of restricted data. This                                              has had a common audit methodology
                                          reminding them of their
policy provides added clarity for EY                                                 for some time; now we have a
                                          responsibilities around these policies
people and forms the fundamental                                                     common language and processes
                                          and general security awareness
element of broader guidance that                                                     regarding audit quality.
                                          practice.
includes key policies on conflicts of                                                There are six components to SAQ:
interest, personal data privacy and       Components of the audit quality            tone at the top, strengthening
records retention. Other guidance         control program                            people capabilities, simplification,
includes:                                 In the following sections, we describe     audit technology and digital,
•   Social media guidance                 the principal components of the audit      enablement and quality support, and
                                          quality control program, which EY          accountability. SAQ is implemented by
•   Information—handling requirements
                                          Nigeria follows:                           each member firm, and is coordinated
•   Knowledge—sharing protocols                                                      and overseen globally.
                                          •   Instilled professional values
Cybersecurity                                                                        Audit quality and the key elements
                                          •   Internal quality control system
Managing the risk of major and                                                       of SAQ are something every senior
complex cybersecurity attacks is          •   Client acceptance and continuance      manager, manager and team member
a part of doing business for all          •   Performance of audits                  must understand and be committed to
organizations. While no systems                                                      implementing locally. SAQ is essential
                                          •   Review and consultation                to all our goals and ambitions, and
are immune from the threat of
cyber—attacks, EY Nigeria is vigilant     •   Audit partner rotation                 each of the Regional and Area leaders
                                                                                     is held accountable for those goals.
in the steps taken to secure the          •   Audit quality reviews
environment of EYG member firms                                                      We have made significant progress
and to protect their clients’ data.       •   External quality—assurance reviews
                                                                                     through SAQ. EY’s internal and
The EY approach to cybersecurity          •   Compliance with legal requirements     external inspection findings globally
is proactive and includes the                                                        are showing improvement, and we
implementation of technologies and        Instilled professional values              are producing greater consistency
processes necessary to manage and         Sustainable Audit Quality                  in execution. We have deployed
minimize cybersecurity risks globally.                                               world—class tools that enhance the
EY information security and data          Quality is the foundation for
                                                                                     quality and value of our audits. Our
privacy programs, consistent with         exceptional client service. It is what
                                                                                     ability to deliver consistency is based
industry practices and applicable legal   we pride ourselves on. It is integral
                                                                                     in part on the use of EY Canvas,
requirements, are designed to protect     to our work and central to our
                                                                                     our online audit platform. It better
against unauthorized disclosure of        responsibility to provide confidence
                                                                                     supports audit execution, streamlines
data. There is a dedicated team of        to the capital markets. Delivering
                                                                                     communications and enables us to
internal and external cybersecurity       quality is at the heart of all we do and
                                                                                     provide a seamless audit.
specialists who actively monitor and      supports our purpose of building a
defend EY systems.                        better working world for our people,
                                          our clients and our communities. This
Beyond technical and process              is reflected in the Sustainable Audit
controls, all EY people are required to   Quality (SAQ) program, which is the
affirm in writing their understanding     highest priority for our Assurance
of the principles contained in the EY     practices.

Transparency Report 2018: EY Nigeria                                                                                           8
Commitment to quality                                                       (3/9)
We recently launched the EY Canvas          The EY culture strongly supports          When a report comes into the EY
Client Portal, which adds to the            collaboration and places special          Ethics Hotline, either by phone or
leading—edge tools already offered          emphasis on the importance                internet, it receives prompt attention.
to our auditors. In addition, we have       of consultation in dealing with           Depending on the content of the
deployed the 2018 Audit Milestones          complex or subjective accounting,         report, appropriate individuals from
Program globally, which establishes         auditing, reporting, regulatory and       Risk Management, Talent, Legal
the use of Milestones on selected           independence matters. We believe          or other functions are involved
PIE audits as one important step            it is important to determine that         to address the report. The same
to improving results and sustaining         engagement teams and clients              procedures are followed for matters
quality across engagements.                 correctly follow consultation advice,     that are reported outside of the EY
                                            and we emphasize this when                Ethics Hotline.
There is also a network of Quality
                                            necessary.
Enablement Leaders (QELs) across                                                      Our values: who we are
the practice and an overall Global              The consistent stance of EY Nigeria   People who demonstrate integrity,
Audit Quality Committee.                        has been that no client is more       respect and teaming
They help us in executing and                   important than our professional       People with energy, enthusiasm and
reviewing root-cause analysis and               reputation -the reputation of EY      the courage to lead
understanding the impact our                    Nigeria and reputation of each of
                                                                                      People who build relationship based
initiatives are having in driving quality       our professionals
                                                                                      on doing the right thing
outcomes, better behaviours and a
continuous improvement mindset.             Code of Conduct                           Internal quality control system
This infrastructure demonstrates            We promote a culture of integrity         Structure
that audit quality is the single most       among our professionals. The EY
important factor in our decision—           Global Code of Conduct provides a         EY Nigeria’s reputation for providing
making and the key measure on which         clear set of principles that guide our    high-quality professional audit
our professional reputation stands.         actions and our business conduct, and     services independently, objectively
                                            are to be followed by all EY personnel.   and ethically is fundamental to our
Tone at the top
                                            The EY Global Code of Conduct is          success as independent auditors.
EY Nigeria leadership is responsible        divided into five categories:             We continue to invest in initiatives
for setting the right tone at the top                                                 to promote enhanced objectivity,
and demonstrating EY’s commitment           •    Working with one another             independence and professional
to building a better working world          •    Working with clients and others      skepticism. These are fundamental
through behavior and actions. While                                                   attributes of a high-quality audit.
the tone at the top is vital, our
                                            •    Acting with professional integrity
                                                                                      At EY Nigeria, our role as auditors
people also understand that quality         •    Maintaining our objectivity and
                                                                                      is to provide assurance on the
and professional responsibility                  independence
                                                                                      fair presentation of the financial
start with them. Our shared values,         •    Respecting intellectual capital      statements of the companies we
which inspire our people and guide
                                            Through our procedures to monitor         audit. We bring together qualified
them to do the right thing, and our
                                            compliance with the EY Global Code        teams to provide our services,
commitment to quality are embedded
                                            of Conduct, and through frequent          drawing on our broad experience
in who we are and in everything
                                            communications, we strive to create       across industry sectors and services.
we do.
                                            an environment that encourages all        We continually strive to improve
The EY approach to business ethics          personnel to act responsibly, including   our quality and risk management
and integrity is contained in the           reporting misconduct without fear of      processes so that the quality of our
EY Global Code of Conduct and               retaliation.                              service is at a consistently high level.
other policies, and is embedded
                                            The EY Ethics Hotline provides our        We recognize that in today’s
in the EY culture of consultation,
                                            people, clients and others outside        environment — characterized by
training programs and internal
                                            of the organization with a means to       continuing globalization and the rapid
communications. Senior management
                                            confidentially report activity that       movement of capital and the impact
regularly reinforces the importance of
                                            may involve unethical or improper         of technology changes — the quality
performing quality work, complying
                                            behavior and that may be in violation     of our audit services has never been
with professional standards, adhering
                                            of professional standards or otherwise    more important. As part of EY Vision
to our policies, leading by example
                                            inconsistent with the EY Global Code      2020+, we continue to invest heavily
and through various communications.
                                            of Conduct. The hotline is operated       in developing and maintaining our
Also, EY’s quality review programs
                                            by an external organization that          audit methodology, tools and other
assess professional service as a key
                                            provides confidential and, if desired,    resources needed to support quality
metric in evaluating and rewarding all
                                            anonymous hotline reporting services      service.
professionals.
                                            worldwide.

Transparency Report 2018: EY Nigeria                                                                                             9
Commitment to quality                                                    (4/9)

While the market and stakeholders         to provide the basis for continual             additional risk management
continue to demand high-quality           improvement in audit quality,                  procedures for specific high-risk
audits, they also demand increasingly     consistent with the highest standards          factors.
efficient and effective delivery          in the profession.
of audit services. In addition to         The GE is responsible for
the investments mentioned, EY                                                        •   Comply with legal, regulatory and
                                          implementing quality improvement.
continues to seek ways to improve                                                        professional requirements
                                          As such, it reviews the results of our
the effectiveness and efficiency of its                                              In addition, the EY Global Conflicts
                                          internal AQR program and external
audit methodology and processes,                                                     of Interest Policy defines global
                                          audit firm regulatory reviews,
while improving audit quality.                                                       standards for addressing categories
                                          as well as any key actions designed to
We work to understand where our           address areas                              of potential conflicts of interest and
audit quality may not be up to our        for improvement.                           a process for identifying them. It also
own expectations and those of                                                        includes provisions for managing
                                          The recent results of such monitoring,
stakeholders, including external audit                                               potential conflicts of interest as
                                          together with the recent feedback
firm regulators. We seek to learn                                                    quickly and efficiently as possible
                                          from independent external audit
from external and internal inspection                                                through the use of appropriate
                                          firm regulators, provide EY Nigeria
activities and to identify root causes                                               safeguards. Such safeguards range
                                          with a basis to conclude that our          from obtaining a client’s consent
of adverse quality occurrences to         internal control systems are designed
enable us continually to improve audit                                               for EYG member firms to act for
                                          appropriately and are operating
quality, and we believe that taking                                                  two or more clients to declining an
                                          effectively.
effective and appropriate actions to                                                 engagement to avoid an identified
improve quality is important.             Client acceptance and                      conflict.
                                          continuance                                The EY Global Conflicts of Interest
Effectiveness of the quality control
system                                    EY policy                                  Policy and associated guidance were
                                                                                     updated in early 2015. The updates
EY has designed and implemented           The EY Global Client Acceptance and
                                                                                     take into account the increasing
a comprehensive set of global audit       Continuance Policy sets out principles
                                                                                     complexity of engagements and
quality control policies and practices.   for member firms to determine
                                                                                     client relationships, and the need for
These policies and practices meet         whether to accept a new client or a
                                                                                     speed and accuracy in responding to
the requirements of the International     new engagement, or to continue with
                                                                                     clients. They also align with the latest
Standards on Quality Control issued       an existing client or engagement.
                                                                                     International Ethics Standards Board
by the International Auditing and         These principles are fundamental to
                                                                                     for Accountants (IESBA) standards.
Assurance Standards Board (IAASB).        maintaining quality, managing risk,
EY Nigeria has adopted these              protecting our people and meeting          Putting policy into practice
global policies and procedures,           regulatory requirements. The               We use the EY Process for Acceptance
and has supplemented them as              objectives of the policy are to:           of Clients and Engagements
necessary to comply with local laws       •   Establish a rigorous process           (PACE), an intranet—based system,
and professional guidelines, and to           for evaluating risk and making         for efficiently coordinating client
address specific business needs.              decisions to accept or continue        and engagement acceptance and
We also execute the EY Audit Quality          clients or engagements                 continuance activities in line with
                                                                                     global, service line and member firm
Review (AQR) program to evaluate          •   Meet applicable independence
whether our system of audit quality                                                  policies. PACE takes users through
                                              requirements
control has operated effectively so as                                               the acceptance and continuance
                                          •   Identify and deal appropriately with   requirements, and identifies the
to provide reasonable assurance that
                                              any conflicts of interest              policies and references to professional
our people comply with applicable
professional standards, internal          •   Identify and decline clients or        standards needed to assess both
policies and regulatory requirements.         engagements that pose excessive        business opportunities and associated
                                              risk                                   risks.
The results of the AQR program and
external inspections are evaluated        •   Require consultation with
and communicated within EY Nigeria            designated professionals to identify

Transparency Report 2018: EY Nigeria                                                                                            10
Commitment to quality                                                    (5/9)
As part of this process, we carefully      to building trust and confidence in the   section 225 of the International
consider the risk characteristics of a     capital markets and in economies the      Ethics Standards Board for
prospective client or engagement and       world over.                               Accountants Code of Ethics (IESBA
the results of several due diligence                                                 Code), Responding to Non-Compliance
                                           Audit methodology
procedures. Before we take on a new                                                  with Laws and Regulations and the
engagement or client, we determine         EY GAM provides a global framework        resulting conforming changes to the
whether we can commit sufficient           for delivering high-quality audit         ISAs. In addition, updated guidance
resources to deliver quality service,      services through the consistent           was issued on performing joint audits
especially in highly technical areas,      application of thought processes,         and audits when the entity uses a
and if the services the client wants       judgments and procedures in all audit     service organization, along with new
are appropriate for us to provide.         engagements, regardless of size.          policies relating to maintaining the
The approval process is rigorous, and      EY GAM also requires compliance           audit documentation in electronic
no new audit engagement may be             with relevant ethical requirements,       form. EY GAM was also enhanced by
accepted without the approval of our       including independence from               adding guidance to address common
PPD.                                       the entity we audit. Making risk          questions from audit teams and issues
                                           assessments, reconsidering and            arising from inspections.
In the EY annual client and                modifying them as appropriate, and
engagement continuance process,                                                      In addition, we monitor current
                                           using these assessments to determine
we review our service and ability to                                                 and emerging developments, and
                                           the nature, timing and extent of
continue to provide quality service,                                                 issue timely audit planning and
                                           audit procedures are fundamental
and confirm that clients share EY                                                    other reminders. These reminders
                                           to EY GAM. The methodology also
Nigeria’s commitment to quality and                                                  emphasize areas noted during
                                           emphasizes applying appropriate
transparency in financial reporting.                                                 inspections as well as other key
                                           professional skepticism in the
The partner in charge of each                                                        topics of interest to our local audit
                                           execution of audit procedures.
audit, together with our Assurance                                                   regulator(s) and the International
                                           EY GAM is based on International
leadership, annually reviews our                                                     Forum of Independent Audit
                                           Standards on Auditing (ISAs) and is
relationship with the audit client to                                                Regulators (IFIAR).
                                           supplemented in Nigeria to comply
determine whether continuance is           with the local regulatory or statutory    Technology
appropriate.                               requirements.                             Our audit engagement teams use
As a result of this review, certain        Using an online tool, EY Atlas, an EY     technology to assist in executing and
audit engagements are identified           auditor is presented with a version       documenting the work performed in
as requiring additional oversight          of EY GAM organized by topic and          accordance with EY GAM.
procedures during the audit (close         designed to focus the audit strategy
monitoring), and some audit clients                                                  EY Canvas, our global audit platform,
                                           on the financial statement risks,
are discontinued. As with the client                                                 lies at the heart of the audit and
                                           and the design and execution of
acceptance process, our Regional and/                                                enables us to provide a high-quality
                                           the appropriate audit response to
or cluster PPD is involved in the client                                             audit. EY Canvas is built using HTML5,
                                           those risks. EY GAM consists of two
continuance process and must agree                                                   state-of-the-art technology for web
                                           key components: requirements and
with the continuance decisions.                                                      applications. This allows us to provide
                                           guidance, and supporting forms            data security and to evolve our
Decisions about acceptance                 and examples. The requirements            software to respond to changes in the
or continuance of clients and              and guidance reflect both auditing        accounting profession and regulatory
engagements consider the                   standards and EY policies. The forms      environment. The predecessor
engagement team’s assessment               and examples include leading practice     audit support tool, GAMx, was
of whether the company’s                   illustrations, and assist in performing   decommissioned in 2018.
management may pressure us to              and documenting audit procedures.
accept inappropriate accounting,                                                     Through the use of profile questions,
                                           EY GAM can be “profiled” or tailored
auditing and reporting conclusions                                                   audit engagements in EY Canvas
                                           to present the relevant requirements
to undermine quality. Considerations                                                 are automatically configured with
                                           and guidance, depending on the
and conclusions on the integrity of                                                  information relevant to an entity’s
                                           nature of the entity being audited. For
management are essential                                                             listing requirements and industry.
                                           example, there are profiles for listed
to acceptance and continuance                                                        This helps to keep our audit plans
                                           entities and for those considered
decisions.                                                                           customized and up-to-date, and
                                           non-complex entities. Enhancements        provides direct linkage to our audit
Performance of audits                      to the audit methodology are made         guidance, professional standards and
                                           regularly to address new standards,
As part of EY Vision 2020+, EY has                                                   documentation templates. EY Canvas
                                           emerging auditing issues and matters,
invested significantly in improving                                                  is built with a user interface that
                                           implementation experiences, and
audit methodologies and tools, with                                                  allows the team to visualize risks and
the goal of performing the highest-        external and internal inspection          their relationship to the planned
                                           results. In 2017, EY GAM was updated
quality audits in the profession. This
                                           to address the requirements of new
investment reflects EY’s commitment

Transparency Report 2018: EY Nigeria                                                                                           11
Commitment to quality                                                     (6/9)
response and work performed in key         EY Atlas is a global technology            whole, and the related accounting
areas. It also enables a linkage for our   platform that enables our auditors         and financial statement presentation.
group audit teams to communicate           to access the latest accounting and        A tax professional reviews the
inter-office risks and instructions so     auditing content, including external       significant tax and other relevant
that the primary audit team can direct     standards, EY interpretations and          working papers. For listed and certain
execution and monitor performance          thought leadership.                        other companies, an engagement
of the group audit.                                                                   quality reviewer (described
                                           Formation of audit engagement
                                                                                      below) reviews important areas
EY Canvas includes a Client Portal to      teams
                                                                                      of accounting, financial reporting
assist teams in communicating with         EY Nigeria policies require an annual      and audit execution, as well as the
clients and streamlining their client      review of partner assignments              financial statements of the company
requests. Mobile applications are          by our Assurance leadership and            we audit and our auditor’s report.
integrated with EY Canvas to help          Nigeria PPD to make sure that the
our people in their audit work; for                                                   The nature, timing and extent of the
                                           professionals leading listed-company
example, in monitoring the status of                                                  reviews of audit work depend on many
                                           audits possess the appropriate
the audit, capturing audit evidence                                                   factors, including:
                                           competencies (i.e., the knowledge,
securely and performing inventory          skills and abilities) to fulfill their     •   The risk, materiality, subjectivity
observations.                              engagement responsibilities, and are           and complexity of the subject
Audit engagement teams use other           in compliance with applicable auditor          matter
software applications, forms and           rotation regulations.                      •   The ability and experience of the
templates during various phases            The assignment of professionals to             audit team members preparing the
of an audit to assist in executing         an audit engagement is also made               audit documentation
procedures, making and documenting         under the direction of our Assurance
audit conclusions, and performing                                                     •   The level of the reviewer’s direct
                                           leadership. Factors considered
analysis.                                                                                 participation in the audit work
                                           when assigning people to audit
At EY, we are making data analysis         teams include engagement size and          •   The extent of consultation
integral to our audits. Our use of data    complexity, specialized industry               employed
and analysis is not about additive         knowledge and experience, timing of        Our policies also describe the roles
procedures or visualizations. It is        work, continuity, and opportunities for    and responsibilities of each audit
about taking large populations of          on-the-job training. For more complex      engagement team member for
company data, and applying our             engagements, consideration is given        managing, directing and supervising
globally consistent technology (EY         to whether specialized or additional       the audit, as well as the requirements
Helix) and methodology (EY GAM) to         expertise is needed to supplement or       for documenting their work and
audit that data.                           enhance the audit engagement team.         conclusions.
EY Helix is a library of data analyzers    In many situations, internal specialists   Consultation requirements
for use in audits. These data analyzers    are assigned as part of the audit
are transforming the audit through         engagement team to assist in               EY consultation policies are built upon
the analysis of larger populations         performing audit procedures and            a culture of collaboration, whereby
of audit-relevant data, identifying        obtaining appropriate audit evidence.      audit professionals are encouraged
unseen patterns and trends in that         These professionals are used in            to share perspectives on complex
data, and helping to direct our audit      situations requiring special skills        accounting, auditing and reporting
efforts. The use of data analytics         or knowledge, such as information          issues. Consultation requirements
also allows us to obtain better            systems, asset valuation and actuarial     and related policies are designed
perspectives, richer insights and a        analysis.                                  to involve the right resources so
deeper understanding of transactions                                                  that audit teams reach appropriate
and areas of risk.                         Review and consultation                    conclusions.

EY is deploying data analyzers to          Reviews of audit work                      Consultation is built into the decision-
analyze the business operating cycles      EY policies describe the requirements      making process; it is not just a
of the companies that we audit,            for timely and direct senior               process to provide advice.
supported by analytics-based audit         professional participation, as well
programs to aid the application of                                                    For complex and sensitive
                                           as the level of review required for
these data analyzers.                                                                 matters, we have a formal process
                                           the work performed. Supervisory
                                                                                      requiring consultation outside of
Using the EY Helix library of data         members of an audit engagement
                                                                                      the audit engagement team with
analyzers, our engagement teams can        team perform a detailed review of the
                                                                                      other personnel who have more
enhance their audit risk assessment,       audit documentation for accuracy and
                                                                                      experience or specialized knowledge,
enabling the audit of higher-risk          completeness. Senior audit executives
                                                                                      primarily Professional Practice and
transactions, and assisting our people     and engagement partners perform
                                                                                      Independence personnel. In the
in asking better questions about audit     a second-level review to determine
                                                                                      interests of
findings and evaluating the outcomes.      adequacy of the audit work as a

Transparency Report 2018: EY Nigeria                                                                                             12
Commitment to quality                                                  (7/9)
objectivity and professional             of an audit engagement team to            is less restrictive than the IESBA
skepticism, our policies require         raise any disagreements relating to       requirements, the EY Global
members of Professional Practice,        significant accounting, auditing or       Independence Policy requires the
Independence and certain others          reporting matters.                        lead engagement partner and the
to withdraw from a consultation                                                    engagement quality reviewer to
                                         These policies are made clear to
if they currently serve, or have                                                   be rotated after seven years. For
                                         people as they join EY, and we
recently served, the client to which                                               a new PIE (including a newly listed
                                         continue to promote a culture that
the consultation relates. In this                                                  company) client, the lead engagement
                                         reinforces a person’s responsibility
circumstance, other appropriate                                                    partner and the engagement quality
                                         and authority to make their own views
individuals would be assigned.                                                     reviewer may remain in place for an
                                         heard, and seek out the views of
                                                                                   additional two years before rotating
EY policies also require that we         others.
                                                                                   off the team, if they have served the
document all consultations, including    Differences of professional opinion       client for six or more years prior to
written concurrence from the person      that arise during an audit are            the listing. Following rotation, the
or persons consulted, in order to        generally resolved at the audit           partner may not resume the lead or
demonstrate their understanding of       engagement team level. However, if        engagement quality review role until
the matter and its resolution.           any person involved in the discussion     at least two years
Engagement quality reviews               of an issue is not satisfied with the     have elapsed.
                                         decision, they refer it to the next
Engagement quality reviews are                                                     We employ tools to track partner
                                         level of authority until agreement is
performed by audit partners in                                                     rotation that enable effective
                                         reached or a final decision is made.
compliance with professional                                                       monitoring of compliance with
standards for audits of all listed       Furthermore, if the engagement            requirements.
companies and those considered           quality reviewer makes                    We have also implemented a process
close monitoring. Engagement             recommendations that the                  for partner rotation planning and
quality reviewers are experienced        engagement partner does not accept        decision-making that involves
professionals with significant           or the matter is not resolved to the      consultation with, and approvals
subject matter knowledge. They are       reviewer’s satisfaction, the auditor’s    by, our Professional Practice and
independent of the engagement            report is not issued until the matter     Independence professionals.
team and able to provide objective       is resolved. EY policies require
evaluation of significant accounting,    documentation of disagreements and        Audit quality reviews
auditing and reporting matters. In no    their resolution.                         The EY Global AQR program is the
circumstances may the responsibility                                               cornerstone of the EY process to
of the engagement quality reviewer       Audit partner rotation
                                                                                   monitor audit quality. EY Nigeria
be delegated to another individual.      EY supports mandatory audit partner       executes the Global AQR program,
The engagement quality review            rotation to help reinforce auditor        reports results and develops
spans the entire engagement cycle,       independence. EY Nigeria complies         responsive actions plans. The primary
including planning, risk assessment,     with the audit partner rotation           goal of the program is to determine
audit strategy and execution.            requirements of the code of the           whether systems of quality controls,
Policies and procedures for the          IESBA, the Securities and Exchange        including those of EY Nigeria, are
performance and documentation of         Commission of Nigeria, and the            appropriately designed and followed
engagement quality reviews provide       Financial Reporting Council of Nigeria,   in the execution of audit engagements
specific guidelines on the nature,       , as well as the U.S. Securities and      to provide reasonable assurance
timing and extent of the procedures      Exchange Commission (SEC), where          of compliance with policies and
to be performed, and the required        required. EY Nigeria supports audit       procedures, professional standards,
documentation evidencing their           partner rotation because it provides      and regulatory requirements. The
completion. Our Regional and Cluster     a fresh perspective and promotes          Global AQR program complies with
PPD approves all engagement quality      independence from company                 guidelines in the International
review assignments.                      management, while retaining               Standard on Quality Control No. 1
                                         expertise and knowledge of the            (ISQC No. 1), as amended, and is
Audit engagement team resolution         business. Audit partner rotation,         supplemented where necessary to
process for differences of               combined with independence                comply with Nigeria professional
professional opinion                     requirements, enhanced systems            standards and regulatory
EY has a collaborative culture that      of internal quality controls and          requirements. It also aids EY
encourages and expects people to         independent audit oversight,              Nigeria’s continual efforts to identify
speak up, without fear of reprisal, if   helps strengthen independence             areas where we can improve our
a difference of professional opinion     and objectivity, and are important        performance or enhance our policies
arises or if they are uncomfortable      safeguards of audit quality.              and procedures.
about a matter relating to a client      For PIEs where rotation of the
engagement. Policies and procedures      audit partner is not mandated by
are designed to empower members          local independence regulation or

Transparency Report 2018: EY Nigeria                                                                                         13
Commitment to quality                                                  (8/9)
Executed annually, the program           reviewed.                                 other stakeholders.
is coordinated and monitored by          The results of the Global AQR             Compliance with legal
representatives of the Global PPD        program, external practice monitoring
network, with oversight by Global        and inspection activities are evaluated   requirements
Assurance leadership.                    and communicated to improve               The EY Global Code of Conduct
The engagements reviewed each year       quality. Any quality improvement          provides a clear set of standards
are selected on a risk-based approach,   plans describe the follow-up actions      that guide our actions and business
emphasizing audit engagements that       to be taken, the people responsible,      conduct.
are large, complex or of significant     the timetable and deadlines, and          EY Nigeria complies with applicable
public interest. The Global AQR          sign-off on completed actions.            laws and regulations, and EY’s
program includes detailed risk-          Measures to resolve audit quality         values underpin our commitment to
focused file reviews covering a large    matters noted from the Global AQR         doing the right thing. This important
sample of listed and non-listed audit    program, regulatory inspections           commitment is supported by a
engagements to measure compliance        and peer reviews are addressed            number of policies and procedures,
with internal policies and procedures,   by Assurance leadership and our           explained in the paragraphs below.
EY GAM requirements, and relevant        PPD. The actions are monitored by
                                                                                   Anti-bribery
local professional standards and         our PPD and Assurance leadership.
regulatory requirements. It also         These programs provide important          The EY Global Anti-bribery Policy
includes reviews of a sample of          practice monitoring feedback for          provides EY people with direction
non-audit engagements. These             our continuing quality improvement        around certain unethical and illegal
measure compliance with the              efforts.                                  activities. It emphasizes the obligation
relevant professional standards and                                                to comply with anti-bribery laws and
internal policies and procedures         External quality assurance                provides greater definition of what
that should be applied in executing      review                                    constitutes bribery. It also identifies
non-audit services. In addition,                                                   reporting responsibilities when
                                         EY Nigeria’s audit practice is subject
practice-level reviews are performed                                               bribery is discovered. In recognition
                                         to periodic inspection by the Financial
to assess compliance with quality                                                  of the growing global impact of
                                         reporting Council, UK. As part of its
control policies and procedures in                                                 bribery and corruption, efforts have
                                         inspections, the FRC evaluates quality
the functional areas set out in ISQC                                               been increased to embed anti-bribery
                                         control systems and reviews selected
No. 1. The Global AQR program                                                      measures across EY.
                                         engagements.
complements external practice
monitoring and inspection activities,    The last quality assurance inspection
such as inspection programs executed     by FRC took place in 2015. The
by audit regulators and external peer    final report on the inspection was
reviews.                                 issued on 19 February 2016. The
                                         FRC commenced another review in
AQR reviewers and team leaders
                                         October 2018.
are selected for their skills and
professional competence in               We respect and benefit from the FRC
accounting and auditing, as well         inspection process. We thoroughly
as their industry specialization;        evaluate points raised during the
they often work in the Global AQR        inspection in order to identify areas
program for a number of years and        where we can improve audit quality.
are highly skilled in the execution      Together with the AQR process,
of the program. Team leaders and         external inspections aid us in making
reviewers are assigned to inspections    our audits and related control
outside of their home location and       processes of the highest quality in the
are independent of the audit teams       interests of our clients’ investors and

Transparency Report 2018: EY Nigeria                                                                                          14
Commitment to quality                                                  (9/9)

Insider trading                           Data privacy                             Document retention
The EY Global Insider Trading Policy      The EY Global Personal Data Privacy      EY Nigeria’s record retention policy
reaffirms the obligation of our people    Policy sets out the principles to be     applies to all engagements and
not to trade in securities with insider   applied to the use and protection of     personnel. This policy addresses
information, provides detail on what      personal data, including that relating   document preservation whenever any
constitutes insider information and       to current, past and prospective         person becomes aware of any actual
identifies with whom our people           personnel, clients, suppliers, and       or reasonably anticipated claim,
should consult if they have questions     business associates. This policy         litigation, investigation, subpoena
regarding their responsibilities.         is consistent with applicable laws       or other government proceeding
                                          and regulations concerning data          involving us or one of our clients
Trade sanctions
                                          protection and privacy for maintaining   that may relate to our work. It also
It is important that we are aware         and processing personal data.            addresses Nigeria legal requirements
of the ever—changing situation            Furthermore, we have a policy to         applicable to the creation and
with respect to international trade       address our specific Nigeria data        maintenance of working papers
sanctions. EY monitors sanctions          privacy requirements and business        relevant to the work performed.
issued in multiple geographies and        needs.
provides guidance to EY people on
impacted activities.

Transparency Report 2018: EY Nigeria                                                                                      15
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