Transparency Report 2020 - EY Nigeria
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Contents Message from the Country Managing Partner and the EY Nigeria Assurance Leader ............................. About us .......................................................................................................................................... 3 Legal structure, ownership and governance ..................................................................................... 5 Network arrangements .................................................................................................................. 6 Commitment to Sustainable Audit Quality ......................................................................................... 8 Infrastructure supporting quality .................................................................................................... 8 Instilled professional values ............................................................................................................ 9 Internal quality control system ..................................................................................................... 11 Client acceptance and continuance ............................................................................................... 12 Performance of audits ................................................................................................................. 13 Review and consultation .............................................................................................................. 15 Rotation and long association ....................................................................................................... 16 Audit quality reviews ................................................................................................................... 16 External quality assurance review ................................................................................................. 17 Compliance with legal requirements .............................................................................................. 17 Independence practices .................................................................................................................. 19 Continuing education of audit professionals ..................................................................................... 21 Revenue and remuneration ............................................................................................................. 22 Financial information ................................................................................................................... 22 Partner remuneration .................................................................................................................. 23 Appendix 1: List of PIE audit clients ................................................................................................ 24 EY Nigeria PIE audit clients........................................................................................................... 24 Appendix 2:.................................................................................................................................... 25 2 | Transparency Report 2020: EY Nigeria
Message from the Country Managing Partner and the EY Nigeria Anthony Oputa Jamiu Olakisan Managing Partner EY Nigeria Assurance Leader EY Nigeria Assurance Leader Welcome to the Transparency Report 2020 of EY Nigeria. We believe that how we advance sustainable 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 update 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 through 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 embrace the transparency objectives of the European Union’s Regulation 537/2014 , which require statutory auditors of public interest entities (PIEs) to publish annual transparency reports. The EY Nigeria Transparency Report 2020 complies with the Regulation, and covers the year ended 30 June 2020 and any more recent relevant events. 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; our independence practices; and the impact of COVID-19 on our operations. EY Nigeria is focused on enhancing audit quality and upholding our independence, informed by several factors, 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 inspection findings and taking responsive actions. The need for trust and confidence in financial reporting in our capital markets has never been greater, and auditors play an important role in this regard. 3 | Transparency Report 2020: EY Nigeria
• 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. Anthony Oputa 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 delivered by EY people help build trust and confidence in business and the capital markets. EY auditors serve the public interest by delivering high-quality audits with independence, integrity, objectivity and professional skepticism. In so doing, the EY organization plays a critical role in building a better working world for EY people, clients and communities. 4 | Transparency Report 2020: EY Nigeria
About us Legal structure, ownership firm of EYG, has no financial operations and does not provide any professional services. and governance Each Region elects a Regional Partner Forum (RPF), In Nigeria ,Ernst & Young is a Partnership organized in whose representatives advise and act as a sounding Nigeria and is a member firm of Ernst & Young Global board to Regional leadership. The partner elected as Limited, a UK company limited by guarantee (EYG). In Presiding Partner of the RPF also serves as the this report, we refer to ourselves as “EY Nigeria,” Region’s representative on the Global Governance “we,” “us” or “our.” EY refers collectively to the global Council (see page 6). organization of the member firms of EYG. EY Nigeria is owned by the partners and governed by an executive committee of partners as of 1 July 2020 Anthony Oputa, became the Managing Partner. He is supported by the other four service line leaders and Market leader who together provide leadership to the four business lines: Consulting, Assurance, Strategy and Transaction and Tax Services. The firm has its head office in Lagos and other offices in Abuja and Port Harcourt. EY Nigeria has 28 partners, 30 directors (Executive and associate) and over 500 professional staff. EYG member firms are grouped into three geographic Areas: Americas; Asia-Pacific; and Europe, Middle East, India and Africa (EMEIA). The Areas comprise multiple Regions, which themselves consist of member firms. EY Nigeria is part of the EMEIA Area, which comprises EYG member firms in 97 countries in Europe, the Middle East, India and Africa. Within the EMEIA Area, there are 10 Regions. EY Nigeria is part of the Africa Region. Ernst & Young (EMEIA) Limited (EMEIA Limited), an English company limited by guarantee, is the principal coordinating entity for the EYG member firms in the EMEIA Area. EMEIA Limited facilitates the coordination of these firms and cooperation between them, but it does not control them. EMEIA Limited is a member 5 | Transparency Report 2020: EY Nigeria
Network arrangements clients and others in each country, and be more responsive to local needs. Global Governance Council EY is a global leader in assurance, tax, strategy, transaction and consulting services. Worldwide, over The Global Governance Council (GGC) is the main 298,000 people in member firms in more than 150 oversight body of EYG. It comprises one or more countries share a commitment to building a better representatives from each Region, other member firm working world, united by shared values and an partners as at-large representatives and up to six unwavering commitment to quality, integrity and independent non-executives (INEs). The Regional professional skepticism. In today’s global market, the representatives, who otherwise do not hold senior integrated EY approach is particularly important in the management roles, are elected by their RPFs for a delivery of high-quality multinational audits, which can three-year term, with provision for one successive span nearly every country in the world. reappointment. The GGC advises EYG on policies, strategies, and the public interest aspects of its This integrated approach enables EY member firms to decision-making. The GGC approves, in some instances develop and draw upon the range and depth of upon the recommendation of the GE, certain matters experience required to perform such diverse and that could affect EY. complex audits. EYG coordinates the member firms and promotes Independent Non-Executives cooperation among them. EYG does not provide Up to six Independent Non-Executives (INEs) are services, but its objectives include the promotion of appointed from outside EY. The INEs are senior leaders exceptional high-quality client service by member from both the public and private sectors and reflect firms worldwide. Each member firm is a legally distinct diverse geographic and professional backgrounds. entity. Their obligations and responsibilities as They bring to the global organization, and the GGC, members of EYG are governed by the regulations of the significant benefit of their varied perspectives and EYG and various other agreements. The structure and principal bodies of the global depth of knowledge. The INEs also form a majority of organization, described below, reflect the principle the Public Interest Sub-Committee (PIC) of the GGC. that EY, as a global organization, has a common The role of the PIC includes public interest aspects of shared strategy. decision-making, issues raised under whistle-blowing policies and procedures, and stakeholder dialogue and At the same time, the network operates on a Regional engagement in quality and risk management level within the Areas. This operating model allows for discussions. The INEs are nominated by a dedicated greater stakeholder focus in the Regions, permitting committee. member firms to build stronger relationships with 6 | Transparency Report 2020: EY Nigeria
Global Executive Global Practice Group The Global Executive (GE) brings together EY’s This group brings together the members of the GE, GE leadership functions, services and geographies. As of committees, Regional leaders and sector leaders. The 1 July 2020, it is chaired by the Chairman and CEO of Global Practice Group seeks to promote a common EYG, and includes its Global Managing Partners of understanding of EY’s strategic objectives and helps Client Service and Business Enablement; the Area drive consistency of execution across the organization. Managing Partners; the global functional leadership for Talent; the leaders of the global service lines — EYG member firms Assurance, Consulting (previously Advisory), Strategy Under the regulations of EYG, member firms commit and Transactions (previously Transaction Advisory themselves to pursue EY’s objectives, such as the Services) and Tax; and one EYG member firm partner provision of high-quality service worldwide. To that on rotation. end, the member firms undertake the implementation The GE also includes the Global Vice Chair of Markets, of global strategies and plans, and work to maintain the Global Vice Chair of Transformation, the Chief the prescribed scope of service capability. They are Client Technology Officer, the Chair of the Global required to comply with common standards, Accounts Committee, the Chair of the Emerging methodologies and policies, including those regarding Markets Committee, as well as a representative from audit methodology, quality and risk management, the Emerging Markets practices. independence, knowledge sharing, HR and technology. The GE and the GGC approve nominations for the Above all, EYG member firms commit to conducting Chairman and CEO of EYG and ratify appointments of their professional practices in accordance with the Global Managing Partners. The GE also approves applicable professional and ethical standards, and all appointments of Global Vice Chairs. The GGC ratifies applicable requirements of law. This commitment to the appointments of any Global Vice Chair who serves integrity and doing the right thing is underpinned by as a member of the GE. the EY Global Code of Conduct and EY values (see page 10). The GE’s responsibilities include the promotion of global objectives and the development, approval and, Besides adopting the regulations of EYG, member where relevant, implementation of: firms enter into several other agreements covering aspects of their membership in the EY organization, • Global strategies and plans such as the right and obligation to use the EY name, • Common standards, methodologies and policies to and knowledge sharing. be promoted within member firms • People initiatives, including criteria and processes Member firms are subject to reviews to evaluate for admission, evaluation, development, reward adherence to EYG requirements and policies governing and retirement of partners issues, such as independence, quality and risk • Quality improvement and protection programs management, audit methodology and HR. Member • Proposals regarding regulatory matters and public firms unable to meet quality commitments and other policy EYG membership requirements may be subject to • Policies and guidance relating to member firms’ termination from the EY organization. service of international clients, business development, markets and branding • EY’s development funds and investment priorities • EYG’s annual financial reports and budgets • GGC recommendations The GE also has the power to mediate and adjudicate disputes between member firms. GE committees Established by the GE and bringing together representatives from across the organization, the GE committees are responsible for making recommendations to the GE. In addition to the Global Audit Committee, examples of other committees include Assurance, Consulting, Tax, Strategy and Transactions, Global Markets and Investments, Global Accounts, Emerging Markets, Talent and Risk Management. 7 | Transparency Report 2020: EY Nigeria
Commitment to Sustainable Audit Quality Infrastructure supporting This helps provide greater assurance as to the objectivity of audit quality and consultation processes. quality The Global PPD also leads and oversees the Global Professional Practice group. This is a global network of Quality in our service lines technical subject-matter specialists in accounting and NextWave is EY’s global strategy and ambition to auditing standards, who consult on accounting, deliver long-term value to clients, people and society. auditing and financial reporting matters; and perform NextWave reconfirms EY’s purpose, ambition, and various practice monitoring and risk management strategy. EY’s purpose of building a better working activities. world continues to inspire EY people to not only serve clients, but also to use our knowledge, skills and experiences to support the communities in which we The Global PPD oversees the development of the EY live and work. The insights and quality services we Global Audit Methodology (EY GAM) and related deliver help build trust and confidence in the capital technologies so that they are consistent with relevant markets and in economies around the world. professional standards and regulatory requirements. The Global Professional Practice group also oversees Delivering high-quality audits and continuously the development of the guidance; training and improving what we do are fundamental to building a monitoring programs; and processes used by member better working world. To do so, we recruit, develop and firm professionals to execute audits consistently and retain the right people; embrace innovation; effectively. The Global, Area and Regional PPDs, encourage simplification; and monitor what we do together with other professionals who work with them closely. Serving the public interest through the in each member firm, are knowledgeable about EY delivery of high-quality audits consistently around the people; clients; and processes; and they are readily world is a top priority. Significant investments continue accessible for consultation with audit engagement to be made to deliver state-of-the-art tools and teams. develop EY people. EY audit teams embrace a digital- first approach and are supported by a more than Additional resources often augment the Global US$600m investment in new and emerging Professional Practice group, including networks of technologies. professionals focused on: EYG member firms and their service lines are • Internal-control reporting and related aspects of the EY audit methodology accountable for delivering quality engagements. EY member firms’ service lines manage the overall • Accounting, auditing and risk issues for specific process for quality reviews of completed engagements industries and sectors and input for the quality of in-process engagements, • Event-specific issues involving areas of civil and which helps achieve compliance with professional political unrest; or sovereign debt and related accounting, auditing, reporting and disclosure standards and EY policies. implications The Global Vice Chair of Assurance coordinates • General engagement matters and how to work member firms’ compliance with EY policies and effectively with audit committees procedures for services provided by Assurance. Risk Management Professional Practice Risk Management (RM) oversees organization-wide The Global Vice Chair of Professional Practice, referred activities designed to help EY people meet global and to as the Global Professional Practice Director (PPD), is local compliance responsibilities and support client- overseen by the Global Vice Chair of Assurance and facing teams in delivering quality and exceptional works to establish global audit quality control policies client service. Responsibility for high-quality service and procedures. Each of the Area PPDs is overseen by and ownership of the risks associated with quality is the Global PPD and the related Area Assurance Leader. placed with the member firms and their service lines. 8 | Transparency Report 2020: EY Nigeria
Among other things, the Global RM Leader helps Cybersecurity oversee the identification and management of these Managing the risk of major and complex cyberattacks risks, as well as other risks across the organization as is a part of doing business for all organizations. While part of the broader Enterprise Risk Management no systems are immune from the threat of framework. cyberattacks, EY Nigeria is vigilant in the steps it takes Member firm partners are appointed to lead risk to secure and protect client data. The EY approach to management initiatives (supported by other staff and cybersecurity is proactive and includes the professionals), including coordinating with the service implementation of technologies and processes lines on such matters. The Global RM Leader is necessary to manage and minimize cybersecurity risks responsible for establishing globally consistent risk globally. EY information security and data privacy management execution priorities and enterprise-wide programs, consistent with industry practices and risk management. applicable legal requirements, are designed to protect against unauthorized access to systems and data. These priorities cascade to member firms through an There is a dedicated team of cybersecurity specialists Enterprise Risk Management (ERM) program. who constantly monitor and defend EY systems. There were additional complexities in 2020 as the Beyond technical and process controls, all EY people world deals with the COVID-19 pandemic. This are required to affirm in writing their understanding of required a coordinated response across EY via the principles contained in the EY Global Code of activation of the Global Crisis Management Program Conduct and their commitment to abide by them. (GCMP). Every aspect and geography of the business There are also required security awareness learning was affected. The GCMP, led by the Global RM Leader, activities. Various policies outline the due care that involved EY’s leadership on a frequent and consistent must be taken with technology and data, including, but basis. The GCMP is an extensive program that is not limited to, the Global Information Security Policy, reviewed regularly. It includes plans that cascade from and a global policy on the Acceptable Use of the Global and Area levels. Technology. EY cybersecurity policies and processes recognize the importance of timely communication. EY Global Confidentiality Policy people receive regular and periodic communications Protecting confidential information is ingrained in the reminding them of their responsibilities from these everyday activities of EYG member firms. Respect for policies and of general security awareness practice. intellectual capital and all other sensitive and restricted information is required by the EY Global Components of our audit quality control Code of Conduct, which provides a clear set of program principles to guide the behaviors expected of all those In the following sections, we describe the principal who work with EY. The Global Confidentiality Policy components of the audit quality control program, further details this approach to protect information which EY Nigeria follows: and reflect the ever-changing restrictions on the use of data. This policy provides added clarity for those • Instilled professional values who work with EY and forms the fundamental broader • Internal quality control system guidance that includes key policies on conflicts of • Client acceptance and continuance interest, personal data privacy and records retention. • Performance of audits Other guidance includes: • Review and consultation • Social media guidance • Rotation and long association • Information-handling requirements • Audit quality reviews In addition, the global policy on Reporting Fraud, • External quality assurance reviews Illegal Acts and Other Non-compliance with Laws, • Compliance with legal requirements Regulations and EY’s Global Code of Conduct requires EY professionals to speak up on observing behavior that is believed to be a violation of a law or regulation, Instilled professional values applicable standard or EY’s Global Code of Conduct. This includes the unauthorized or improper disclosure Sustainable Audit Quality of confidential information. Quality is the foundation of our work and central to Furthermore, the global policy on Personal Data EY’s responsibility to provide confidence to the capital Protection supports and builds upon provisions within markets. This is reflected in the Sustainable Audit the EY Global Code of Conduct regarding respecting Quality (SAQ) program, which continues to be the and protecting personal information, in accordance highest priority for EY member firms’ Assurance with local law and professional standards, which has practices. been updated consistent with the EU General Data Protection Regulation (GDPR). 9 | Transparency Report 2020: EY Nigeria
SAQ establishes a strong governance structure that The SAQ infrastructure demonstrates that audit enables each member firm to provide high-quality quality is the single most important factor in our audits. It is implemented locally; and coordinated and decision-making and the key measure on which our overseen globally. The word “sustainable” in SAQ is professional reputation stands. used to demonstrate that this is not a one-off, short- term initiative, but an ongoing process of Tone at the top improvement. EY Nigeria’s leadership is responsible for setting the There are six SAQ pillars: tone at the top; exceptional right tone at the top and demonstrating EY’s talent; simplification and innovation; audit technology commitment to building a better working world and digital; enablement and quality support; and through behavior and actions. While the tone at the accountability. The pillars are supported by a top is vital, our people also understand that quality foundation of serving the public interest. and professional responsibility start with them and that within their teams and communities, they are Significant progress has been made through SAQ. EY leaders too. Our shared values, which inspire our member firms’ internal and external inspection people and guide them to do the right thing, and our findings globally are improving, and there is greater commitment to quality are embedded in who we are consistency in execution. EY has deployed world-class and in everything we do. technological tools that enhance the quality and value of EY audits, including the EY Canvas online audit The EY approach to business ethics and integrity is platform, the EY Helix analytics platform and the EY contained in the EY Global Code of Conduct and other Atlas research platform. policies and is embedded in the EY culture of consultation, training programs and internal A key feature of EY Canvas is “My EY” (formerly known communications. Senior management regularly as the EY Canvas Client Portal), which enables clients reinforces the importance of performing quality work, to communicate with audit teams and confirm what complying with professional standards, adhering to our information auditors have requested and whether that policies, and leading by example. In addition, EY information has been provided. EY Canvas also assesses the quality of professional services provided facilitates the use of the “Milestones” project as a key metric in evaluating and rewarding EY management functionality, which helps audit teams professionals. stay on pace with their audit execution and drive executive involvement. Finally, project management The EY culture strongly supports collaboration and enhancements within Canvas empower audit teams to places special emphasis on the importance of be focused on audit execution. consultation in dealing with complex or subjective accounting, auditing, reporting, regulatory and When Milestones, My EY, and the project management independence matters. We believe it is important to tools and enablement are used, engagement teams determine that engagement teams and clients can more effectively execute audit tasks with correctly follow consultation advice, and we emphasize appropriate skepticism and curiosity. As a result, audit this when necessary. quality is enhanced. Other SAQ initiatives include: a new approach to The consistent stance of EY Nigeria has been that no pictorially depict a company’s internal controls and client is more important than our professional processes; the Personal Workload Tool, which reviews reputation — the reputation of EY Nigeria and the personal responsibilities and assesses whether there is reputation of each of our professionals. sufficient time to execute high-quality audits; Purpose- Led Outcome Thinking (PLOT), a framework that focuses on the behaviors that drive high-quality audits; and Key Findings Review, which helps coach EY teams. Code of Conduct There is also a network of Quality Enablement Leaders We promote a culture of integrity among our (QELs), an overall Global Audit Quality Committee and professionals. The EY Global Code of Conduct provides a Culture and Behaviors Taskforce. They help us in a clear set of principles that guide our actions and our executing and reviewing root cause analysis and business conduct and are to be followed by all EY understanding the impact of our initiatives in driving personnel. The EY Global Code of Conduct is divided quality outcomes, better behaviors and a continuous into five categories: improvement mindset. • Working with one another Audit quality is something that every team member • Working with clients and others must understand and be committed to implementing • Acting with professional integrity locally. SAQ is essential to all our goals and ambitions, • Maintaining our objectivity and independence and each Regional and Area leader has oversight of • Protecting data, information and intellectual the efforts to achieve those goals. capital 10 | Transparency Report 2020: EY Nigeria
Through our procedures to monitor compliance with We recognize that in today’s environment — the EY Global Code of Conduct and through frequent characterized by continuing globalization, the rapid communications, we strive to create an environment movement of capital and the impact of technology that encourages all personnel to act responsibly, changes — the quality of our audit services has never including reporting misconduct without fear of been more important. As part of NextWave, we retaliation. continue to invest heavily in developing and maintaining our audit methodology, tools and other The EY Ethics Hotline provides EY people, clients and resources needed to support quality service. others outside of the organization with a means to confidentially report activity that may involve While the market and stakeholders continue to demand unethical or improper behavior, and that may be in high-quality audits, they also demand an increasingly violation of professional standards or otherwise effective and efficient delivery of audit services. In inconsistent with the EY shared values or Global Code addition to the investments mentioned, EY continues of Conduct. Globally the hotline is operated by an to seek ways to improve the effectiveness and external organization that provides confidential and, if efficiency of its audit methodology and processes, desired, anonymous hotline reporting. while improving audit quality. When a report comes into the EY Ethics Hotline, either We work to understand where our audit quality may by phone or internet, it receives prompt attention. not be up to our own expectations and those of Depending on the content of the report, appropriate stakeholders, including independent audit regulators. individuals from Risk Management, Talent, Legal or We seek to learn from external and internal inspection other functions are involved in addressing the report. activities and to identify the root causes of adverse The same procedures are followed for matters that are quality occurrences to enable us continually to reported outside of the EY Ethics Hotline. improve audit quality. We believe that taking effective and appropriate actions to improve quality is important. Our values: who we are Effectiveness of the quality control system People who demonstrate integrity, EY has designed and implemented a comprehensive respect, teaming and inclusiveness set of global audit quality control policies and practices. These policies and practices meet the requirements of the International Standards on Quality People with energy, enthusiasm and Control issued by the International Auditing and the courage to lead Assurance Standards Board (IAASB). EY Nigeria has adopted these global policies and procedures and has People who build relationships based supplemented them as necessary to comply with local on doing the right thing laws and professional guidelines, and to address specific business needs. We also execute the EY Audit Quality Review (AQR) Internal quality control program to evaluate whether our system of audit system quality control has operated effectively to provide reasonable assurance that EY Nigeria and our people comply with applicable professional standards, internal Structure policies and regulatory requirements. EY Nigeria’s reputation for providing high-quality The results of the AQR program and external professional audit services independently, objectively inspections are evaluated and communicated within EY and ethically is fundamental to our success as Nigeria to provide the basis for continual improvement independent auditors. We continue to invest in in audit quality, consistent with the highest standards initiatives to promote enhanced objectivity, in the profession. independence and professional skepticism. These are fundamental attributes of a high-quality audit. The Global Executive has responsibility for the implementation of quality improvement. As such, it At EY Nigeria, our role as auditors is to provide reviews the results of the internal AQR program and assurance on the fair presentation of the financial external audit firm regulatory reviews, as well as any statements of the companies we audit. We bring key actions designed to address areas for together qualified teams to provide audit services, improvement. drawing on our broad experience across industry sectors and services. We continually strive to improve The recent results of such monitoring, together with our quality and risk management processes so that the feedback from independent audit regulators, provide quality of our service is at a consistently high level. EY Nigeria with a basis to conclude that our internal 11 | Transparency Report 2020: EY Nigeria
control systems are designed appropriately and are We believe that the requirements within ISQM 1 can operating effectively. help to improve quality at the firm and engagement level as an effective system of quality management is Update to the control framework – ISQM 1 foundational to achieving consistent engagement quality. In September 2020, the IAASB approved a quality management standard that includes significant changes to the way professional accountancy firms manage quality. The International Standard on Quality Client acceptance and Management 1 (ISQM 1) will replace the current International Standard on Quality Control 1 (ISQC 1) continuance and take a more proactive and risk-based approach. EY policy ISQM 1 will be effective as of December 2022 but remains subject to final approval by the Public Interest The EY global policy on Client and Engagement Oversight Board, in accordance with due process. Acceptance sets out principles for member firms to determine whether to accept a new client or a new ISQM 1 will require firms to design, implement, engagement or to continue with an existing client or monitor and assess the overall system of quality engagement. These principles are fundamental to management (SQM) that provides reasonable maintaining quality, managing risk, protecting EY assurance a firm will meet its quality objectives. people and meeting regulatory requirements. The The standard includes more robust requirements for objectives of the policy are to: the governance, leadership and culture of professional • Establish a rigorous process for evaluating risk accountancy firms, and a risk assessment process that and making decisions to accept or continue clients evaluates risks to achieving quality objectives and or engagements identification of controls that address those risks. It • Meet applicable independence requirements also requires more extensive monitoring of the SQM to • Identify and deal appropriately with any conflicts evaluate the effectiveness and identify deficiencies of interest that require corrective actions. • Identify and decline clients or engagements that Many steps have already been taken to improve the pose excessive risk SQM. An effective SQM is the foundation for EY’s • Require consultation with designated quality initiatives and is key to quality and operating professionals to identify additional risk management procedures for specific high-risk effectiveness. The EY approach is to implement an factors SQM that is consistently applied across the entire network of member firms. This is especially important • Comply with legal, regulatory and professional requirements in a global economy where many audits involve the use of other EY member firms. A globally consistent SQM In addition, the EY global policy on Conflicts of Interest helps ensure engagement quality and consistent defines global standards for addressing categories of execution. potential conflicts of interest and a process for identifying them. It also includes provisions for While the standard is effective as of December 2022, managing potential conflicts of interest as quickly and EY Nigeria has commenced work to implement the efficiently as possible using appropriate safeguards. new standard alongside EY’s System of Quality Such safeguards may include obtaining client consent Management transformation program. Our initial steps to act for another party where a conflict of interest have included: may exist, establishing separate engagement teams to • Identifying the functions and service lines that fall act for two or more parties, implementing “Chinese within the scope of ISQM 1 Walls” between engagement teams or declining an • Establishing a program governance structure to engagement to avoid an identified conflict. manage the design and implementation of a The EY global policy on Conflicts of Interest and system of quality management that complies with ISQM 1 with representatives from the various associated guidance consider the increasing functions and service lines complexity of engagements and client relationships, and the need for speed and accuracy in responding to • Identifying and assessing quality risks and documenting controls in accordance with the clients. They also align with the latest International network developed approach Ethics Standards Board for Accountants (IESBA) • Identifying network resources and requirements standards. and how they are implemented or used by the country in SQM Putting policy into practice • Identifying enhancements to the control We use the EY Process for Acceptance of Clients and framework and challenging current controls for Engagements (PACE), an intranet-based system, for compliance with the new standard efficiently coordinating client and engagement 12 | Transparency Report 2020: EY Nigeria
acceptance and continuance activities in line with entity we audit. Making risk assessments; global, service line and member firm policies. PACE reconsidering and modifying them as appropriate; and takes users through the acceptance and continuance using these assessments to determine the nature, requirements, and identifies the policies and timing and extent of audit procedures are fundamental references to professional standards needed to assess to EY GAM. The methodology also emphasizes both business opportunities and associated risks. applying appropriate professional skepticism in the execution of audit procedures. EY GAM is based on As part of this process, we carefully consider the risk International Standards on Auditing (ISAs) and is characteristics of a prospective client or engagement supplemented in Nigeria to comply with the local and the results of several due diligence procedures. Nigeria regulatory or statutory requirements. Before we take on a new engagement or client, we determine whether we can commit sufficient resources Using an online tool, EY Atlas, an EY auditor is to deliver quality service, especially in highly technical presented with a version of EY GAM organized by topic areas, and if the services the client wants are and designed to focus the audit strategy on the appropriate for us to provide. The approval process is financial statement risks, and the design and execution rigorous, and no new audit engagement may be of the appropriate audit response to those risks. EY accepted without the approval of Regional or GAM consists of two key components: requirements local PPD. and guidance; and supporting forms and examples. The requirements and guidance reflect both auditing In the EY annual client and engagement continuance standards and EY policies. The forms and examples process, we review our service and ability to continue include leading practice illustrations and assist in to provide a quality service and confirm that clients we performing and documenting audit procedures. serve share EY Nigeria’s commitment to quality and transparency in financial reporting. The partner in EY GAM can be “profiled” or tailored to present the charge of each audit, together with our Assurance relevant requirements and guidance, depending on the leadership, annually reviews our relationship with the nature of the entity being audited — e.g., there are audit client to determine whether continuance is profiles for listed entities and for those considered appropriate. non-complex entities. As a result of this review, certain audit engagements Following a successful pilot in 2019, EY GAM was are identified as requiring additional oversight updated to include the profession’s first data-first procedures during the audit (close monitoring), and approach to auditing, which is called Digital GAM. some audit clients are discontinued. As with the client Utilizing the suite of EY Helix analyzers, the flow of acceptance process, our PPD is involved in the client audit procedures, supplemented with new continuance process and must agree with the requirements and guidance, enhances the way EY continuance decisions. member firms perform audits. The EY audit approach combines the vast amounts of financial and non- Decisions about acceptance or continuance of clients financial data available from an entity’s systems with and engagements consider the engagement team’s broad sources of knowledge to enable EY auditors to assessment of whether the company’s management obtain sufficient and appropriate audit evidence. may pressure us to accept inappropriate accounting, Through visualizing whole populations of data and auditing and reporting conclusions to undermine applying professional skepticism, EY auditors can quality. Considerations and conclusions on the provide an additional challenge to management’s integrity of management are also essential to assertions to drive high audit quality. acceptance and continuance decisions. Other enhancements have been made to address new Performance of audits standards; emerging auditing issues and matters; implementation experiences; and external and internal There has been significant investment by EY in inspection results. Recently, EY GAM was updated for improving audit methodologies and tools, with the goal the requirements of ISA 540 (Revised), Auditing of performing the highest-quality audits in the Accounting Estimates and Related Disclosures profession. This investment reflects EY’s commitment (effective for audits of periods beginning on or after to building trust and confidence in the capital markets 15 December 2019) and a suite of enablement to and in economies the world over. implement those requirements was issued. Audit methodology In addition, current and emerging developments are monitored, and timely audit planning and execution EY GAM provides a global framework for delivering communications are issued that emphasize areas high-quality audit services through the consistent noted during inspections as well as other key topics of application of thought processes, judgments and interest to local audit regulators and the International procedures in all audit engagements, regardless of Forum of Independent Audit Regulators (IFIAR). size. EY GAM also requires compliance with relevant Specifically, with respect to the impact that COVID-19 ethical requirements, including independence from the is having on the global economy, guidance has been 13 | Transparency Report 2020: EY Nigeria
issued to address the accounting and financial through the analysis of larger populations of audit- reporting concerns that the entities EY member firms relevant data; identifying unseen patterns and trends audit are facing, as well as audit considerations when in that data; and helping to direct our audit efforts. performing audits in the current environment. The use of data analytics also allows us to obtain better perspectives; richer insights; and a deeper Technology understanding of transactions and areas of risk. Our audit engagement teams use technology to assist EY is deploying data analyzers to analyze the business in executing and documenting the work performed in operating cycles of the companies that we audit, accordance with EY GAM. supported by analytics-based audit programs to aid the application of these data analyzers. EY Canvas, the global EY audit platform, lies at the heart of the audit and enables us to provide a high- Using the EY Helix library of data analyzers, EY audit quality audit. EY Canvas is built using state-of-the-art engagement teams can enhance their audit risk technology for web applications. This allows us to assessment, enabling the audit of higher-risk provide data security and to evolve our software to transactions, and assisting EY people in asking better respond to changes in the accounting profession and questions about audit findings and evaluating the regulatory environment. outcomes. Through the use of profile questions, audit EY Atlas is a global technology platform that enables engagements in EY Canvas are automatically EY auditors to access the latest accounting and configured with information relevant to an entity’s auditing content, including external standards, EY listing requirements and industry. This helps to keep interpretations and thought leadership. our audit plans customized and up-to-date, and provides direct linkage to our audit guidance, Formation of audit engagement teams professional standards and documentation templates. EY Nigeria’s policies require an annual review of EY Canvas is built with a user interface that allows the partner assignments by our Assurance leadership and team to visualize risks and their relationship to the Regional or Cluster PPD as applicable. This is carried planned response and work performed in key areas. It out, among other things, to make sure that the also enables a linkage for group audit teams to professionals leading audits of listed entities and other communicate inter-office risks and instructions so that public-interest entities possess the appropriate the primary audit team can direct execution and competencies (e.g., the knowledge, skills and abilities) monitor performance of the group audit. to fulfill their engagement responsibilities and are in EY Canvas includes the My EY client portal to assist compliance with applicable auditor rotation teams in communicating with clients and streamlining regulations. their client requests. Mobile applications are The assignment of professionals to an audit integrated with EY Canvas to help our people in their engagement is also made under the direction of our audit work — e.g., in monitoring the status of the audit, Assurance leadership. Factors considered when capturing audit evidence securely and performing assigning people to audit teams include engagement inventory observations. size and complexity; specialized industry knowledge Audit engagement teams use other applications, data and experience; timing of work; continuity; and analyzers and forms during various phases of an audit opportunities for on-the-job training. For more to assist in executing procedures, making and complex engagements, consideration is given to documenting audit conclusions and performing whether specialized or additional expertise is analysis. This includes EY Smart Automation, a needed to supplement or enhance the audit collection of applications that are being developed and engagement team. deployed globally through EY Canvas to digitally In many situations, internal specialists are assigned as enable EY audit professionals in executing audit part of the audit engagement team to assist in procedures and processes. performing audit procedures and obtaining appropriate audit evidence. These professionals are used in situations requiring special skills or knowledge, Digital GAM and data analytics such as tax, forensics, information systems, asset At EY, we are making data analysis integral to our valuation and actuarial analysis. audits. Our use of data and analysis is not about additive procedures or visualizations. It is about taking Fraud large populations of company data and applying our Part of the EY commitment to quality is a policy of globally consistent technology (EY Helix) and continuous improvement, which has resulted in methodology (EY GAM) to audit that data. innovations to risk and audit procedures regarding EY Helix is a library of data analyzers for use in audits. fraud. These innovations include: These data analyzers are transforming the audit 14 | Transparency Report 2020: EY Nigeria
• Leveraging the power of advanced technology culture of consultation has become even more through: important to help EY member firms reach the • Mandating the use of data analytics for fraud appropriate conclusions for entities that they audit on testing a timely basis. Consultation requirements and related • Enhancing risk assessments and audit policies are designed to involve the right resources so scoping by using more external data and that audit teams reach appropriate conclusions. information, such as social media • Using electronic confirmations for audit evidence wherever possible, moving in time The EY culture of consultation enables to matching the audited company’s records of engagement teams to deliver seamless, banking transactions with those provided by consistent and high-quality services that the bank meet the needs of audited entities, their • Mandating annual forensics training for all audit governance bodies and all stakeholders professionals Review and consultation For complex and sensitive matters, there is a formal process requiring consultation outside of the audit engagement team with other personnel who have Reviews of audit work more experience or specialized knowledge, primarily EY policies describe the requirements for timely and Professional Practice and Independence personnel. In direct senior professional participation, as well as the the interests of objectivity and professional skepticism, level of review required for the work performed. EY policies require members of Professional Practice, Supervisory members of an audit engagement team Independence and certain others to withdraw from a perform a detailed review of the audit documentation consultation if they currently serve, or have recently for technical accuracy and completeness. Senior audit served, the client to which the consultation relates. In executives and engagement partners perform a this circumstance, other appropriately qualified second-level review to determine the adequacy of the individuals would be assigned. audit work as a whole and the related accounting and EY policies also require that all consultations are financial statement presentation. Where appropriate, documented, including written concurrence from the and based on risk, a tax professional reviews the person or persons consulted, to demonstrate their significant tax and other relevant working papers. For understanding of the matter and its resolution. listed and certain other companies, an engagement quality reviewer (described below) reviews important Engagement quality reviews areas of accounting, financial reporting and audit execution, as well as the financial statements of the Engagement quality reviews are performed by audit company we audit and our auditor’s report. partners in compliance with professional standards for audits of all listed companies, certain public-interest The nature, timing and extent of the reviews of audit entities and those considered to need close work depend on many factors, including: monitoring. Engagement quality reviewers are • The risk, materiality, subjectivity and complexity experienced professionals with significant subject of the subject matter matter knowledge. They are independent of the • The ability and experience of the audit team engagement team and provide an objective evaluation members preparing the audit documentation of the significant judgments the engagement team • The level of the reviewer’s direct participation in made, and the conclusions reached in formulating the the audit work auditor’s report. The performance of an engagement • The extent of consultation employed quality review, however, does not reduce the responsibilities of the partner in charge of the Our policies also describe the roles and responsibilities engagement for the engagement and its performance. of each audit engagement team member for In no circumstances may the responsibility of the managing, directing and supervising the audit, as well engagement quality reviewer be delegated to as the requirements for documenting their work and another individual. conclusions. The engagement quality review spans the entire Consultation requirements engagement cycle, including planning, risk assessment, audit strategy and execution. Policies and EY consultation policies are built upon a culture of procedures for the performance and documentation of collaboration, whereby audit professionals are engagement quality reviews provide specific guidelines encouraged to share perspectives on complex on the nature; timing and extent of the procedures to accounting, auditing and reporting issues. As the be performed; and the required documentation environment in which EY member firms work has evidencing their completion. In all circumstances, the become more complex and globally connected, the EY 15 | Transparency Report 2020: EY Nigeria
engagement quality review is completed before the For PIEs, the EY Global Independence Policy requires date of the auditor’s report. the lead engagement partner, the engagement quality reviewer and other audit partners who make key The Regional AMP (or Regional Audit Leader) and decisions or judgments on matters significant to the Regional or Cluster PPD approve all engagement audit (together, the “key audit partners”) to be rotated quality review assignments. after seven years. For a new PIE (including a newly listed company), key audit partners may remain in Audit engagement team resolution process for place for an additional two years before rotating off differences of professional opinion the team if they have served the company for six or EY has a collaborative culture that encourages and more years prior to the listing. expects people to speak up, without fear of reprisal, if Upon completing the maximum service period for a difference of professional opinion arises or if they rotation, a key audit partner may not lead or are uncomfortable about a matter relating to a client coordinate professional services to the PIE audit client engagement. Policies and procedures are designed to until after completing a cooling-off period. This period empower members of an audit engagement team to is five years for a lead audit engagement partner, raise any disagreements relating to significant three years for an engagement quality reviewer and accounting, auditing or reporting matters. two years for other partners subject to rotation. These policies are made clear to people as they join Where the required cooling-off period for the lead EY, and we continue to promote a culture that audit engagement partner established by the local reinforces a person’s responsibility and authority to legislative body or regulator is less than five years, the make their own views heard and seek out the higher of that cooling-off period or three years may be views of others. substituted for the otherwise required five-year Differences of professional opinion that arise during an cooling off period. This jurisdictional exception for audit are generally resolved at the audit engagement the lead audit engagement partner may only be team level. However, if any person involved in the applied for audit periods beginning prior to 15 discussion of an issue is not satisfied with the decision, December 2023. they refer it to the next level of authority until an In addition to the audit partner rotation requirements agreement is reached or a final decision is made. applicable to PIE audit clients, EY has established a Furthermore, if the engagement quality reviewer long association safeguards framework that, makes recommendations that the engagement partner consistent with the requirements of the IESBA Code does not accept or the matter is not resolved to the includes consideration of the threats to independence reviewer’s satisfaction, the auditor’s report is not created by the involvement of professionals over a issued until the matter is resolved. Differences of long period of time on an audit and a safeguards professional opinion that are resolved through framework to address such threats. consultation with Professional Practice are We employ tools to effectively monitor compliance appropriately documented. with internal rotation and requirements for audit Rotation and long association partners and other professionals who have had a long association with the audit client . There is also a EY supports mandatory audit partner rotation to help process for rotation planning and decision-making that reinforce auditor independence. EY Nigeria complies involves consultation with, and approvals by, our with the audit partner rotation requirements of the Professional Practice and Independence professionals.. IESBA Code, the Securities and Exchange Commission External rotation of Nigeria, and the Nigerian Code of Corporate Governance issued by the Financial Reporting Council For public interest entities, we comply with the of Nigeria, and other regulated industries requirement, external rotation requirements of Art. 17 (1) of the EU as well as the U.S. Securities and Exchange Audit Regulation. Commission (SEC), where required. EY Nigeria supports audit partner rotation because it provides a fresh perspective and promotes independence from company management, while retaining expertise and Audit quality reviews knowledge of the business. Audit partner rotation, The EY Global AQR program is the cornerstone of the combined with independence requirements, enhanced EY process to monitor audit quality. EY Nigeria systems of internal quality controls and independent executes the Global AQR program, reports results and audit oversight, helps strengthen independence and develops responsive action plans. The primary goal of objectivity, and are important safeguards of audit the program is to determine whether systems of quality. quality controls, including those of EY Nigeria, are appropriately designed and followed in the execution 16 | Transparency Report 2020: EY Nigeria
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