Education of Principle Based Auditing. Reference to concepts from Code of Ethics Paul Hurks
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1 Education of Principle Based Auditing Reference to concepts from Code of Ethics Paul Hurks
2 Principle based Auditing Principle-based regulation for auditing: Public interest Professional Accountant Code of Ethics Clarified ISAs ISQC1
3 Public Interest IFAC/PIOB-search for a definition in the context of: Legitimacy Independence Transparency Performance (competence, efficiency) Accountability
4 Professional Accountant IFAC definition (draft): The term PA describes a person who has expertise in the field of accountancy, achieved through formal education and practical experience and who: demonstrates and maintains competence complies with a code of ethics is held to a high professional standard, and is subject to enforcement by a PAO (= IFAC MB) or other regulatory mechanism; PAs can be differentiated from one another by certain factors such as competence, responsibilities and services provided.
5 Code of Ethics Fundamental Principles: Integrity Objectivity Competence & Due Care Confidentiality Professional Behaviour (and Independence)
6 Code of Ethics Conceptual Framework: Case Fundamental Principles Threats Negligible? Safeguards Evaluation Documentation
7 Code of Ethics Evaluation: (A ) In excercising professional judgment, a professional accountant should consider what a reasonable and wellinformed third party, having knowledge of all relevant information, including the threats and safeguards applied, would conclude to be (un)acceptable.
8 Clarified ISAs (IAASB) Standards for Auditing & Assurance: An audit is an audit Principle-based standards Requirements to interprete in a case-systemic way Tailor made application
9 ISQC1 (IAASB) Standards for Quality Control: Control: firms are required to design and implement a system of Quality Control, tailor made, self generativing improvements. Quality: audit quality is/should be measured in terms of public interest (society interest / macro perspective). Clientsatisfaction is of minor importance. Important elements: Moral imagination Professional skepticism
10 Moral imagination Moral imagination entails the ability to consider a situation from the perspective of various stakeholders; it is the ability to discover and evaluate possibilities within a particular set of circumstances by questioning and expanding one s operative mental framework (Werhane/Moriarty 2009, DePaul University Chicago)
11 Moral imagination Examples Enron Enron moved certain assets and liabilities belonging to high risk activities offbalance sheet through SPE-transactions; collateral was not properly disclosed. Worldcom Managers followed instructions to make improper accounting adjustments repeatedly during three years, thus creating fraudulent accounting records, in order to help the company leaders convince Wall Street investors and analysts that it had met the quarterly earnings numbers executives had prediceted/announced, even though they knew it was dishonest and a an absurd way of doing business. Lehman Brothers etc, etc, etc, Often heard quotes: All this was not illegal
12 Moral imagination Examples
13 Moral imagination In the concept of moral imagination we try to discover our restrictions in thinking, considering, reasoning in the context of our: existing framework (historical / organisational / cultural), social roles (historical / organisational / cultural), as these provide a degree of predictability of human behaviour (compare: eyepiece of a telescope) Because of existing frameworks/social roles: people tend to appeal to dominant narratives people tend to adapt to groupthink people tend to seek evidence that reinforce facts people tend to confuse reality with what they want it to be people tend to overestimate powers and abilities people tend to be obedient to organisational authority
14 Moral imagination Crises may be unavoidable, disasters are not! Do not look just through the telescope! Detect the tremors before the earthquake! Avoid the blind spot! Moral imagination must go hand in hand with moral reasoning, enabling people to contextualise potential scenarios, desicions and its consequences in terms of values, principles and norms for.*) ( *) auditors:... = public interest) Moral imagination, 3 characteristics: 1. Particular situation, practice (not general) 2. Disengage existing framework, extend/adapt in a meaningful way 3. Viable and realistic (no ideals, fantasies)
15 Professional Skepticism Professional Skepticism (ISA-definition): An attitude that includes a questioning mind, being alert to conditions which may indicate possible misstatements due to error, fraud and a critical assessment of audit evidence (Quadackers 2009) Degree of skepticism: too little skepticism endangers effectiveness too much skepticism endangers efficiency The famous view underligned: The auditor should be a watchdog, not a bloodhound The initial mindset is described as presumptive doubt
16 Professional Skepticism Professional Skepticism Considerations Phases: skeptical thinking (phase 1) > education! skeptical behaviour (phase 2) > education! Origin?: innate acquired > education! cultural differences (e.g. Japan) > education! Initial mindset for individuals is not likely to be equal: incentives (personal, organisational) characteristics (curiosity, mindset) knowledge > education! experience and training > education!
17 Professional Skepticism, model Nelson (2009) Input Findings Skeptical Thinking Skeptical Behaviour Output Findings Incentives Characteristics Knowledge Experience and Training
18 Professional Skepticism Professional Skepticism Considerations Anectotal evidence exists that auditors become more professional skeptical after they have been personally involved in an investigation, failure or liability. Evidence that education provides curiosity and a questioning mind (academic level), new recruits demonstrate this trait significantly more than their former generation superiors. Appropriate personal qualities is best achieved through junior staff working closely with more experienced staff and partners that already have the right qualities. Reviewees experience the concept of professional skepticism when it is a priority attitude of the reviewer, when the review is performed at the job, and when review notes are retained after the review for monitoring purposes. The proportion of audit time spent by staff sitting in the audit room completing electronic schedules has increased at the expense of time spent by reviewing client records, client discussions and obtaining evidence. There is evidence that client cooperation-arrangements are a disincentive for professional skepticism as cooperation and trust are mutually reinforcing conditions. Two vital ingerdients of an audit understanding the business - requirement and trust are pulling in different directions. Judgement short-cuts are usually causes by bias and framing, which is a lack of moral imagination
19 Professional Skepticism Audit regulators Audit regulators have reported lack of professional skepticism on an international basis; relevant elements: Recruitment, education, training, promotion Audit methodology Elements in principle-based regulation: Code of Ethics ISQC1 ISAs (200, 240, 250, 260, 265, 320, 315, 330, 450, 500, 520, 530, 540, , 570, 505/580, 600/610/620) Mandatory audit team meetings Governance Codes ( tone at the top ) Liability-regulation
20 Professional Skepticism What can be done to promote auditor professional skepticism? Education: mindset, attitude, public interest, awareness of individual/ collective professional responsibility, practice examples, train moral imagination; Firms, big & small: culture, recruiting, promotion, incentives, training on the job, macro-responsibility, governance code; Audit regulation: visualize in documentation, reviews, monitoring, liability; Ethics regulation: rotation, audit only, cooling down; Guidance: war stories and success stories from whistleblowers, lessons learnt; Audit inspection: PAO, regulator; Clients, big & small: culture, CSR, governance, audit committee; Academia: further research.
21 Thank you for your attention.
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