How Far Should We Go to Ensure Independence and Objectivity?

Richard Chambers, CIA, CGAP, CCSA, shares his personal reflections and insights on the internal audit profession.

I am not sure if it is my imagination, but the topic of internal auditor independence seems to be picking up steam — especially outside of North America. In the past week, I have commented on the topic twice in my blog (Don’t Confuse Independence With Objectivity, and What Would It Take to Make You More Assertive?).

Lately each time I think I’ve heard a pretty radical idea put forward for enhancing internal audit independence, someone comes along and tops it. I am still attending the Asian Confederation of Institutes of Internal Auditors (ACIIA) Conference in Sydney, Australia. Yesterday, a straw poll revealed a substantial majority of those attendees responding felt they would be more assertive if they were not hired or funded by management of their companies. I thought that was a pretty alarming message for those of us who are advocating that internal auditors can be objective in carrying out their responsibilities in an “independent” internal audit function.

In one of today’s sessions, a noted panelist was asked by the moderator if he felt that internal auditors should be prohibited from owning shares in the company for which they work and audit. To my utter amazement, the panelist quickly expressed the view that such prohibitions should be imposed. In his view, internal auditors should be subject to the same limitations of ownership as the external auditors.

Given that a substantial portion of my career was in the public sector or a “Big Four” accounting firm, I have never owned shares of stock of an enterprise for which I had internal audit responsibilities. However, I would staunchly defend the propriety of corporate internal auditors to do so. As I commented in my earlier blog, internal auditors are not independent of their companies. Until they are hired, evaluated, and compensated by someone completely outside of their company, they will never be totally independent. However, they have an obligation to maintain their objectivity, and that objectivity must be fostered by organizational reporting relationships that enhance the independence of the internal audit activity.

I fear that precluding internal auditors from owning stock in their companies would not foster objectivity — it would foster ambivalence. As a federal Inspector General in the U.S. government, I possessed legislated independence that most internal auditors could only dream of. It would have been easy to become totally disassociated from my agency. Yet, I worked tirelessly to ensure that I did not lose sight of the fact that the agency’s success was an important outcome of the work of my organization.

If internal auditors were forced to divest themselves of their shares of stock in their companies, I shudder to think of the perception it would create among members of their board and management. It would create an extra burden as they sought to overcome the perception that they no longer care about the company’s performance. It would also remove an important connection that internal auditors have with their organizations. In the final analysis, I believe that precluding internal auditors from holding an ownership interest in their organizations is not a prudent solution to perceived objectivity impairments.

I would be interested in your views.

 

Posted on May 11, 2010 by Richard Chambers

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  1.  

    Richard, I agree that prohibiting an internal audit from owning shares in the company for which they work and audit is not a prudent solution.  I also think that this is contrary to the views of the Board of Director community that encourages Board members to have an equity interest in the organizations in which they provide risk oversight.  One of the unique commonalities between the Board and the Internal Auditors is their "Independence" from management responsibility and operation that allows for "objectivity," in their judgment.          

          

     

     

       

  1. The issue about independence is exacerbated when organisational complexity increases, leading to the real need for 'in house' understanding of the organisation in order to deliver meaningful reports. Without this, the result is a 'reliance on compliance' which does little to help understand the risks to effectiveness. The biggest problem is that we are trying to deliver using tools that were designed for the 19th century. There is clear need to think holistically about what auditing is aiming to achieve and then review the tools available to deliver this. Relying on traditional tools, processes and procedures plus auditor integrity and independence will always be open to criticism - especially as we move from compliance into effectiveness and business risk auditing To deliver on independence and objectivity requirements, we need to split the auditing process into two distinct parts - collection of evidence and analysis of evidence. Collection of evidence, for compliance and especially for effectiveness, requires a true picture being created of what is actually happening, day-in and day-out, which is where independence is really needed - if you don't get the true picture, the rest is not worth doing. Getting a picture of compliance is fairly straightforward, providing sampling is good, but getting a picture of effectiveness and risk (to continuing compliance and delivery of business objectives) is much more difficult - but this is what is now expected of auditors. This is the area where new tools are required- something we have been working on for a number of years. Once a truly independent picture of the current reality is obtained, there is a need for objectivity in interpreting it in terms of business risk. Only if we are willing to take a fundamental look at how we do our work will we will be able to square this circle.
  1. I agree that the common connection of the ultimate success of the Company helps to ensure that Internal Auditors have a unique position to engage with management. After a career in Big 4 public accounting, I would question that same assumption about external auditors. How can external auditors ever be **paid** to issue an independent opinion about a company -- much less negotiate about any potential management letter comments (unless you consider the PCAOB for public company audits an effective deterrent)? There is, however, a fundamental difference between internal and external auditing. I don't think that removing an equity interest while retaining the organization's ability to compensate internal auditors would make internal auditors any more effective. It could in fact, as Richard pointed out, have the opposite effect.
  1. Let us begin with the axiom that objectivity is a state of mind. Surely then, dispassion would be an ingredient to attain objectivity and passion otherwise. If only because passion is universally known to affect judgement which flows from objectivity.   

    Why allow a bias (even a positive one) to cloud the judgement of an internal auditor when lack of passion allows him to consider events in the context of a by-stander rather than motivate him to do right by his side (in this case his company) ?

    Notions of morality hinder judgement (there are enough instances of juries confirming to the moral order of the day, to give an analogy) and ownership somehow conveys the image that an internal auditor would (sub-conciously at least) would start viewing events as they roll out as affecting him or her. 

    This, would result in avoidable bias and hence may be avoided at all costs 

     

  1. Although an interesting discussion, I have doubts that the reason  a substantial majority of the conference attendees responded that  they would be "more assertive if they were not hired or funded by management of their companies" is that they shouldn't own stock in their companies.  It seems more likely that the attendees are noting that reporting "administratively" to management is problematic as relates to their independence, objectivity and "assertiveness."   I do think that internal auditor independence and objectivity would be strengthened if the IIA took a stronger position, and asserted for example, that Internal Auditors must report functionally and adminstratively to the board of directors - i.e. hiring, firing and funding decisions related to the internal audit department and the CAE must be made by the board of directors (the same as they do for the CEO).  This position would be the gold standard for ensuring internal auditor independence, objectivity and "assertiveness" and anything less (although probable in many companies), should be noted by the IIA as potentially hazardous to stakeholders.   

  1. I concur with comments from Balu and Mark. There have been a lot of discussions regarding the reporting structure of IA in publicly traded companies.

    I have always felt, that IA should be reporting administratively and functionally to the Audit Committee and the CFO should be reporting to the Board and not the CEO. The right corporate governance structure should produce a healthy tension between organizations. An effective oversight function cannot exist, if there is an in-built conflict in reporting relationships.

    I agree with Mark that IIA should take a stronger position regarding reporting structures and call it "Best Practices".

    Thanks,

    Saty

  1.  If you either love or hate your company, you are not objective.   If you stand to benefit or be harmed from stock price fluctuations you are neither independent nor objective.   If your annual bonus is tied to short term company performance you are neither objective nor independent.  If you have any skin in the game whatsoever, you are not objective.   If you have to speculate that auditors should ignore the obvious vested interests and be "objective" then they are not objective nor independent.

  1. Richard
     
     I'm afraid I need to disagree with you.  The Standards are not on your side of the discussion. The IIA Standards discuss Organizational Independence and Individual Objectivity. Independence is considered an attribute of the audit department position within the organizational structure while Objectivity is an attribute of the auditor. The Standard goes on to state that the "internal auditor should have an impartial, unbiased attitude and avoid conflicts of interest."  Similarly, The Governmant Auditing Standards (GAGAS) also considers avoiding conflicts of interest whether in fact or in appearance as apart of their Objectivity standard.  GAGAS goes on to list a direct financial interest  as a personal impairment. I therefore feel that corporate internal auditors should not allowed to own stock in the companies they audit.
  1. Richard, I do agree with you that precluding internal auditors from owning shares in the company they work for is not a prudent solution to perceived objectivity impairments. I agree that independence is not to be confused with objectivity. But on the issue about whether or not internal auditors should own shares in the company they work and audit leads me to consider what Beni has pointed out that the standards does require independence in fact and in appearance. Having worked with the internal audit, I am aware that the department can be perfectly objective despite its staff owning shares in the company; but as pointed out, IA is not totally independent of the company. How far should we go to ensure independence and objectivity? It is as far as maintaining independence in fact and in appearance to the extent of compliance to financial interest issues. However, considering the views and circumstances surrounding the position of the internal auditors; is it not worth that the body comes to survey to further tackle the issue, as there maybe a need to distinguish between external and internal auditors. Thank you
  1. Where will this argument end?  How about internal auditors should not be compensated at all by the compay that employs them.  If the company does well, you have a job.  If it does poorly, you are laid off.  Of course, this is ludicrous.  If you are a part of a company, you should be able to participate in the bonus plan when good performance warrants.  You should also suffer the consequences of less than good performance.  Seems to me management is looking for a function that will help them improve their performance and not someone who thinks they need to be the second coming of the external auditor.

  1. I believe we are lost in nuance to some extent, and like Mark Thornton noted there may be a potential misreading of Auditors perspective.

    In my mind our primary niche is composed of information provided to governance that allows them to more effectively fulfill their roles and responsibilities. While we do many things, the provision of this primary service does require independence and objectivity. Let's imagine a future where the internal audit products have become so mature that standard reporting to governance is developed based on best practices. The market begins to value the IA standard risk management report so much that regulators began to mandate them. At that point in time a discussion like this will need to take place. However, today with IA still maturing towards providing consistent risk management information to governance I would label this conversation as pre-mature. 

  1. hey

    i need your help.

    which one is the correct answer

     

    18. which is not an attribute of an external auditor

    a. independence

    b. client advocacy

    c. objectivity

    d. concern for the public interest.

  1. I have been doing some research on this topic.  I am the bookkeeper for a public company.  Am I allowed to purchase stock?

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