Internal Audit Ratings Guide

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    Internal Audit Ratings Guide

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    Table of Contents

    Audit Ratings Definitions 3

    Audit Report Ratings Matrix 4

    Audit Report Ratings Guidelines 7

    XYZ Audit Ratings 9

    Internal Control Option Criteria 12

    Audit Ratings Example 13

    Appendix 14

    A: Definition of Internal Audit Ratings and Rankings 15

    B: Rating of Audit Findings 17

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    Audit Report Ratings Matrix

    Rating

    Scale

    Description

    Effective

    1 Overall risk program is reliable and requires negligible improvements.

    The risk management procedures are formalized and documented and clearly communicated and

    understood throughout the business. Risk management system is robust and possesses the capacity and

    ability to consistently identify, document and assess existing and emerging risks.

    Risk controls effectively manage, mitigate and transfer existing and foreseeable risks and do not expose

    the business to undue risk. Risk program does not expose the business to unwarranted financial loss or

    regulatory non-compliance. Audit recommendations are generally housekeeping in nature.2

    Monitor

    3

    Overall risk program is adequate for the current level of risk within the business, but requires ongoing

    monitoring.

    The risk management procedures are formalized and documented, but not clearly communicated. Risk

    procedures need to be clearly communicated and business needs to obtain assurance that procedures

    are understood. Although the risk management system possesses the capacity and ability to identify,

    document and assess existing risk, specific improvements are needed to ensure accurate and timely

    incorporation of emerging risks.

    Risk controls adequately manage, mitigate and transfer existing risks but improvements are required as

    emerging risks and changing conditions could lead to a weakened risk management capacity. Risk

    program does not expose the business to immediate financial loss or regulatory noncompliance. The

    director must make improvements within 60 days.

    4

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    Audit Report Ratings Matrix

    Rating

    Scale

    Description

    Needs Improvement

    5

    Overall risk program is not adequate.

    The risk management procedures are partially formalized and documented, and not clearly

    communicated. Risk procedures require improvement to assure that risk processes are fully documented,

    and need to be clearly communicated. The business unit needs to obtain assurance that the risk process

    is understood.

    Risk management system requires improvement to ensure reliability of procedures to accurately and in a

    timely manner identify, document and assess existing and new risks. Controls require improvement to

    ensure ability of mechanisms to manage, mitigate, and transfer existing and emerging risks as changing

    conditions will possibly lead to a weakened risk management capacity. The line of business, withoutimprovements, is likely to be vulnerable to financial loss or regulatory noncompliance. Improvements are

    required within the next 30 to 60 days.

    6

    Impaired

    7

    Overall risk program is impaired.

    The risk management procedures are for the most part informal and undocumented, and not

    communicated. Risk procedures require improvement to assure that risk processes are fully and

    accurately documented, and must be communicated and understood by the business.

    Risk management systems require significant improvement to ensure reliability of procedures toaccurately and in a timely manner identify, document and assess existing and new risks . Controls require

    extensive improvements to secure ability to manage, mitigate, and transfer existing and emerging risks, as

    conditions will lead to a weakened risk management capacity. Risk program exposes the business to

    potential financial loss or regulatory noncompliance. Improvements are needed within the next 30 days.

    8

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    Audit Report Ratings Matrix

    Rating

    Scale

    Description

    Unsatisfactory

    9

    Overall risk program is not acceptable.

    The risk management procedures are largely nonexistent, undocumented and not communicated. Risk

    procedures must be instituted, formalized, documented and clearly communicated.

    Risk management systems must be implemented immediately to accurately and in a timely manner

    identify, document, and assess existing and new risks.

    Implementation of control mechanisms is required to manage, mitigate and transfer risks present in

    business processes and possess flexibility to react under changing conditions. The line of business is

    exposed to material financial loss or regulatory noncompliance. Improvements are needed within the nexttwo weeks and the audit committee must be made aware of improvements to be implemented.

    10

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    Audit Report Ratings Guidelines

    Rating

    Scale

    Description

    Effective

    1

    No high-risk issues

    No medium-risk issues

    No more than three low-risk issues

    2

    No high-risk issues

    No more than one medium-risk issue

    No more than six low-risk issues

    Monitor

    3

    No high-risk issues

    No more than three medium-risk issues

    No more than four low-risk issues

    OR

    No high or medium-risk issues and more than six low-risk issues

    4

    No high-risk issues

    No more than four medium-risk issues

    No more than six low-risk issues

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    Audit Report Ratings Guidelines

    Rating

    Scale

    Description

    Needs Improvement

    5

    No more than one high-risk issue

    No more than four medium-risk issues

    OR

    No high-risk issues and no more than six medium-risk issues

    6

    No more than two high-risk issue

    No more than six medium-risk issues

    OR No more than one high-risk issue and more than six medium-risk issues

    Impaired

    7 No more than three high-risk issues

    No more than four medium-risk issues

    8

    No more than three high-risk issues No more than six medium-risk issues

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    Rating

    Scale

    Description

    Unsatisfactory

    9

    More than four high-risk issues

    No more than six medium-risk issues

    OR

    No more than two high-risk issues and more than six medium-risk issues

    10

    More than four high-risk issues

    More than six medium-risk issues

    Audit Report Ratings Guidelines

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    XYZ Audit Ratings

    ST

    Strong

    Audited area meets or exceeds XYZ Comp anystandards in all critical respects. Level of internal controls is functioning effectively

    and efficiently. Information systems and user operations are integrated and support the business. Generally, no more than twolowobservations were noted.

    SA Satisfactory

    Audited area meets XYZ Companystandards overall. Generally, no more than two Importantobservations may exist which

    are being promptly addressed by management. A few Notableobservations may also exist.

    N

    Needs Improvement

    Audited area does not meet XYZ Comp anystandards overall. Generally, there is either at least one Highobservation and/or at

    least three Importantobservations, which if uncorrected could expose XYZ Companyto an unacceptable risk.

    U

    Unsatisfactory

    Audited area contains unacceptable gaps in overall control structure and/or controls are not working as intended. Generally, thereare at least one Highobservation and/or five Importantobservations. The area requires immediate attention with oversight

    by senior management.

    Business Importance Codes

    H High

    Risk involves a substantial and direct exposure to loss of assets and/or misstatement of financial information and/or loss of

    revenue and/or significant negative impact on operating effectiveness and/or the companys reputation . High likelihood and high

    impact.

    I

    Important

    Risk involves an unacceptable and direct exposure to loss of assets and or misstatement of financial information and/or loss of

    revenue and/or negative impact on operating effectiveness and/or the companys reputation. Moderate likelihood and moderate to

    high impact or high likelihood and moderate impact.

    N

    Notable

    Risk involves an important but indirect and limited level exposure to loss of assets and/or loss of revenue and/or negative impacton operating effectiveness and/or the companys reputation, which is outside of XYZ Companyrisk appetite. Low likelihood and

    moderate to high impact or moderate likelihood and moderate to low impact. This also includes low impact/high likelihood

    observations.

    L LowGenerally, issues classified in this category are brought to managements attention as an efficiency improvement. Low likelihood

    and low to moderate impact or low to moderate likelihood and low impact.

    Note:

    Each audit report observat ion is assig ned a priority rat ing to establish its level of crit icality. The rat ings are assigned co llaborat ively by internal audit and XYZ Comp any

    management respons ible for the process being audi ted.

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    XYZ Audit RatingsOverall Classif icat ions COSO

    F

    FinancialReporting

    Reliability of the financial reporting process

    O Operational Operational effectiveness and efficiency

    C Compliance Compliance with applicable laws and regulations

    S StrategicHigh level goals, aligned with and supporting the mission of

    XYZ Comp any

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    Internal Control Option CriteriaBased on th e results of the audit, the system of internal con trols w il l be rated as Strong, Satisfactory,

    Unsatisfactory, or Crit ical based on the fol low ing c riter ia:

    Rating Definition

    Strong Satisfactory Unsatisfactory Critical

    No issues. Issues are not likely to impair

    business operations or jeopardize

    financial integrity.

    Significant issues exist.

    Corrections required to avoid or

    contain exposure. Prompt action is required.

    Significant issues find/ indicate

    processes/results are unreliable.

    Impact of weaknesses is likelywidespread/ compounding.

    Immediate attention required.

    Attributes of Control Environment

    Strong Satisfactory Unsatisfactory Critical

    Control processes/monitoring are

    effective.

    Control processes/monitoring are

    effective for key cycles/functions.

    Control processes/monitoring have

    weaknesses/are not effective.

    Control monitoring is not in place

    or is extremely unreliable.

    Low potential for undetected errors

    and omissions.

    Major issues would likely be

    detected.

    Major issues may not be detected

    and corrected.

    Very high potential for

    losses/undetected errors and

    omissions.

    Compliance with company policy,

    GAAP.

    Policy and GAAP complianceissues have no material impact on

    operations or financial statements.

    Policy or GAAP non-compliancecould (or do) have material impact

    on operations/ financials.

    Policy or GAAP non-complianceissues are severe, pervasive, and

    material to operations/financials.

    Financials/results are reliable;adjustments not necessary.

    Financial adjustments, if any, areminor.

    Material financial adjustments maybe required.

    Financials/results are likelyunreliable. Major problems exist.

    No regulatory compliance issues. Regulatory compliance issues, if

    any, are minor and isolated.

    Regulatory compliance issues may

    show signs of being systemic.

    Compliance issues are significant

    and carry severe consequences

    (fines, sanctions, etc.)

    No risk to CBI image. Issues carry low level of (or no)

    risk to CBI image.

    Issues may carry potential for

    damage to CBI image.

    Issues may carry severe risk of

    damage to CBI image.

    No ethics issues.

    Ethics issues, if any, are minor

    and management takes timely,

    appropriate corrective actions.

    Ethics issues not addressed

    appropriately and/or management

    does not set the appropriate tone.

    Ethics issues not addressed

    appropriately and/or management

    does not set the appropriate tone.

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    Audit Ratings Example

    Rating

    Definition

    Satisfactory

    The audited area has effectively assessed its risks, implemented control processes, andcomplied with applicable policies, procedures, and appropriate laws and regulations. We mayhave noted a few inconsistencies, but compensating controls exist that sufficiently minimizethe risk of loss.

    GenerallySatisfactory

    The audited area has adequately assessed its risks, and has implemented generally effective

    control processes. We may have noted some weaknesses in controls, but they are not such

    that the audited area is significantly exposed to risk of loss. Such audited areas are in general

    compliance with applicable policies, procedures, and appropriate laws and regulations.

    Marginal

    The audited area has control, policy, procedural, compliance and/or repeat findings that are

    sufficiently important to warrant the attention of more senior levels of management. Any

    deterioration in the current operating routine could lead to serious exposures and regulatorycriticisms.

    Unsatisfactory

    The audited area has serious control, policy, procedural, compliance and/or repeat findings.

    Losses may not yet be realized, but exposure to potentially serious loss may exist. Exposuremay also exist to potentially serious criticism by regulators. Such situations require urgent

    action and senior management involvement in implementing corrective action.

    Unrated This rating is generally reserved for first time audits, limited scope audits and special projects.

    Audit rat ings are assigned based on the fo l lowing def in i t ions:

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    APPENDIX

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    Appendix A: Definition of Internal Audit Ratings and RankingsDefinit ion of Review Ratings

    Adequate

    There are no identified issues that have either a Medium or High ranking.

    There may be a limited number of issues with a Low ranking and/or other observations for potential improvement.

    Needs Improvement

    There are one or more identified issues with either a Medium or High ranking.

    A deficiency or combination of deficiencies impact the design and/or operating effectiveness of control for the area under review to the extent

    that required control objectives may not be consistently achieved.

    The deficiency or combination of deficiencies impact the companys ability to provide reasonable assurance over the effective design and/or

    operation of control thus affecting the companys risk exposure within the area being reviewed .

    The deficiencies merit prompt attention and remediation by management to improve the overall design and/or operating effectiveness of control

    for the area under review, in order to meet required control objectives.

    Inadequate

    There are one or more identified issues with either a Medium or High ranking.

    A deficiency or combination of deficiencies significantly impair the design and/or operating effectiveness of control for the area under review to

    the extent that required control objectives may not be consistently achieved.

    The deficiency or combination of deficiencies significantly impact the companys ability to provide reasonable assurance overthe effective

    design and/or operation of control thus affecting the companys risk exposure within the area being reviewed .

    The deficiencies merit immediate attention and remediation by management to improve the overall design and/or operating effectiveness of

    control for the area under review, in order to meet required control objectives.

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    Definition of Internal Audit Ratings and RankingsDef in i t ion o f Issue Rankings

    HIGH

    The issue is a control deficiency which represents a significant gap in the design and/or operating effectiveness ofcontrol affecting the companys ability to address relevant risks and provide reasonable assurance regarding the

    achievement of desired outcomes.

    The issue requires an immediate, comprehensive, corrective action plan with progress to be monitored by an

    appropriate level of management.

    MEDIUM

    The issue is a control deficiency which represents a gap in the design and/or operating effectiveness of control

    affecting the companys ability to address relevant risks and provide reasonable assurance regarding the

    achievement of desired outcomes.

    The issue requires prompt attention to ensure internal control is designed and/or operating effectively.

    LOW

    The issue represents an opportunity to improve control and processes to support the achievement of desired

    outcomes.

    The issue should be addressed promptly, as time and resources permit.

    Considerable professional judgment is required in applying the ratings defined and used in this report regarding

    individual f indings, recommendations and in form ulating and overal l conclusion. Acco rdingly, others could rate the

    findings or con clusion differently and this should b e born in mind when cons ider ing this report.

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    Appendix B: Rating of Audit Findings

    Rating Categories Risk/Impact Explanation

    Need for Action and

    Responsible Function Reporting Obligations

    Particularly Severe (A)Risks threatening the existence of the

    organization, e.g.:

    Fatal material losses

    Image loss/publicly effective impact

    (massive loss of customers)

    Violation of regulatory requirements

    (and possible revoking of the

    operating license)

    Urgent remediation by the

    management board required,

    immediate involvement of the

    supervisory body

    Monitoring of timely

    remediation by internal audit

    ("follow- up)

    Refer to reporting obligations for Major (C)

    and Severe (B) findings, and:

    Immediate notification of the

    supervisory body by the management

    board

    Severe (B) Critical risks for business continuity,

    e.g.:

    Very high material losses (losses

    are not detected timely)

    Image loss/ publicly effective

    impact (adversely affects the

    image on the market)

    Violation of regulatory

    requirements (and possible

    criminal liability, etc.)

    Immediate remediation by the

    management board required

    (immediate involvement of the

    supervisory body and the

    supervisory authorities in

    case of severe findings

    against management board

    members)

    Monitoring of timelyremediation by internal audit

    ("follow- up)

    Refer to reporting obligations for Major

    findings (C) and:

    Immediate submission of the internal

    audit report to the management

    board

    Immediate notification of the

    chairman of the supervisory body and

    the supervisory authorities by the

    management board in case of severefindings against management board

    members

    At least annual reporting from the

    management board to the

    supervisory body (highlighted

    findings, including remedy measures

    taken and their implementation

    statuses)

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    Appendix B: Rating of Audit Findings

    Rating Categories Risk/Impact Explanation

    Need for Action and

    Responsible Function Reporting Obligations

    Major (C) High risks for business continuity, e.g.:

    High material losses (if weaknesses

    are not remedied timely)

    Image loss (many internal and

    external parties are affected)

    Violation of regulatory requirements

    (and possible fines, etc.)

    Remediation required, close

    supervision by the responsible

    member of the management

    board

    Monitoring of timely remediation

    by internal audit ("follow- up)

    Highlighted in the internal audit report

    Included in the (annual) overall internal

    audit report to the management board

    (including remedy measures taken)

    Reported to the supervisory body by

    the management board at least

    annually, if not remedied

    If not remedied within an appropriate

    period, the responsible member of the

    management board has to be informed

    in writing. If the findings remain

    unresolved during the financial year,

    the management board has to be

    informed in writing in the next (annual)

    overall internal audit report, at latest.

    Improvement

    Opportunity (D)

    Medium risks for business continuity, e.g.:

    Medium material losses

    Image loss (internal, some external

    parties are effected, if applicable)

    Non-compliance with/implementation

    of certain regulatory requirements

    Implementation of certain

    improvement measures

    recommended

    Monitoring by the head of the

    audited organization unit;

    immediate involvement of the

    management board is not

    required

    Monitoring of timely remediation

    by internal audit ("follow- up)

    Included in the internal audit report

    Not included in the (annual) overall

    internal audit report

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    Appendix B: Rating of Audit Findings

    Rating Categories Risk/Impact Explanation

    Need for Action and

    Responsible Function Reporting Obligations

    Comment (E) Low or no risks

    "Food for thought" for

    improvement/further development

    Decision on prioritization and

    implementation of measures

    remains in the audited

    organizational unit

    Monitoring by the head of the

    audited organization unit;

    involvement of the management

    board is not required

    Not included in the follow-up

    by internal audit

    Summarized in the internal audit report

    or in a separate management

    summary/memo

    Not included in the (annual) overall

    internal audit report