Directive 4.25
Directive 4.25
CA
                                                                                                         PAKISTAN
Chartered Accountants
      of Pakistan                                                                                           HEAD OFFICE
Directive 4.25
      IFAC's SMO-1 Quality .Assurance requires that a mandatory quality assurance review system should
      be in place for firms performing Audit, Assurance and Related Services to ensure that the firms
      and its partners comply with all applicable professional standards with particular emphasis on
      strengthening the quality of audit assignments. Similar programs for ensuring quality of practice
      are followed by institutes globally including those operating in Bangladesh, Sri Lanka, UK and
      Malaysia.
      ICAP already runs a Quality Control Review (QCR) Program under QCR framework since 2003.
      The QCR framework covers firms that are engaged in statutory external audits of:
      Now the Institute is introducing 'Audit Practice Review & Support Program'                   for all the Non-
      QCR rated firms engaged in Audit, Assurance and Related Services.
The APRS Program approved by the Council, after due process, is attached herewith. It outlines:
      Chartered Accountants   Avenue, Clifton, Karachi-75600    (Pakistan).   Ph: (92-21) 111-000-422,   Fax: 99251626
                                  Website: www.icap.org.pk.     E-mail: info@icap.org.pk
AUDIT PRACTICE REVIEW &
  SUPPORT PROGRAM
TABLE OF CONTENTS
  Part - VI     Appeal
    6.1         Appellate Forum                                                 27
    6.2         Filing of Appeal                                                28
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Preamble/Background
Building public trust in the work performed by practicing members is one of the key
priorities of the Institute, therefore, improvements in the existing practice regime is
also one of the strategic objectives approved by the Council of the Institute.
Accordingly, the Council of the Institute decided to introduce this ‘Audit Practice
Review & Support Program’ to ensure maintenance of quality standards of the
professional practices. This will ensure that the work carried out by practicing
members complies with Professional Standards and is in accordance with the
directives of the Council and other laws, regulations and pronouncements of
professional bodies as applicable in Pakistan.
The ‘Audit Practice Review & Support Program’ provides the application of best
practices followed by professional institutes around the world. The ‘Audit Practice
Review & Support Program’ will run in parallel with the Quality Control Review
(QCR) Program and firms which have attained satisfactory QCR rating under the
QCR program of the Institute are excluded from the ambit of the ‘Audit Practice
Review & Support Program’.’.
The key features of the ‘Audit Practice Review & Support Program’ are as follows:
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(i) Review of engagements to ensure that Audit, Assurance and Related Services
   rendered by firms, comply with the Chartered Accountants Ordinance, 1961,
   Chartered Accountants Bye-Laws, 1983, Professional Standards, Training
   Regulations and Directives of the Council of the Institute;
The Council believes that the effective implementation of the Program will go a long
way in the development of the profession.
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PART I – SCOPE, DEFINITIONS AND
           OBJECTIVES
                              Page 5 of 34
1.1.   Scope
       The ‘Audit Practice Review & Support Program (APRSP, the Program)
       applies to all firms providing Audit, Assurance or Related Services conducted
       under legal and financial reporting framework as applicable in Pakistan.
1.2. Definitions
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1.2.4. “Committee” means the ‘Members Affairs Committee’ formed by the
      Council of the Institute;
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1.2.12. “Re-Review” means re-review conducted as prescribed under
      paragraph 4.3.1(c) of this Program on the direction of the Committee
      on some or all of the aspects covered in clause 1.3.1;
Any term not defined under this Program shall have the same meaning as
prescribed in the Chartered Accountants Ordinance, 1961 (here-in-after
referred to as ‘the Ordinance’) or the Chartered Accountants Bye-Laws, 1983
(here-in-after referred to as ‘the Bye-Laws’) or any other Directive or
pronouncement of the Institute.
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1.3.   Objective of the APRSP
1.3.1 The objective of the Program with respect to a firm is to ensure that:
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PART II - SELECTION AND ARRANGEMENT
              OF REVIEWS
                               Page 10 of 34
2.1.   Firms subject to Practice Review
       2.1.2. Where the name of the firm is appearing in the list of firms having
             satisfactory QCR rating, that firm shall be excluded from the purview of
             this Program. If the name of the firm is removed from the list of firms
             having satisfactory QCR rating, that firm shall be subject to this
             Program if it does not apply for review under the QCR Program within
             one year from the date of removal from the list of firms having
             satisfactory QCR rating.
       2.1.3. A firm may apply for an exemption from Practice Review by filing an
             Exemption Form in a prescribed format with the Director of Practice
             Review certifying that:
2.2.2. A firm, already in practice on the Effective Date of the Program and in
      which at least one member is engaged in providing Audit, Assurance
      or Related Services shall be subject to Practice Review at any time
      after one year of effective date of the Program and thereafter, every
      two and a half years from the date of its last Practice Review. However,
      the Director of Practice Review may, on special request of the firm,
      grant an extension in the Practice Review for a period not exceeding
      three months, from the date the Practice Review is due to commence.
      Every firm shall ensure that all members engaged in providing Audit,
      Assurance or Related Services shall be subjected to Practice Review
      at least once within a period of five years. However, any delay on the
      Part of Directorate of Practice Review to commence, conduct or
      complete the Practice Review during the stipulated time shall be
      excluded from this period.
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      of this clause, the term “change” means:
       2.3.1. The Director of Practice Review shall serve a notice to a Firm indicating
              that Practice Review of the firm is due.
       2.3.2. The firm shall complete and file a Planning Questionnaire, in a format
              prescribed by the Committee, with the Director of Practice Review
              within 30 days of the notice issued under paragraph 2.3.1.
       2.3.4. The Director of Practice Review shall give notice in writing in a form to
              be prescribed by the Committee giving the name(s) of the assigned
              Reviewer(s) and the commencement date of a firm’s review.
       2.3.5. The notice shall be served upon the firm at least 30 days prior to the
              commencement date or such shorter period as may be mutually agreed
              by the firm and the Director of Practice Review.
       2.3.6. Within 15 days of receipt of the notice pursuant to section 2.3.4, the
              firm may file an objection in writing to the named Reviewer(s) for any
              other valid reason.
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PART III - DIRECTORATE OF PRACTICE
                REVIEW
                               Page 15 of 34
3.1.   Establishment of the Directorate of Practice Review (DPR)
       There shall be a DPR in the Institute for carrying out the activities and
       functions under the Program. The DPR shall be headed by a Director
       or Senior Manager, Practice Review appointed by the Council as it may
       deem appropriate. There will be other staff and reviewers appointed by
       the Committee. The reviewers shall be appointed as full time practice
       reviewers.
3.2.1. The Director of Practice Review shall have the following functions and
       responsibilities:
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                  f) to maintain record of all reviews, by name of the firm, partner,
                     location, period covered, date of review etc.
                                                                          Page 17 of 34
PART IV -THE REVIEW PROCESS AND
             REPORT
                             Page 18 of 34
4.1.   Review Process
       4.1.2. On the commencement date of the Practice Review, the Reviewer shall
             attend at the office of the Firm, or any other location as may be agreed
             with the firm. In conducting the Practice Review, the Reviewer shall
             consider:
                                                                         Page 19 of 34
              h)    Compliance with CPD program/directive of the Institute.
       4.1.3. The Reviewer shall select two engagement files to be reviewed for each
             partner or sole proprietor engaged in audit, assurance and related
             services of the firm. However, the Reviewer may, if deemed necessary,
             select additional files to be reviewed with reasons to be recorded in
             writing duly concurred by Director of Practice Review. The Reviewer
             shall consider the following factors regarding selection of files:
       4.1.4. The Reviewer shall use a Practice Review checklist duly approved by
             the Committee to ensure that requirements of the Program have been
             met. The format of the checklist shall be placed on the Institute’s
             website for the information of members of the institute.
       4.2.1. At the conclusion of the Practice Review, the Reviewer shall prepare a
             draft report within 30 days, setting out Reportable Deficiencies and
             Non-Reportable Matters.
       4.2.2. After completion of the review, the Reviewer shall discuss the
             Reportable Deficiencies, if any, in the draft report with a representative
             of the Firm and may revise the draft report.
       4.2.3. The Director of Practice Review shall discuss the draft report with the
             Reviewer to ensure that all Reportable Deficiencies have been
             adequately identified and appropriately reported and the draft report
             conforms to the requirement of the Practice Review.
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       4.2.4. The Director of Practice Review may also discuss the report with the
              Firm.
       4.2.5. On conclusion of the review by the Director of Practice Review, the draft
              report will be delivered to the firm for comments to be provided within
              21 days.
       4.2.6. The Director of Practice Review or a Reviewer may require the firm to
              provide written confirmation of any actions planned by the firm to
              address deficiencies.
       4.2.7. If the Firm disagrees with a Reportable Deficiency listed in the report,
              it may provide explanation and documentation to support its position.
       4.2.8. The Director of Practice Review or a Reviewer may amend the draft
              report as appropriate, taking into consideration any matters arising from
              paragraph 4.2.3 to paragraph 4.2.7, concluding with recommendations
              as to a course of action and submit the final report to the relevant bench
              of the Committee for review.
       4.3.1. The Committee shall consider the report and matters pertaining to the
              Practice Review, or of a Re-Review, and may take one or more of the
              following actions:
4.3.2. The Committee shall not refer a matter to the Investigation Committee
      or Secretary solely for the failure of a firm or a member, to produce a
      document subject to a valid claim of legal privilege that has not been
      waived.
                                                                    Page 22 of 34
4.3.3. In determining the action to be taken pursuant to paragraph 4.3.1, the
      Committee may consider, but will not be limited to, the following
      matters:
e) public interest;
4.3.5. The Investigation Committee and the Council shall proceed on the
      recommendation of the Committee referred to in sub clause 4.3.1(e) in
      accordance with the provisions of investigation envisaged in the
      Ordinance and Bye-laws of the Institute.
4.3.6. The Committee shall ensure that its decision pursuant to paragraph
      4.3.1(e) is communicated in writing to the firm or member through
      Director of Practice Review within fifteen days from the date of such
      decision.
                                Page 24 of 34
5.1.   File Retention
       5.1.1. Any file created during a Practice Review shall be retained until the
             Practice Review has been deemed complete by the Committee and
             thereafter for a period of twelve months after the conclusion of Practice
             Review Year in which the Practice Review was completed. However,
             if a firm or a member makes an appeal under this Program against the
             decision of the Committee, all files and documentation relevant for the
             Practice Review shall be retained by the Firm, and the Institute till the
             case attains finality or for a period of twelve months as described above
             whichever is later.
5.2. Confidentiality
       5.2.1. A member of the Committee, or any person acting on its behalf, or the
             Director of Practice Review or any Reviewer, or a staff member of
             Directorate of Practice Review, shall not make use of or disclose the
             contents of any report, files, working paper files, books, documents or
             other material reviewed, or any confidential information concerning the
             affairs of any firm or a member or of its clients obtained in the course
             of a Practice Review to anyone, except to the Director or Directorate of
             the Practice Review, the Committee, the Appellate Forum and or the
             Council as required under this Program.
                                                                          Page 25 of 34
PART VI - Appeal
                   Page 26 of 34
6.1 - Appellate Forum
6.1.1 Two Appellate Forums (the Forum) shall be constituted by the Council under
      the Program to provide grievance mechanism to firms or members not
      satisfied with the outcome of the Practice Review, one each for the Northern
      and Southern Regions.
6.1.2 The Forum shall comprise three members appointed by the Council, of which
      two shall be from the members of the Institute who have been past members
      of the Council and have served at-least one full term in the Council and one
      shall be a person who has exercised the powers of, or has been, a judge of a
      High Court or who is or has been, an advocate of a High Court and is qualified
      to be a Judge of a High Court. Such person shall also act as Chairman of the
      Forum.
6.1.3 The members of the Committee or of the Council shall not be nominated on
      the Forum. A cooling off period of two years shall be required for eligibility to
      be appointed at the Forum for the former members of the Committee or of the
      Council.
6.1.4 The quorum for a meeting of the Forum shall be the majority of its members.
      In case the Chairman is unable to attend the meeting, the members present
      shall decide amongst themselves a person to act as Chairman at that meeting.
6.1.5 The term of the Forum shall be three years from the date of its constitution.
6.1.6 No member of the Forum shall serve for more than two consecutive terms of
      two years each.
6.1.7 A member retiring after serving two consecutive terms shall be eligible for re-
      appointment, after two years from the date of retirement.
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6.2 Filing of Appeal
6.2.1 Any member or a firm aggrieved by the decision of the Committee shall have
      a right to appeal before the Forum within 30 days of such decision having been
      communicated to the member or the firm, on the prescribed form and
      accompanied by such documents and information as may be prescribed.
6.2.2 The Forum shall, at the request of the applicant, or on its own motion give a
      personal hearing to the aggrieved member or authorized representative of the
      firm, who must either be a lawyer or a member of the Institute.
6.2.3 The Committee shall authorize any of its members or any representative to
      attend the hearing on its behalf.
6.2.4 Director of Practice review is also entitled to attend the hearing of the Forum,
      if he so desires;
6.2.5 The Forum shall have the power to confirm, vary or reverse the original
      recommendation/decision of the Committee that has been appealed. The
      Forum can also remand the case to Director of Practice Review with
      directions;
6.2.6 The decision of the Forum shall be final which shall be communicated to the
      appellant with a copy to the Director of Practice Review and the Chairman of
      the Committee.
6.2.7 The Forum shall preferably dispose of the appeal within 60 days from the date
      of filing of appeal.
6.2.8 During the process of appeal, the Forum can grant relief to the firm or member
      suspending the decision of the Committee.
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PART VII - MISCELLANEOUS
                           Page 29 of 34
7.1 Failure to Comply
7.1.1 Failure to comply with any provision of this Program, including a failure to
       comply with any decision or requirement of the Committee, can be referred to
       the Investigation Committee of the Institute under Section 20A of the
       Chartered Accountants Ordinance, 1961.
7.2.2 The Council may provide guidance on matters not specifically covered under
       this Program.
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PART VIII – SUPPORT BY THE INSTITUTE
                                Page 31 of 34
   8.1   TECHNICAL HELPLINE
          A Technical Helpline has been established on the Institute’s website, where
          members can post their queries in relation to financial reporting, auditing or
          ethics related matters. Guidance will also be provided through this helpline in
          respect of matters arising from the provisions of this Program. The Helpline
          may      be     accessed       by     visiting    the     Institute’s       website
          http://www.icap.net.pk/your-technical-helpline .
1. When the firm shall be subject to Practice Review under this program?
   A firm, already in practice on the effective date of this program and in which at least
   one member is engaged in providing Audit, Assurance or Related Services shall be
   subject to Practice Review at any time after one year of effective date of this program.
   The program applies to all firms providing Audit, Assurance or Related Services
   conducted under legal and financial reporting framework as applicable in Pakistan.
5. Does this program conflict with the existing QCR program of the Institute?
   No, this program shall not be applicable to the firms which have attained satisfactory
   QCR rating under the QCR program of the Institute.
6. What if the name of any firm is removed from the list of firms having
   satisfactory QCR rating under the QCR program of the Institute?
   If the name of the firm is removed from the list of firms having satisfactory QCR rating,
   that firm shall be subject to this Program if it does not apply for review under the QCR
   Program within one year from the date of removal from the list of firms having
   satisfactory QCR rating.
   The Members’ Affairs Committee may with the approval of three-fourth majority of its
   members, refer the case to the Investigation Committee of the Institute where the
   member has continuously failed to implement the action plans and improve the
   standard of work after two Re-Reviews. The Members’ Affairs Committee may also
   report to the Investigation Committee any other matter relating to non-compliance
   with professional standards.
8. What if the firm is restricted to produce any document to the Institute due to
   absence of consent from its client?
   The Committee shall not refer a matter to the Investigation Committee or Secretary
   solely for the failure of a firm or a member, to produce a document subject to a valid
   claim of legal privilege that has not been waived.
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   “Technical Helpline” is available on the Institute’s website for providing guidance on
   professional and other matters relating to the Program. Members can post their
   queries on the Helpline.
10. Whether an appeal can be filed against the decisions made under this
    program?
11. What is the timeline to file an appeal before the Appellate Forum?
   Any member or a firm aggrieved by the decision of the Committee shall have a right
   to appeal before the Forum within 30 days of such decision having been
   communicated to the member or the firm.
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