AUDIT REPORTING
Today’s audit reports need
to boil away the unessential
to quickly get to what’s
important to stakeholders.
                  Norman Marks
                  Illustration by Sean Yates
A
                  company president once told me shortly after I joined the
                  organization that he didn’t understand why he was receiving
                  copies of internal audit reports. He didn’t understand how
                  they were relevant to his work. He had better uses of his time
                  than reading our reports.
                       He is not alone. Drew Stein, a board member and former
                  CEO in New Zealand, has written, “Almost all of internal
                  audit findings are mundane operational compliance issues.”
                       When organizational leaders don’t see value to them in
                  what internal auditors share — even questioning whether
                  they should waste their time reading audit reports — some-
                  thing is wrong and change is needed. These leaders will only
                  see value if internal auditors’ communications are about
                  issues that matter to them and to the organization’s success,
                  and provide clear, concise, and actionable information. In
                  other words, auditors must provide them with the informa-
                  tion they need to be effective leaders.
                       In an era of dynamic change, organizations and the
                  managers who run them are also changing how they moni-
                  tor and run the business. In particular, they must be ready to
                  make decisions quickly because risk and opportunity don’t
                  wait for them. A decision delayed is often a decision that is
                  made by a competitor.
                       In many ways, the internal audit profession has chal-
                  lenged many of its traditional, tried-and-true methods and
Information
Distillation
24 INTERNAL AUDITOR                                                                APRIL 2018
APRIL 2018   INTERNAL AUDITOR 25
                                                                                     TO COMMENT on this article,
INFORMATION DISTILLATION                                                             EMAIL the author at norman.marks@theiia.org
principles to meet these changing stake-        a few tests. You wait. Then you wait         a glance whether there was anything
holder demands. One thing that hasn’t           some more. Eventually, a nurse appears.      they needed to worry about. It gave
changed is that many internal auditors          You run to her and ask, “How is she?         them the assurance they needed to
are still communicating their findings          Will she be OK?”                             rely with confidence on the controls
through a traditional audit report, and               The nurse hands you a binder and       around derivatives trading risks.
that may not be sufficient. They may            says, “Here’s the doctor’s report.”                If we identified significant internal
not realize that the International Stan-              You raise your voice. “Is she OK?”     control weaknesses, we did more than
dards for the Professional Practice of Inter-         The nurse smiles and informs you       rely on a rating system. The cover note
nal Auditing does not require a formal,         that there is an executive summary on        would have one sentence that described
written audit report. Standard 2400:            page 3 where you will find the informa-      them at a high level. The executive
Communications requires that “Internal          tion you need.                               summary would explain how enterprise
auditors must communicate the results                 The leaders of the organization,       objectives might be affected.
of engagements.” The Standards require          internal audit’s stakeholders, are not             Going back to the story about the
communication, and internal auditors            that different. They want to know            sick child, if you opened the report to
should consider how they can communi-           whether everything — the people, pro-        the executive summary and it said your
cate effectively.                               cesses, and systems relied on to manage      child’s condition was “needs improve-
      The traditional audit report and its      risks — is going to be all right (assur-     ment,” would that be acceptable? Would
standard format tell stakeholders what          ance). They also need to know what           it provide the assurance you need or the
auditors want to say, rather than telling       they need to do (advice and insight).        information you need to care for her?
stakeholders what they need to know.                  They don’t need to know:
A more effective audit communication                  » Why internal audit did the           WHAT DO YOU MEAN?
tells leaders what they need to know,                    audit. They need to know the        After I left Tosco, I joined Solectron
when they need to know it, in a form                     results and why they matter, not    Corp., a global electronics manufactur-
that is not only readily understand-                     the audit planning process. The     ing company. My first task as CAE was
able but actionable by them. In other                    results will include assurance on   to review and approve the audit report
words, internal auditors should provide                  specific risks and objectives.      for our audit of the Shenzhen, China
stakeholders with the information they
need to be effective. At the end of an
audit engagement, the auditor should
consider what information — assurance,
                                                   If the executive summary said your child’s
insight, and advice — will help stake-
holders lead the organization to success.
                                                   condition was “needs improvement,”
What are their challenges, and how can
internal audit help deal with them?
                                                   would that be acceptable?
WHAT STAKEHOLDERS                                     » How internal audit performed         facility. My predecessor had developed
NEED TO KNOW                                            the work.                            an audit report format that led with the
Your young child comes to you cry-                    » Background information that          results presented in a table. There was a
ing in the night and tells you she has a                they should already know and         row for each area of risk that had been
tummy ache. Her head seems warm but                     is not relevant to the assurance,    included in scope, with an assessment of
she doesn’t have a high temperature, so                 advice, and insight internal         the related controls — using a red, yel-
you bring her into bed with you and                     audit is sharing.                    low, green color-coding system — and
she comfortably cuddles up. But soon                  » Details that are being handled       the number of significant findings.
she starts crying and curls up into a                   appropriately at lower levels of           In the draft audit report I reviewed,
fetal position. “Mommy, daddy, it really                the organization.                    the assessment for every area of risk was
hurts!” she cries. This time when you           The “Cover Note Example” on page             “red,” and the paragraph directly below
touch her head, it is hot, and you decide       27 accompanied an audit report to            the table started with, “The system of
to take her to the emergency room.              stakeholders at Tosco Corp. when I           internal controls at the Shenzhen facil-
      Fortunately, she is seen quickly          was the company’s chief audit execu-         ity is not adequate. Significant improve-
by a doctor, who says he needs to run           tive (CAE). The note showed them at          ments are required.”
26 INTERNAL AUDITOR                                                                                                           APRIL 2018
Internal audit  communications                     “must be accurate, objective, clear,             concise,
constructive, complete, and timely,” according to Standard 2420: Quality of Communications.
   COVER NOTE EXAMPLE
   The note below — originally a hard copy, later in an email — was attached to an audit report
   sent to executive management and the audit committee at Tosco Corp.
   January 15, 1995
   Audit of Derivatives Trading
   » Are there any risk issues of significance to the audit committee or executive manage-
      ment? YES/NO
   » Are there any outstanding major internal control findings meriting audit committee or
      executive management attention? YES/NO
   Distribution:
   Audit Committee
     I called Audrey, the audit director   and objectives. It told the executive,           » Helps them identify and then
for Asia Pacific and Japan and a direct    in clear and readily understandable                  take the necessary and appro-
report to me. “Audrey, what does this      language, that the plan to move                      priate actions.
mean?” I asked. Her reply was, after       production from other locations to          For example, our report following an
a moment’s hesitation, “Norman, the        Shenzhen would probably fail. That          audit of the process for reviewing and
internal controls are not adequate.” I     assessment was then followed with           approving capital expenditure requests
repeated my question and she repeated      advice on the changes necessary to          at Tosco led with an opinion statement:
her answer.                                address the situation. We changed the       “The Authorization for Expenditure
     “Audrey, imagine that as you are      audit report to lead with the effect on     process does not meet the needs of the
getting on the elevator on the fourth      the business and its strategy. We used      organization. Decisions are not timely
floor of the corporate office in Singa-    the language of the business to share       and, as a result, business opportunities
pore, you see Chester, the president       our assurance, advice, and insight,         are lost — rendering null the original
and CEO for Asia Pacific and Japan.        rather than the language of internal        business justification.”
He asks you, ‘What do I need to know       audit (risk and controls).                       The first words used the language
about your audit of Shenzhen?’ I want           The senior management team             of the business to highlight the fact
you to call me tomorrow and tell me        and the board are focused on execut-        that business objectives likely were not
what you would say, recognizing that       ing on and achieving their strategies       being achieved. The opinion contin-
you only have until the elevator reaches   and objectives. Internal audit may          ued by saying that capital decisions
the ground floor.”                         know how internal control and risk          might be delayed to the extent that
     Audrey called me the next day.        management deficiencies may affect          revenue opportunities were lost. The
“I would tell Chester that ‘the con-       those goals, but unless auditors say        audit report went on to explain what
trols in Shenzhen will not be able to      more than “the system of internal           was happening, gave an example of a
support the 30 percent expansion           control is not adequate,” there is          missed opportunity and the cost to the
in manufacturing capacity planned          no assurance that management will           business, and how management had
for later this year,’” she said. Instead   appreciate what the audit results           agreed to address the issue. This report
of blandly saying that controls were       should mean to them.                        prompted change.
inadequate, or even that the listed             Internal auditors need to com-
areas of risk were outside acceptable      municate the results of their audits in a   HAVE A DISCUSSION
levels, Audrey was giving executive        way that:                                   Many internal audit departments track
management actionable information               » Makes it clear which enterprise      and report to their audit committee
that would help it run the business                objectives might be affected        the number and aging of outstand-
successfully. This advice and insight              and how.                            ing audit recommendations. One of
was based on an understanding of                » Explains which risks to objec-       the reasons management often fails to
the organization’s strategies, plans,              tives are outside desired levels.   take all the necessary actions promptly
APRIL 2018                                                                                              INTERNAL AUDITOR     27
                                                                           VISIT our mobile app + InternalAuditor.org to watch an
                                                                           interview with Norman Marks on ensuring stakeholders
INFORMATION DISTILLATION                                                   receive the information they need from internal audit.
is that internal audit and operating         Internal auditors should realize that              When there is more to say than
management do not have a common              their final product is not really the         “everything is fine,” a face-to-face
understanding of the potential effect        audit report and its recommenda-              conversation with management can
on enterprise objectives.                    tions — it’s the change that they             be the best communication method,
      Some auditors talk about internal      enable. Informing executive manage-           especially in private when difficult top-
audit having to “sell” its audit findings.   ment and the board that internal              ics can be discussed candidly. The most
They complain when management is             audit and management have agreed on           effective communications result in a
reluctant to make the change they rec-       defined actions is far better than shar-      shared understanding, and this is best
ommend. But perhaps management is            ing internal audit’s recommendation           achieved when both sides not only talk
right! Maybe the risk is one they should     and management’s response.                    and listen, but ask questions to make
be taking on business grounds, or there                                                    sure they understand the other fully.
is a better way to address the issue.        BEYOND THE REPORT                             This is the path to effective change
      Rather than writing a recommen-        The Core Principles for the Professional      and delivering the full value of internal
dation and asking for a management           Practice of Internal Auditing talks about     audit to management.
response, internal audit departments         sharing not only assurance and advice,             A meeting or a phone call also
                                                                                           may be essential if issues are serious
                                                                                           and need to be addressed promptly. If
   Internal auditors need to communicate                                                   the risk is significant, it doesn’t make
                                                                                           any business sense to delay corrective
   in a way that is easy to receive, absorb,                                               action for weeks while the audit report
                                                                                           is being drafted.
   and act on the information.                                                             FORMS OF COMMUNICATION
                                                                                           Internal auditors need to communicate
should sit down with operating man-          but insight. Every good internal audi-        in a way that is easy for the individual
agement and discuss:                         tor has opinions that go beyond what          with whom they desire to communicate
     » Do we agree on the facts?             is typically included in the formal audit     to receive, absorb, and act on the infor-
     » Do we agree that there is a           report. These may be of great value to        mation they need. Every CAE should
        risk to one or more enterprise       management — if management gets to            take full advantage of modern commu-
        objectives?                          hear them. For example, the audit team        nication methods as well as embrace the
     » Do we agree on the significance       may have thoughts on:                         oldest way to communicate — talking
        of the risk?                              » The competence of the man-             and listening.
     » What is the root cause of the                  agement team and staff.                   CAEs should understand how
        problem?                                  » Teamwork and morale in the             each of their key partners in manage-
     » Should the risk be accepted or                 area audited.                        ment and on the board likes to receive
        action taken to minimize it?              » The level of resources available       information, especially the informa-
     » What are the options and                       to the team (people, budget,         tion they want to get from internal
        which is best?                                systems, computers, etc.).           audit. These days, executives receive
     » Will the actions bring the risk            » The ability of the team to             most of their information in dash-
        to an acceptable level?                       deliver optimal performance.         boards and similar forms, as well as
     » What is a reasonable time             At the same time, management may              in meetings and emails. CAEs should
        frame within which to com-           have questions on these or similar top-       consider asking that the CEO’s and
        plete the corrective actions, and    ics and may welcome the opportunity           chief financial officer’s (CFO’s) daily
        who will own each task?              to ask for the audit team’s thoughts.         dashboards or metrics include a sec-
A constructive, open discussion with         Often, these insights are at least as valu-   tion that highlights audit-related issues
management — where everybody is              able as the assurance and recommenda-         meriting that executive’s attention.
listening and working toward the             tions for change included in the audit        Sometimes, that is enough.
shared objective of enabling enterprise      report. But there has to be an opportu-            If the executive needs to know
success — is far more likely to result       nity for management to hear and dis-          that the audit engagement confirmed
in the change necessary for success.         cuss the insights of the audit team.          that controls over a specified risk are
28 INTERNAL AUDITOR                                                                                                       APRIL 2018
How   auditors           communicate results         “may vary     based on the organizational structure,
type of internal audit, and related recommendations,” according to The IIA Practice Guide, Audit Reports.
working effectively, then that can be            Communications should start early           The audit report has value in
communicated with a descriptor and a        and be frequent. If internal audit finds   enabling a discussion with senior man-
green light. If controls are not adequate   something that appears problematic         agement and the board — although
and the CEO’s or CFO’s attention is         during the audit engagement, it should     serious issues should be communicated
necessary, a red light replaces the green   be talking about it, and listening, to     promptly in person or by phone. In
one with a link to the details, which       management straight away.                  some industry sectors, the report is nec-
may be the audit report in full or abbre-        The closing meeting at the end of     essary to meet the requirements of the
viated form.                                fieldwork is an excellent opportunity      regulators. But rather than considering
                                            for sharing, not only by the inter-        the audit report to be the primary com-
LISTEN AND ASK QUESTIONS                    nal audit team but by management.          munication vehicle in every case, internal
As a CAE, I told my internal audit          The meeting should conclude with           audit should adapt to its stakeholders’
teams that I don’t ever want them to        a shared understanding of the facts        needs for assurance, advice, and insight.
“go and talk” to somebody. I want them      and issues, the risks they represent to    When internal audit provides the execu-
to “go and listen.” If they are talking     enterprise objectives, and the actions     tive team and the board with the infor-
more than 40 percent of the time, they      that everyone agrees should be taken.      mation they need, when they need it,
are talking too much. Internal audit’s      If internal audit has done that well,      to run the organization successfully, it is
communications should provide its           the audit report simply becomes an         optimizing its value.
audience, its stakeholders, with the        after-the-fact summary. Even if there
opportunity to listen actively — to ask     is no formal audit report, everybody       NORMAN MARKS, CRMA, CPA, was a
questions and to discuss the situation      should be assured that all issues will     CAE and chief risk officer at major global
and its implications.                       be addressed appropriately.                corporations for more than 20 years.
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APRIL 2018                                                                                                INTERNAL AUDITOR 29