The Role of Internal Audit in CSR Reporting Practices and the Ethical Considerations

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    The Role of Internal Audit in CSRReporting Practices and the Ethical

    Considerations

    Barry Ackers

    University of South Africa

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    Presentation Structure

    Introduction

    King III

    Accountability

    Corporate Social Responsibility

    CSR Assurance

    Ethical Dilemmas

    Ethics & Morality

    Ethical Theories

    Ethical dissonance Empirical research

    Conclusion

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    King III in South Africa

    King Code of Governance for South Africa 2009 (King III) 1st March 2010

    Voluntary on an apply or explain basis.

    Principle 9.3 Sustainability reporting and disclosure should be

    independentlyassured

    But recommended practice 3.4.4 requires the audit committee to

    recommend the board to appoint an external assurance provider on

    material sustainability issues

    JSE regulations 7.F.5 and 8.63 JSE-listed companies should adopt King III

    Principle 7.1 requires the board to ensure that there is an effective risk-

    based internal audit activity

    Recommended practices 7.2.2. & 7.5.1.requires internal audit to beindependent and objective

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    King III (cont.)

    1.3. The board should ensure that the companys ethics are managed effectively

    1.3.1. build and sustain an ethical corporate culture 1.3.2. determine clearly articulated ethical standards which should ensure

    that measures are taken to achieve adherence throughout the business

    1.3.3. measure adherence to ethical standards

    1.3.4. internal and external ethics performance is aligned around the same

    ethical standards

    1.3.5. ethical risks and opportunities are incorporated in the risk

    management process

    1.3.6. implementation of a code of conduct and ethics-related policies

    1.3.7. compliance with the code of conduct is integrated into the operations

    1.3.8. the companys ethics performance should be assessed, monitored,

    reported and disclosed.

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    SIGMA Management Framework

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    CSR means different things to different people

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    What is CSR?

    Triple bottom line Business ethics

    Environmental responsibility Corporate giving

    Corporate social performance Sustainable development

    Corporate sustainability Corporate governance

    Corporate citizenship Corporate social investment

    Corporate accountability Corporate philanthropy

    Environmental, social & governance Community relations

    Corporate community involvement Community affairs

    Community development Corporate ethics

    Stewardship Responsible business

    Global citizenship Corporate societal marketing

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    The Triple Bottom Line

    Corporate governance is concerned with holding the balancebetween economic and social goals and between individual andcommunal goals the aim is to align as nearly as possible the

    interests of individuals, corporations and society.Sir Adrian Cadbury

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    There is no way to avoid paying serious attention to corporate citizenship: the costs

    of failing are simply too high... There are countless win-win opportunities waiting to

    be discovered: every activity in a firms value chain overlaps in some way with socialfactors everything from how you buy or procure to how you do your research

    yet very few companies have thought about this. The goal is to leverage your

    companys unique capabilities in supporting social causes, and improve your

    competitive context at the same time. The job of todays leaders is to stop being

    defensive and start thinking systematically about corporate responsibility.

    The CSR Business Case

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    The Global Reality USA resource consumption = 6 planets (WWF 2006)

    UK resource consumption = 3.1 planets (NEF 2006) RSA resource consumption = 1.2 planets (WWF 2006)

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    What is Corporate Social Responsibility?CSR is still evolving no universally accepted definition

    Sustainable development is described as development meeting the needs of the

    present without compromising the ability of future generations to meet theirown needs.

    Generally, CSR is understood to be the way firms integrate social, environmental

    and economic concerns into their values, culture, decision making, strategy and

    operations in a transparent and accountable mannerand thereby establish

    better practices within the firm, create wealth and improve society.Business has an ethical responsibility to contribute to economic development

    while simultaneously improving the quality of life of its workforce, their

    families, the local community and society at large

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    Purpose of CSR reports

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    What Matters and to Whom?

    Stakeholders Human Rights Technology Legislat ion Economic Safety Environmental

    Customers

    Community

    Environmentalists Regulators

    Unions

    Employees

    Media

    Competitors

    Impacts

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    Its about Balancing interests

    + - + +

    - - - +

    + - + +

    - - - +

    + - + +

    - - - +

    Social Benefit

    Profitability

    End of the line

    Keep right on truckin

    Lots of horsepower,

    no fuel

    Rolls Royce for the few

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    Eells Continuum of Social Responsibility

    Direction ofmaximumresponsibility

    Direction ofminimumresponsibility

    TRADITIONALCORPORATION

    Economic Man

    SOCIAL/METROCORPORATIONWhole Man

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    Theoretical Frameworks

    Shareholder primacy

    Stakeholder theory

    Instrumentalism

    Legitimacy

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    The Need for Assurance

    How do stakeholders receive confidence about the veracity of CSR

    reporting

    The board of directors

    King III

    International Standards for the Professional Practice of Internal Auditing

    Standard 2010 Planning risk-based audit plans Standard 2060 Reporting to Senior Management and the Board must

    also include significant risk exposures and control issues

    Standard 2110 Assess and make appropriate recommendations for

    improving governance process Standard 2120 Evaluate the effectiveness and contribute to the

    improvement of risk management processes.

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    Benefits of Independent CSR Assurance

    Assurance provides a monitoring mechanism to address agency problem

    Assurance strengthens accountability while reinforcing trust and confidence in

    corporate reporting

    Statutory (financial) information is more credible than voluntary non-financial

    information, since the former is subjected to audit, and the latter is usually not

    Reduces the risk of greenwash

    Improves the public perception (reputation management) about the reporting

    company activities

    Improves CSR-related controls and reporting systems

    Enhances CSR report content;

    Assists with legislative and regulatory compliance

    Assists in risk identification and management Reduces the risk of substantial remediation costs, penalties and litigation

    Facilitates eligibility for CSR reporting awards or schemes

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    Measurable standards to assess CSR performance

    Collection, evaluation and reporting of non-financial information

    Competent assurance team

    Independence and objectivity

    Plan should cover all sites and operations

    CSR progress report

    Publication of engagement results to affected stakeholders

    Characteristics of CSR Assurance

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    Internal audit

    An independent, objective assurance and consulting activity designed to add

    value and improve an organizations operations. It helps an organizationaccomplish its objectives by bringing a systematic, disciplined approach to

    evaluate and improve the effectiveness of risk management, control, and

    governance processes.

    Focuses on internal and not external stakeholders

    Risk-based audit approach (IIA Standards and King III)

    The internal audit activity must be independent and objective (Standards)

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    Ethical Dilemmas

    Steven Covey Train journey

    Bowen McCoy The Sadhu

    Nike Bangladesh

    Ok Tedi BHP

    Groucho Marx

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    Morals and ethics

    Used interchangeably

    Synonymous Linguistic difference

    Morality the collection of moral principles guiding individual choices,

    decisions and actions

    Ethics the cognitive, analytical, systematic, and reflective application of

    moral principles

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    Ethics The study of ethics involves the disciplined enquiry into the basis of morality

    and law

    Ethics provides the basis of for choosing between right & wrong; good & bad;acceptable & unacceptable actions

    Economic CSR ethicality is based on compliance with the law

    Moral CSR how society and the environment are treated

    Situational ethics and relativity

    Characteristics of ethics includes:

    Honesty

    Fairness

    Prudence

    Respect for and service to others

    Keeping promises

    Being truthful

    Developing business relationships based on trust and integrity

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    Ethical decision-making theories Utilitarianism (maximising satisfaction, individual rights and justice)

    Deontology (principle of generalisability) Contractualism (agreement by individuals concerned)

    Virtue ethics (in the context of personal relationships)

    Consequentialism (principle of maximisation)

    Egoism (self-interest)

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    Ethics of CSR Changing paradigm requires deliberate moral

    and ethical decisions

    Voluntary nature of King III apply or explain Two paradigms :

    Empiricism the is of economic affairs

    Instrumental reasons: engaging in CSR

    for the companys benefit

    Normativism what organisations

    ought to do

    Moral reasons: the right thing to do

    Corporate ethical responsibility along a

    continuum of: Mandatory compliance: legal & regulatory

    Desirable philanthropy: prudent or

    voluntary

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    Ethical approaches to management Immoral management decisions and actions in conflict with societys ethical

    norms

    Regulation is an impediment to the achievement of objectives

    Moral management ethical behaviour complying with societys norms

    Consider both the letter and spirit of the law

    Amoral management may be oblivious to impacts of their decisions on

    others

    Guided by the letter of the law

    Includes a group who believe that their ethical decisions affect their

    personal and not business lives

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    Leadership ethics Ethical behaviour is not exerted by the

    corporation, but by individuals

    King III principle 1.1 requires the board toprovide effective leadership based on an

    ethical foundation

    Therefore initiated according to the

    character of the corporate leadership

    The board and the CEO determinecorporate values

    Set the tone at the top

    Walk the talk since employees emulate

    management behaviour

    Ethical trap management must choosebetween behaving ethically and

    succumbing to the situational pressures

    towards engaging in unethical practices

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    Altruism & Philanthropy Altruism voluntary contributions to society (possibly uncompensated or

    costly)

    Philanthropy discretionary transfers of wealth to stakeholders

    Economic CSR

    Discretionary altruism ill disciplined managers violating theirfiduciary responsibilities

    Prudent altruism strategically controlling intrusive public policy

    Ethical CSR

    Altruism is both socially desirable and morally commendable

    Instrumentalism transforms philanthropy beyond prudent altruism intostrategic tool to develop legitimacy, enhance corporate reputation &exploit market opportunities

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    Ethical dissonance

    Hard choices are often not between good

    and bad but between good and good

    or bad and bad

    Good people will do bad things, when

    facing threats to their livelihood

    Individuals may hold particular beliefs, but

    may act in ways that are inconsistent with

    their personal values

    Even the most morally upright individuals

    could display dishonest tendencies under

    certain circumstances

    70% of 6 000 managers and executives had

    experienced pressure to conform and

    compromise their personal values

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    Research Approach & Methods

    Objective to establish the role of the internal audit activity in

    CSR assurance (in the context of the King III requirement forindependent CSR assurance)

    Although primarily conceptual it includes two empirical mixed

    methods phases

    Content analysis of annual/sustainability reports Survey responses

    Purposive sample of the top 200 JSE-listed companies

    (market cap)

    53% of companies

    99% of market capitalisation

    Primarily interpretative and therefore not generalisable.

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    Types of CSR Assurance Providers (content)

    78%

    62%

    56%

    5%

    4%

    5%

    4%

    6%

    2%

    2%

    2%

    2%

    17%

    24%

    30% 2%

    0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

    2007/8

    2010/1

    2011/2

    Assurance by a Big 4 audit firm Assurance by a Mid tier audit firm

    Joint assurance by two Big 4 audit firms Assurance by an internal audit activity

    Joint assurance by Big 4 audit firm & CSR Consultancy Assurance by a specialist CSR assuror

    Assurance by a certification body

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    CSR Assurance Provision 2007 2012 (content)

    -

    10

    20

    30

    40

    50

    60

    2011/2 2010/1 2007/8 UK Japan Australia Germany USA

    50

    40

    18

    26%

    21%

    9%

    57%

    29%

    12%11% 11%

    Number of CSR assurance reports Percentage

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    Important CSR assurance elements (survey)

    95%

    92%

    90%

    90%

    90%

    84%

    79%

    5%

    8%

    5%

    5%

    7%

    13%

    18%

    5%

    5%

    3%

    3%

    3%

    0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

    the depth of work undertaken

    the transparency of activities undertaken

    the clarity of the assurance report

    the reliability (reputation) of the assurance provider

    the audit opinion provided (i.e. qualified, unqualified ordisclaimer)

    the assurance standard (framework) utilised

    limitations on scope of assurance engagement

    Agree Neutral Disagree

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    Suitable CSR assurance providers (survey)

    0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

    Big 4 audit firms

    Other audit firms

    Specialist CSR

    assuranceconsultancies

    Certification bodies

    Internal audit

    56%

    33%

    85%

    49%

    67%

    26%

    44%

    10%

    43%

    18%

    18%

    23%

    5%

    8%

    15%

    Agree Neutral Disagree

    ( )

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    Reasons for providing CSR assurance (survey)

    0% 20% 40% 60% 80% 100%

    Required by King III

    Demonstrates good corporatecitizenship

    Demonstrates improved transparency

    Demonstrates improved stakeholderresponsibility

    Demonstrates improved stakeholderaccountability

    Provides verified CSR disclosures

    70%

    82%

    85%

    74%

    74%

    90%

    15%

    13%

    10%

    18%

    18%

    10%

    15%

    5%

    5%

    8%

    8%

    Agree Neutral Disagree

    R f i ti CSR ( )

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    51%

    23%

    15%

    13%

    10%

    10%

    10%

    8%

    8%

    55

    5%

    3%

    0 5 10 15 20 25

    Not applicable

    Building capacity to do so in future

    Too expensive

    Little value will be added

    CSR disclosures are for informationonly

    Internal audit reviews CSR

    Too time consuming

    Not considered important at thisstage

    No legal/regularity requirement todo so

    Stakeholders trust corporatedisclosures

    Other

    Stakeholders do not rely on CSRdisclosures

    Reasons for resisting CSR assurance (survey)

    St k h ld th t l CSR di l ( )

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    Stakeholders that rely on CSR disclosures (survey)

    0

    5

    10

    15

    20

    25

    30

    3582%

    79%

    69%

    56%54% 54%

    49%46%

    44%

    38% 38%

    13%

    41%

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    Internal audits role in CSR matters

    80%

    67%

    44%

    25%

    38%

    89%

    78%

    67%

    6%

    20%

    33%

    56%

    75%

    62%

    11%

    6%

    33%

    0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

    Active CSR governance role

    Recent internal audit of CSR

    Recent CSR consulting role

    Assists certification bodies

    Assists external CSR assurors

    Complies with Standard 2130

    Could be more active in CSR

    Has capacity to be active inCSR

    Yes Uncertain No

    C l i

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    Conclusion King III implementation is beginning to entrench the principles of good

    governance, including CSR, into South African company practice (especially JSE-listed companies)

    Internal audit particularly important in developmental CSR maturity stage Standards require risk-based audit approach CSR presents a material risk

    Not intended by King III (based on recommended practice 3.4.4)

    Internal audit could form an integral part of the combined assurance model asenvisaged by King III recommended practice 7.3.1)

    However, the company CSR approach is influenced by the philosophical, moral &ethical base

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    Thank you!

    Any Questions?Barry Ackers

    E-mail : [email protected]

    Cell : +27 12 429 8993

    The journey of a thousand miles starts with a single step!!!(Ancient Chinese Proverb)

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