Public Internal Control
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1 Public Internal Control Robert Gielisse, CIA, CGAP European Commission Principal Adviser, Head of PIC/PIFC Task Force DG Budget Prague April 2015
2 Internal Control - COSO definition A process, effected by an entity's board of directors, management and other staff, designed to provide reasonable assurance regarding the achievement of objectives relating to operations, reporting, and compliance in the following categories: efficiency and effectiveness of operations, safeguarding of assets reliability of reporting (financial and non-financial, internal and external) compliance with laws and regulations 2
3 Internal Control (COSO) Governance (ISO31000) A process, effected by an entity's board of directors, management and other staff, designed to provide reasonable assurance regarding the achievement of objectives relating to operations, reporting, and compliance in the following categories: efficiency and effectiveness of operations, safeguarding of assets reliability of reporting (financial and non-financial, internal and external) compliance with laws and regulations The combination of processes and structures implemented by the Board and management to inform, direct, manage and monitor the activities of the organisation towards the achievement of its objectives Notice the resemblance between the definitions of Internal Control and Governance 3
4 Internal control INTOSAI definition Internal control is an integral process that is effected by an entity s management and personnel and is designed to address risks and to provide reasonable assurance that in pursuit of the entity s mission, the following general objectives are being achieved: executing orderly, ethical, economical, efficient and effective operations; fulfilling accountability obligations; complying with applicable laws and regulations; safeguarding resources against loss, misuse and damage. 4
5 Key message Internal Control: Process owned by People Reasonable assurance that the mission is accomplished (objectives are achieved) 5
6 All EU-28 countries have a system of Internal Control in their public sector But there are differences. a) systems in compliance with up-to-date, generally accepted, international frameworks and standards b) countries in transition (not yet fully compliant with framework/standards under (a)) c) Traditionally-geared approaches, with focus on centralised management and controls 6
7 Let's focus on PIC: internal control in the public sector compliant with international framework and standards Main PIC Principles within the EU-28 1) Good governance as the main driver 2) COSO/INTOSAI internal control set-up for decentralised managerial accountability 3) Incorporating other relevant international guidance 4) Centralised or decentralised functionally independent Internal Audit 5) Accountability triangle 6) CHU function 7) Inspection function clearly separated from Internal Audit 8) Active interaction between internal and external assurance providers 7
8 PIC principles (1) Good Governance as the main driver includes: Respect of the law Acting in the public interest Integrity Tone at the top: do what you say and say what you do Transparency Objectivity: choices based on merit Accountability: explain how authority is used to achieve objectives external and internal 8
9 PIC principles (2) Internal Control set-up that complies with COSO/INTOSAI recommended set-up for decentralised managerial accountability An integrated and interconnected system: Control environment Objective setting and risk management Control activities Information and communication (financial and non-financial, internal and external) Monitoring, Evaluation, and Internal Audit 9
10 COSO interrelated components Control environment Mission statement Integrity, Ethical climate and corporate values Organisational setup/authority Human resources management Risk Assessment Objective setting, Performance measurement and risk scope Risk identification and risk ownership Risk assessment Risk response (avoid, transfer, reduce, accept) Control activities (to reduce the risks identified) Ensuring link with risks Control selection, design and evaluation Policies and procedures IT Information and communication Financial and non-financial Internal and external Balanced Score Cards Monitoring activities Regular and individual assessments Evaluation Internal Audit function 10
11 PIC principles (3) Functionally independent Internal Audit outspoken support by top management is key may be centralised or decentralised operated according to IA standards direct reporting lines to the Board/top management ideally supported by Audit Committee 11
12 PIC principles (4) Incorporating other relevant international guidance IFAC OECD-SIGMA PEFA 12
13 PIC principles (5) Accountability triangle Accountability relates to responsibility and empowerment (authority) Accountability cannot be delegated, responsibility and authority can 13
14 PIC principles (6) - CHU function Key role: coordinate and harmonise approaches and activities relating to PIC Functions of the Central Harmonisation Unit must exist, the operational format may differ Ensuring appropriate legislative framework (primary, secondary and tertiary) IC and IA standard setting Providing guidance Overseeing the PIC landscape and identify gaps Reporting Optional: Certification schemes 14 Training (coordination)
15 PIC principles (7) Inspection function clearly separated from Internal Audit function Format Internal Audit Centralised or decentralised Inspection Specialised service or part of police function Driver Adding value Corrective action Objective Reasonable Assurance on G, RM, C Focus on wrongdoing and its correction Trigger Based on Risk Based on allegations, suspicion Scope Type relation Broad Management Issues Cordial (Critical Friend) Legal and compliance Adversarial, interrogative Assumption Expect things are OK Probably not OK 15
16 PIC principles (8) Active interaction between internal and external assurance providers Audit Committees External Audit (Court of Auditors) at national level External Audit (Audit Authority, European Commission, ECA) regarding EU funds Ultimate client is the Parliament 16
17 Conclusions Good governance is essential for credible government Internal Control is the responsibility of all There are common principles underlying PIC 17
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