Professional Documents
Culture Documents
Accounting Ethics - Notes
Accounting Ethics - Notes
Accounting Ethics - Notes
SESSION 1
1 Accounting ethics
Leadership is really important. If they are not interested in reporting in a reliable way, it will
cause a lot of problems. Sometimes, auditors are misled. Auditors need to be skeptical. When
they select a client, they need to have a good feeling of integrity, otherwise it will lead to
troubles. The auditor needs to try to defend himself, say that he has been misled.
1.2 Who cares about accounting ethics? Who are the stakeholders?
1.3 Who are the “players”? Who has to ensure that we have reliable corporate reporting?
2 Corporate governance
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The audit committee helps and support the auditors.
If internal controls are functioning well, the life of auditor is much easier because he can rely on
that.
To obtain reasonable assurance about whether the financial statements are free from material
misstatements due to error or fraud.
To increase the confidence that users can place on the financial statements. Ex: increase
confidence that earnings are not inflated.
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A license is required to become a certified auditor.
It is the code of ethics for professional accountants, to which auditors need to stick and comply.
There are 5 fundamental principles:
1. Integrity
2. Objectivity
3. Professional competence and Due Care
4. Confidentiality
5. Professional behavior
“A credible and effective audit function is indispensable for an efficient and competitive EU
capital market and it plays a key role in determining investor confidence in that market”.
“The audit tradition is a professional asset of incalculable value. It derives from the market-place
for high-quality, decision-making information”.
“Our system of capital formation relies upon the confidence of millions of savers to invest in
companies. The auditor’s opinion is critical to that trust”.
6 Corporate failures
Failures mean that you were not convinced of the work of auditor, the auditor needs to defend
himself.
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7 What is audit quality?
7.1 Definition
- Joint probability that an auditor will detect a material misstatement in the financial
statements (problem) and report it.
- Meaning (and expectations) differs across the stakeholders.
Independent:
Users derive value from the knowledge that the assurance provider has no interest in the
information other than for its usefulness.
Key area of attention for regulators
Expertise:
Assurers must have the competence to obtain sufficient relevant information to provide a
reasonable basis for their conclusions.
It requires professional judgement and professional skepticism.
Key area of concern for regulators
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Key elements that create an environment for audit quality:
The framework describes in a holistic manner the different input, process, and output factors
relevant to audit quality at the engagement, firm, and national levels. It also demonstrates the
importance of appropriate interactions among stakeholders, and how they may facilitate
improvements to audit quality, as well as perceptions of audit quality.
Further, the framework demonstrates the importance of various contextual factors, such as laws
and regulations, the litigation environment, corporate governance, and the financial reporting
framework – collectively, factors that have the potential to impact the nature and quality of
financial reporting and, directly or indirectly, audit quality.
Examples:
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Professional skepticism: if auditors are acting skeptical, higher audit quality. People are rewarded for being
professional and skeptical.
Education: differs between countries, what is needed is a license that shows that you are a certified
auditor, you need to have a master’s degree. Differs across the different states in the USA. Ex: license from
Florida, you can do the audit in other states, but some states don’t allow it.
Audit firm culture is crucial. Once the top is involved in fraud, it all has to do with the culture of
the firm.
Key attributes to create a culture at audit firm level where audit quality is valued:
Governance arrangements in place to establish appropriate “tone at the top”, and
safeguard the firm’s independence
Necessary personal characteristics are promoted through appraisal and reward systems
supporting audit quality
Financial considerations do not drive actions and decisions that impair audit quality
Importance is emphasized of continuing professional development of partners and staff
and access to high-quality technical support
A culture of consultation on difficult issues is promoted
Robust systems exist for making client acceptance and continuance decisions
Audit firm culture is perceived as a root cause of audit quality! (PCAOB, IAASB, IFIAR, AFM).
Audit firms need to articulate the quality-oriented culture they want to realize (AFM 2015).
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9 Economics of auditing
The audit market is not a free market, more and more regulation that is comping into place. The
regulators are worried and want to protect the quality of the audit.
10 Demand
Empirical evidence: Certain clients are willing to pay fee premium to Big N audit firms, industry
specialists.
What do we learn from article Lennox & Pittman (TAR, 2011): voluntary versus mandatory
audit?
“Exploiting a natural experiment in which voluntary audits replace mandatory audits for
U.K. private companies, we analyze whether imposing audits suppresses valuable
information about the types of companies that would voluntarily choose to be audited.
We control for the assurance benefits of auditing to isolate the role signaling plays by
focusing on companies that are audited under both regimes. These companies
experience no change in audit assurance, although they can now reveal for the first time
their desire to be audited. We find that these companies attract upgrades to their credit
ratings because they send a positive signal by submitting to an audit when this is no
longer legally required. In contrast, companies that dispense with being audited suffer
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downgrades to their ratings because avoiding an audit sends a negative signal and
removes its assurance value.”
11 Supply
The traditional way of auditing is fundamentally changing. There is much more data-driven
audit environment.
The audit data analytic tools are used in various stages of the audit process to perform:
- Risk assessment
- Analytical procedures
- Substantive testing
• Auditing is an economic activity: demand and supply forces shape the audit market
• Raison d’être of the audit market: audit quality
• Specific features of the audit market:
- Audit process/quality is unobservable and outcome is uncertain result even for
auditor (i.e. level of assurance obtained)
- Idiosyncratic nature of the audit service
- Auditor serves public interest which may not always align with client’s interest,
while…
- … client is paying the auditor
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• Impact of regulation on audit market structure: Nearly 50% of small audit firms leave
audit market following SOX (DeFond and Lennox, 2011)
15 Regulation
There is a dramatic increase in regulation, likely to play a more prominent role in shaping audit
quality in the future.
Audit quality remains continuous area of concern to regulators. The six largest audit firm
networks have agreed with international audit regulators on a new initiative to achieve a
measureable reduction in audit deficiency findings by 2019 (see point 17).
16 Public oversight
There are some root causes for structural audit failure, such as professional skepticism and the
audit firm culture/tone at the top.
The effectiveness of public oversight is based on research relating to PCAOB inspections in the
U.S. and internationally for audit firms with clients cross-listed in the U.S.:
- Greater investor confidence
- Higher audit quality and greater value relevance of accounting numbers
Overall, 33% of the listed PIE audits inspected had at least one finding. Down from a high point
of 47% in 2014.
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17.2 Firm-wide systems of quality control
17.3 Examples
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• Failure to appropriately consider
applicable firm or partner rotation rules
Human resources • Compliance with the firm training and
learning plan
Monitoring • Failure to identify audit performance
issues when performing internal
inspections
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SESSION 2: ETHICAL DECISION-MAKING
What is ethics?
Ethics, derived from the Greek word ethikos (character), deals with the concepts of right and
wrong. It is about well-based standards of how people ought to act.
We need to examine and develop one’s ethical standards to ensure that they are reasonable and
well-founded since feelings, laws and social norms can deviate from what is ethical.
Strive to make the right decision in all circumstances, which requires evaluating the effects of
actions on stakeholders.
1.1 Teleology
An act is considered morally right if it produces results. You always assess the moral word of
behavior by looking to the consequences.
Utilitarianism is about bringing the greatest good for the greatest number of people. The end
goal is to maximize the well-being for all concerned.
Problem with the implementation: it can be difficult to assign values to harms and benefits.
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1.2 Deontology – Rights theory
Deontology is derived from Greek “deon” meaning duty. Believe the moral norms should
establish the basis for actions.
Ethical judgement: they focus on the rights of individuals. It considers rights of stakeholders and
related duties to them rather than consequences.
Deontology differs from the rule, based on reason and not outcome. That implies that
deontologists believe there are things we shouldn't do even if it maximizes utility.
Problems with implementation: The rights theory has problems as it relies on moral rules. Ex:
lying is unethical, ok but sometimes not lying can have devastating consequences.
1.3 Justice
Problem with implementation: can be difficult to determine a criteria to distinguish equal from
unequal claims.
Ethical judgement: ethical reasoning methods – virtues (internal traits of character) – apply both
to the decisionmaker and the decision.
It is both on the person engaging in the act and the act itself. The judgments are made not by
applying the rules, but by possessing those traits that enable the decision maker to act for the
good of others.
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2 Cognitive Processes and Ethical Decision Making in Accounting
Heinz’s wife has a rare cancer. A radium drug could help. The druggist charged 10 times what
drug cost ($200 cost; $2,000 for small dose of drug). Heinz could only get together $1,000. The
druggist would make no exceptions to price of drug. What should Heinz do?
First thing you need to know is what is right or wrong. Then you need to act.
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2.3 Rest: component model of ethical decision-making
Rest’s model of ethical action is based upon the presumption that individual’s behavior is related
to his/her moral development. He assumes once you are in that specific stage of moral
development, that will lead to a specific action.
He breaks down the ethical decision-making process into four major components:
1. Moral sensitivity: ability to identify what is moral and amoral.
2. Moral judgement: ability to reason through several courses of actions and making the
right decision when you’re faced with an ethical dilemma.
3. Moral motivation: Once you have decided on what course of action is best, you focus on
the ethical moral action. Your moral values may conflict with other values. Motivation
reflects your willingness to place ethical values ahead of non-ethical values.
4. Moral character: an individual is going to take the action that matches the ethical
intention he had in mind. Having one’s ethical intentions match actions taken.
- Ask to think about the arguments others might make that create barriers to expressing
one’s values in workplace.
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4. What is your most powerful and persuasive response to the reasons and rationalizations
you need to address?
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SESSION 3: ORGANIZATIONAL ETHICS AND CORPORATE
GOVERNANCE
Ethical Issue Intensity: importance of the decisions, based on one’s values, beliefs, morals. If
you’re not very sensitive to it, you won’t realize there is actually a problem. It is important to me
or the organization, based on my values, beliefs, morals.
Organizational factors: values of the organization. Those will influence the person’s own
values. Sometimes they can conflict. Sometimes the organizational has high ethics, they can try
to educt the induvial and increase the level of ethics of that individual. But if the individual is not
really open to that, he will feel uncomfortable. Sometimes they won’t match so the organization
will let the individual go. The tone at the top plays a crucial role.
These 4 will influence the business ethics evaluation that you will make and your intentions to
act. Example: your supervisor provides you with reasons to act in a different way that you
believe you should. You believe it’s not the right thing to do but you will do it anyway.
This will lead to the ethical or unethical behavior, based on what you will do.
It is the interaction between the individual and the organization, based upon person-
organization ethical fit at various stages of the contractual relationship in each potential ethical
fit scenario. There can be a disconnect between your own value and the organization.
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Four potential fit scenarios:
- High-High (high organization and high individual ethics): best-case scenario.
- Low-Low (low organization and low individual ethics): worst-case scenario. Neither you
nor the organization have high ethics
- High-Low (high organization and low individual ethics): The other people will say that
your behavior is not acceptable and will give it a try to socialize you in a sense that you
increase your ethical standards. The more the decisions are in conflict with what the
organization thinks is best, the more uncomfortable the individual is.
- Low-High (low organization and high individual ethics): worse than scenario 3.
It occurs when organizations are essentially drifting from the principles of right and wrong.
Important to understand that ethical collapse doesn’t always implies that you have violated the
rules. Book of Marianne Jennings:
1. Pressure to maintain numbers: tension between ethics and bottom-line figures. Lot of
pressure to come up from the bottom-line figures. Also Tied to revenues, bonuses,…
2. Fear and silence
3. Loyalty to the boss: you think the boss is asking me to do something, I’m well paid, I want
to be loyal so I’m just going to do what he asks me to do
4. Weak board of directors: all major accounting frauds
5. Conflicts of interests overlooked or unaddressed: example: related to a weak BoD, when
the CEO is also in the BoD, you would like that those 2 were separated.
6. Innovation like no other company: makes these companies untouchable, makes them
blind to ethical issues. Exampme: Uber is really innovating data science software but
wasn’t that ethical because they had some problems with personal information of users.
Also Facebook; they have access to a lot of data.
7. Goodness in some areas atones for evil in others: people think if I do good in some areas,
this will justify or can undo something that I did wrong. But that doesn’t make any sense.
Example: donation to charities, this won’t justify that you manipulate other people.
Corporate culture starts with an explicit statement of values, beliefs, and customs from top
management.
Corporate culture represents how things are done in the organization. Ethical culture represents
how things are done in the organization related to the ethical part. The Ethical Culture is a piece
of the Corporate Culture: it is an ethical environment that is created in the workplace by the
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organization’s leadership (tone at the top). Tone at the top is key in creating that ethical culture.
They are the ones creating the ethical environment.
A code of conduct goes beyond what is legal for an organization and provides normative
guidelines for ethical conduct. Support for ethical behavior from top management is a critical
component of fostering an ethical climate.
What are the rules for managers to set ethical tone at the top?
- Consider how your actions affect others: example of Wells Fargo, when it affects yourself
it is much harder than when it affects someone else.
- Do no harm
- Make decisions that are universal: means that if something isn’t right in one place or for
one person, then it’s not right for anyone anywhere. Example: country with poor
pollution standards, you must decide what precautions to take to not harm the local
population, just like you would do in your own country. Don’t say ok here they don’t care
so I don’t care.
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- Reflect before deciding: consider how your decisions will affect all relevant stakeholders.
Don’t be impulsive.
6 Surveys
Conclusions:
People of integrity are self-driven to do the right thing.
KPMG’s Integrity Survey 2013 surveyed more than 3,500 U.S. workers
- Nearly 75% of employees observed misconduct within past 12 months
- More than 50% of employees reported what they observed could cause a significant loss
of public trust if discovered
- Main causes: Pressure to do “whatever it takes” to meet targets, not taking code of
conduct seriously, fear of losing one’s job for not meeting targets, rewarding employees
for results and not the means used to achieve them
When employees were asked what they would do on observing a violation of code of conduct:
23% would look the other way or do nothing.
There was a shift of attention in past decade from bribery, financial manipulation and fraud to:
- Mistreatment of employees: abusive behavior, sexual harassment and discrimination
(e.g., #MeToo)
- Data privacy
Employees are 15 times more likely to believe that their organizations reward and measure
ethical behavior when they see consistent, regular communication from upper management on
issues like trust and ethical conduct.
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Trend 1: Ethical culture strengths remains high
In 2020, +- 1 in 5 US employees were in workplaces with a strong ethical culture compared with
1 in 10 in 2000. Globally, 14% of employees were working in organizations with a strong ethical
culture.
Fraud schemes occur because an employee – usually top management – causes a misstatement
or omission of material information in the organizations’ financial reports.
Methods to use:
- Revenue Overstatement:
o Recording sales that never took place
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o Recording future sales in the current period
- Expense understatement
o Capitalizing operating costs
o Not recording some expense at all
- Improper Asset Valuations
o Manipulating reserves
o Changing the useful lives of assets
o Failing to take a write-down when needed
o Manipulating estimates of fair market value
- Incentive: situational pressure. Incentive to commit fraud, which could be at the tone on
the top but also at the individual level as well. Incentive to commit fraud because you
have a personal benefit, or the organization can benefit from it. You take into account
your own self-interest but also the organization’s and others.
- Perceived opportunity
- Rationalization: rationalize the fraud, then you are able to live with it. One way to
rationalize; it is a one-time event and I’m never going to do that again. But when you
start, next year you will do it again because the situation is not better. The next year you
do it again, and it becomes huge.
In order to prevent financial fraud occur, the organization needs to establish corporate
governance.
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Some examples:
- Independent directors enhance governance accountability
- Separation of the duties of CEO and board chair
- Separate meetings between the audit committee and external auditors strengthen
control mechanisms
Effective corporate governance must include the active and collaborative participation of all of
its principal parties:
- BOD
- Audit Committee
- Management
- Internal auditors
- External auditors
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Internal controls:
The tasks of the internal auditors are to oversee the internal controls.
You first need to define a clear scope of the key controls. Prioritize what you are going to focus
on. That implies that you have to know where the risks are.
Regards to people: internal controls need to be supported from top to down. Back up by senior
management. If management doesn’t really consider that it is important, it won’t work. The
decision makers define the internal control culture and play a key role in creating that culture to
all levels of the organization.
Technology: internal control processes can be automated. Data analytics is more and more used.
9.1.3 Whistleblowing
What is whistleblowing?
Employees (former or current) who report suspected violations (illegal, immoral, illegitimate) to
persons or organizations that may be able to take action
Famous cases?
- Financial fraud case: Worldcom – Cynthia Cooper
- Other type of scandals: Dieselgate, Panama papers, Wikileaks
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- EU: Directive 2019/1937, implementation before December 2021
They make sure they are no errors in the financial statement, no misstatement, no fraud.
They have an obligation to the public interest, that is why they need to conduct audits
independent of any influence of management or the company.
They also need to communicate effectively with the audit committee: accounting policies and
procedures, estimates by management; quality of financial reporting; potential violations of
laws.
1. Throughout The Parable of the Sadhu, Bowen McCoy refers to the breakdown between the
individual and corporate ethic. Explain what he meant by that and how, if we view the hikers
on the trek up the mountain in Nepal as an organization, the ethical person-organization fit
applied to the decisions made on the climb.
The organization in Nepal had a weak ethic because the group was not willing to take
responsibility for the Sadhu and carry him down the mountain.
The organization lacked a guide and a leader that everyone could relate to. Without the support
of an organization, an individual's ethics and values are diminished. It was impossible for
Stephen to get Sadhu down the mountain without the help of others. Therefore, Stephen
essentially gave up and followed the ethics of the organization.
Additionally, the individuals were unethical in not carrying the Sadhu down the mountain
because they would not be able to get back up before the snow melted.
As a result, individuals put their goals ahead of the Sadhu's welfare. Everyone did their part to
take care of the Sadhu if it was not inconvenient, creating an environment where people got
along to get along.
Ultimately, the organization broke down ethically, and everyone drifted into rationalizations,
claiming that they were providing the necessaries such as aid and foot to the Sadhu, when in fact
they put their needs before the life of the Sadhu.
2. Using the various ethical discussions in the first three chapters as your guide, evaluate the
actions of McCoy, Stephen, and the rest of the group from an ethical perspective.
Using Kohlberg's stages of moral development, McCoy reasoned at stage 3 of Sadhu fairness. In
this stage, the individual focuses on what is in his or her best interest but takes into account the
interest of others. Although McCoy provided assistance to the Sadhu, he was primarily
concerned with passing the pass. McCoy justified his moral obligation by providing aid and
comfort to the Sadhu.
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Stephen initially reasoned at Stage 5 of the social contract by weighing the pros and cons of the
Sadhu's welfare. Stephen was motivated to carry the Sadhu down the mountain and tried to get
the other group members to help, but he was unsuccessful and eventually gave up.
Moreover, the group's reasoning was at stage 2, satisfaction of its own needs. The group
maintained a selfish attitude in which their goal was more important than getting Sadhu down
the mountain.
Stephen took on the role of leader, trying to make the others understand that the Sadhu's life
was more important than their plans. He also asked the other groups who came to the mountain
to carry the Sadhu to the hut, and finally, he asked the Sherpas to carry the Sadhu 500 feet from
the hut.
Despite the cultural differences of each group, each group put their own self-interest ahead of
ensuring the Sadhu's well-being.
Furthermore, the groups justified not carrying the Sadhu by the altitude and the need to get
through the pass before the snow melts. This shows how the ethical climate of an organization
plays an important role in the organizational culture.
4. What is the moral of the story of the sadhu from your perspective?
From my perspective, the moral of the story is that even if an individual has a high ethic like
Stephen, without the support of the organization, the individual is lost. Stephen did not have the
resources to carry the Sadhu on his own and without the help of others, he was lost. Therefore,
low organizational ethics wins out over high individual ethics.
What is ethics? It is the moral principles that govern a person’s behavior. Synonyms: morals,
rights and wrongs, creed, credo, rules of conduct, virtues, conscience, standards.
Examples:
- Panama papers: they were legal, didn’t do anything wrong. But morally, it was wrong.
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- Fox: has a new CEO and he sacked the entire ethics office.
- Wells Fargo: they have been creating thousands of fake accounts so that the salespeople
could beef up their commissions to get more money to take home.
- Uber: harassment and abuse in the company
- Tesco: fined £129 million for overstating accounts by £326 million
Building in Bangladesh collapsed: 1100 people died. They found out that the building was built
on a pond. 3 extra floors on the building that shouldn’t have been there. The building was built
too quick. All people hired to check the security of the building had been bypassed.
people were bribed to make this happen faster so that all these people could get into the
building to design the clothes for the high streets.
Corruption, bribery, illegal activity, unethical behavior caused 1100 people to die. People can
die because of it.
how do you reconcile your moral and ethical values in a company that doesn’t
Ethics matter.
Bring your own ethical standards to the organization that you work for. You have to hold your
own morals and values even if the people around you don’t have the same as you.
Imagine you work for an organization, you’ve worked in ethics your whole career, you’re good at
it, you love it. You like the people you work with. You like the company, its mission, its values.
Would you work for this company? This company is actually NHS (National Health Service).
NHS covered up huge data loss that put thousands of people at risk.
Ponder this: “bribery is a perfectly acceptable business expense” -> in some occasions it is.
When you think about an organization, figure out how you can integrate it into your company,
bring your own ethics and morals into that company.
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SESSION 4: ETHICS AND PROFESSIONAL JUDGMENT IN
ACCOUNTING
The foundation for audit quality is good professional judgement. It is related to the concept of
audit risk. Because if there would not be any risk, there is no professional judgement.
Auditing regulators often cite problems in professional judgement as a root cause of audit
deficiencies.
“Why good accountants do bad audits” (Bazerman et al. Harvard Business Review, 2002) was
published almost 2 decades ago, but still applies.
It might be titled “Why good people make bad decisions” – the points they make apply to all
complex judgement tasks.
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- The client’s asserted account balances are usually known prior to testing. When you are
going to do the audit, you get the figures. You know what the figures of last year are. This
is going to influence you.
- Auditors work very closely with their clients, becoming colleagues and friends, trust
relationship naturally develops.
- Auditors often work with the same client personnel year after year can lead to a bias
because you have certain expectation how the client behaves. If you believe someone is
really honest, you will assume he will still be in the future and you will be blind for
another kind of behavior.
- The client hires the auditor and pays the fee
The auditing profession and auditing educators are increasingly focused on improving auditor’s
judgment on engagements. One response is training their personnel.
The firms have developed guidance and position papers. One good example is KPMG’s
Professional Judgment Framework.
Judgement is the process of reaching a decision of drawing a conclusion where there are a
number of possible alternative solutions.
Prescriptive framework is used but pressures, time constraints, and limited capacity may
cause deviations.
Auditor should approach matters with objectivity and independence, with inquiring mind
and critical assessment of audit evidence
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4.2 Elements of the KPMG Framework
In the center is the “mindset”: auditors should approach matters objectively and
independently
The KPMG framework notes that auditors’ judgments and decisions can be intentionally
biased, but that is rare.
Judgments can also be unintentionally biased due to unknowingly using mental shortcuts,
or following self-interest
The KPMG framework identifies common “traps that catch us” and cause unintentional
bias (Judgments traps)
The “rush to solve” – decision makers want/need to make a quick judgment. They under-invest
in early steps, and go with the first workable alternative/
Many of the specific “traps” are related to tendencies to make a “snap judgment”.
In auditing, engagement teams are always under time pressure, but especially so during busy
season: Research (Lopez & Peters 2012) finds lower earnings quality for busy season audits.
An example: the availability tendency, we consider information that is most easily available in
memory. This is actually related to the rush to solve.
We then use the wrong information or solve the wrong problem. Example with the video: he
removed the snow on a car other than his own.
you go to the easiest solution.
Professional example:
- Analytical procedures – do client account balances differ from your expectations? If so,
why?
- Auditors often ask management for an explanation. Because it is easier, but the risk is
high that you will not consider all alternatives.
- Then test management’s explanation instead of developing their own ideas.
Example:
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The auditor notes that the estimate of bad debts is lower this year. The auditor asks a manager
why, who says “a change in our customer base”. Rather than think of other possible
explanations, the auditor seeks evidence to support management’s explanation. The problem:
this is a “non-error” explanation, may block thinking about possible errors/ may be difficult to
prove it does not account for the whole different/ the auditor may run out of budget chasing it
down.
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4.2.3 Judgment “Traps” – Framing
Bedard & Graham (2002) study what happens when a risk assessment question is “framed”
positively or negatively. Auditors responded to one of these versions:
- Positive: “The company’s accounting function is appropriately organized, staffed,
trained, and/or administered.”
- Negative: “The company’s accounting function reveals a number of weaknesses or risks
related to organization, staffing, training, and/or administration.”
Auditors with the negative frame identified 40% more risk factors for their riskier clients.
The confirmation tendency: people put more weight on information that is consistent with their
preferences.
- If the auditor first gathers a lot of consistent evidence, he/she might stop looking for
more information
- Potentially making the wrong decision
Public oversight bodies are especially concerned about this type of bias – inspections often
identify auditors just accepting management’s word & not trying to disconfirm it.
The overconfidence tendency: people tend to overestimate their own abilities to perform tasks
or to make accurate judgments and decisions. As a result of this, they are going to cease
collecting information and potentially making the wrong decision.
Professional example: Harding and Trotman (2009) find that audit superiors are overconfident
in predicting the knowledge of subordinates.
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If so, what will happen? The work that they performed is not verified well enough. They think
that they can rely on their work no matter what.
The anchoring tendency: decision makers start from an initial numerical value and then to
adjust that value insufficiently in forming a final judgment.
Example: in analytical procedures, research shows that auditor’s expected balance for an
account is affected by management’s asserted balance.
For example: audited revenues are $52M in 2016, $56M in 2017. Client management’s unaudited
revenues in 2018 are:
- $60M
- $52M
Prior to doing any testing, what is your expectation of “true” 2018 revenues?
The KPMG Framework says: actively question your assumptions, consider potentially
disconfirming evidence, seek more complete information. Not just accept everything that is in
line with what you had in mind.
Consulting with others can also help reduce these tendencies, these traps.
Decision aids are another commonly used means of improving decision quality in auditing.
Note that the framework starts and ends with coaching. It is all about learning, help people
learning from their mistakes.
Supervisor review of audit work is an important quality control practice in firms.
Good coaching implies not just telling the subordinate the work is correct or incorrect, but also
helping them to avoid mistakes later and to develop as a professional.
Coaching is a skill. Are audit supervisors good at it?
Auditing regulators, audit firms, and researchers have considered several ways:
- Changing auditing standards
- Changing audit firm guidance
- Decision support systems
- Changing economic incentives
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6.1 Changing auditing standards
The KPMG Judgment Framework recommends that talking to others will help avoid judgment
biases.
Auditing standards should encourage team interaction, this could help.
One example is the requirement for “fraud brainstorming”
The engagement team is required to discuss risk of fraud, consider specific risk factors, and
plan how to address them. This should ensure all important information is shared and
considered. But does it work?
To increase auditor skepticism, just saying “be more skeptical” doesn’t help. Research has
studied whether firms can prevent judgments biases adopting new steps in the audit process.
Examples:
- Instructing auditors to “counter-explain” an initial conclusion (say why it might be
wrong)
- Instructing auditors to explicitly consider multiple explanations (and then narrow them
down through testing)
In large audit forms, electronic decision aids are used to support many keys steps in the audit.
- Client acceptance and continuance decisions
- Risk assessment (misstatement/fraud)
- Control and substantive testing (e.g.: test planning, sample size)
- Closing the audit, reviewing work
A decision aid can “force” consideration of evidence, or just offer ideas. Example: linking
identified risk factors to specific tests.
(EY helix)
The greatest change that could be made is to not have the clients be in charge of hiring the
auditor and setting the fee. The chance of this is very low.
7 Auditor Skepticism
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Professional skepticism is an attitude that includes a questioning mind, being alert to
conditions which may indicate possible misstatement due to error or fraud, and a critical
assessment of audit evidence.
What are some of the problems with professional skepticism? What constraints do auditors
face?
- Issue of information asymmetry: the client has all the information, and the auditor has to
get it from him.
- The auditor has responsibility for the entire audit, but their team is spread all around the
world and that creates some challenges of managing a diverse team.
- Auditor faces a ticking clock where they have to get all their audit done within a
reasonable amount of time. Making decisions under this kind of pressure creates a
cognitive bias.
Rate yourself on the following statements: (1= strongly disagree, to 6 = strongly agree)
1. I often accept other people’s explanations without further though.
2. I wait to decide on the issues until I can get more information.
3. The prospect of learning excites me.
4. I am interested in what causes people to behave the way that they do.
5. I am confident of my abilities.
6. I often reject statements unless I have proof that they are true.
• Motivated blindness: Auditors may see what they want to see and easily miss
contradictory information when it’s in their best interest to remain ignorant.
• Incentive system: rewarding results rather than high-quality decisions
• Personality traits: diligence, thoroughness, objectivity and reliability are traits that
influence level of professional skepticism.
• Levers: accountability to reviewers and regulators serve as a lever that impacts skeptical
judgment and skeptical action
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8 Audit Deficiencies
Findings of a study of audit deficiencies for the Center for Audit Quality that resulted in
sanctions from the SEC include
– Failure to gather sufficient competent evidence
– Failure to exercise due care
– Insufficient level of professional skepticism
– Failure to obtain adequate evidence related to management representations
– Failure to express an appropriate audit opinion
Satyam Case resulted in PwC being sanctioned due to a lack of due care and exercise of
professional skepticism by accepting evidence provided by management that was less than
persuasive.
When professional judgment is compromised, the public loses trust in the accounting profession.
The reputation of the profession is built on its historical foundation of ethics and integrity.
IFAC’s Policy Position Paper #4, A Public Interest Framework for the Accounting Profession: A
distinguishing mark of the accounting profession is the acceptance of its responsibility to act in
the public interest.
International Ethics Standards Board for Accountants (IESBA) include integrity, objectivity,
professional competence and due care, confidentiality, and professional behavior.
10 Threats to Independence
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Financial Self- Having a loan from the client, from an officer or director of the
Interest Threat client, or from an individual who owns 10 percent or more of the
client’s outstanding equity securities.
Management Establishing and maintaining internal controls for the client.
Participation
Threat
11 Safeguards
Source of the
Examples of Safeguards
Safeguard
Created by the Professional resources, such as hotlines, for consultation on ethical
profession, issues.
legislation, or Education, professional standards, ban on non-audit services
regulation
Implemented • The client has personnel with suitable skill, knowledge, or
by the client experience who make managerial decisions about the delivery of
professional services and makes use of third-party resources for
consultation as needed.
• The tone at the top emphasizes the client’s commitment to fair
financial reporting and compliance with the applicable laws,
rules, regulations, and corporate governance policies.
• Policies and procedures are in place to achieve fair financial
reporting and compliance with the applicable laws, rules,
regulations, and corporate governance policies.
• Policies and procedures are in place to address ethical
conduct.
• Policies are in place that bar the entity from hiring a firm to
provide services that do not serve the public interest or that
would cause the firm’s independence or objectivity to be
considered impaired.
Implemented Policies and procedures addressing ethical conduct and compliance
by the firm with laws and regulations. Audit firm quality control procedures
13 Examples of regulations
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Financial relationships
Family relationships
Business relationships
Employment or association with attest clients
Providing novattest services to attest client.
Safeguards can be put into place to reduce or eliminate threats of compromising independence,
integrity and objectivity, but nothing can substitute for ethical intent and ethical action!
Skepticism through the lens of cognitive bias. How cognitive bias can inform not just the auditor
but also the standard setters, the preparers and the public who are using the reports.
Wanted to find out that with is it that auditors are still seem to be finding a problem 10 years
after the global financial crisis.
Auditors face 3 constraints:
- Issue of information asymmetry: the client has all the information, and the auditor has to
get it from him.
- The auditor has responsibility for the entire audit, but their team is spread all around the
world and that creates some challenges of managing a diverse team.
- Auditor faces a ticking clock where they have to get all their audit done within a
reasonable amount of time. Making decisions under this kind of pressure creates a
cognitive bias.
One important thing that we do know about professional skepticism is that professional
skepticism is not just about people being different. Yes some people are inherently professional
skeptic than other, but it is basically about the interaction between differences between people,
and environmental conditions, things like time pressure and client environment.
When you move to business, you still need to retain some sort of critical mindset. Whether you
call it professional skepticism or something else, it’s within the DNA of an auditor.
On the one hand, we have the regulator who is issuing constantly new guidance and regulation.
On the other hand, we have the audited company which doesn’t always seems to see what
actually the benefit of all that regulation for them is.
It is a challenge to maintain the professional skepticism, to match the expectations from both
parties.
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3 elements to the definition of professional skepticism:
7. Critical assessment: Requirement for the practitioner to make a critical assessment of the
validity of evidence obtained.
• Search for knowledge: refers to the desire to investigate beyond the obvious as well as
the desire to corroborate. This takes knowledge and understanding further by requiring
the practitioner to draw inferences and apply evidence-based thinking.
• Suspension of judgment: requires the practitioner to withhold judgement until
appropriate evidence is obtained.
Example: a judge in a murder case has received a lot of media coverage. The media has
portrayed the defendant in very poor light due to his previous job-related convictions. How will
the judge exercise critical assessment? The judge would not automatically assume guilt. But this
doesn’t mean that the judge should ignore other information. The judge would draw inferences
to previous convictions when judging the defendant’s character and regard for rules and
regulations. In arriving at the verdict, the judge would require evidence and proof to
substantiate or corroborate the arguments put forward by the defense and prosecution. The
judge would arrive at a verdict by weighing up the facts and evidence at his disposal.
8. Questioning mind: need to make the critical assessment with a questioning mind and attitude
of professional skepticism.
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In the current year, management revalued their fixed assets. How will you evaluate a
questioning mind in relation to the revaluation?
Make enquiries regarding the reasons for revaluation and the method used to arrive at the
revaluation.
Would exercise autonomy by conducting your own revaluation calculations or obtaining the
use of your own expert. You would not simply accept the claims by management or
management’s expert.
You would exercise self-esteem by inspecting the calculations and assumptions of
management’s calculations and challenge the reasonableness of the assumptions in respect to
other entities operating in similar industries.
9. Alertness: also requires the practitioner to be alert to evidence that contradict or brings into
question the reliability of documents.
Example: auditor of Orange Limited. You have been informed that management’s bonuses are
dependent on the achievement of a preset net profit target. Current year: revenues increased
more that 10% in comparison to prior. While tax expense decreased by 13%. Management are
pleased with Orange Limited’s performance as they have satisfied the bonus requirement.
How will you react to this information in respect of alertness?
You would be alert to the possibility that the net profit may be misstated in order to meet the
target.
You would also be aware of the increase in revenue with the decrease in tax expense. This
appears to be a contradiction to the normal relationship between revenue and tax expense. You
would expect that an increase in revenue would also result to an increase in tax expense.
You would further recognize that management may provide misleading information to cover
up possible misstatements.
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SESSION 5:
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