PART 1 LESSON 10

INTERNAL CONTROL & ETHICS

LESSON 6
INTERNAL CONTROL
Internal Control

It provides a reasonable assurance to achieve the objectives of the organization.

Increases efficiency and ensures polices are implemented. It is the integration of
organization policies and attitudes. Assurance is provided to meet the entity’s objectives.

It includes.
 Effectiveness and efficiency in organizations operations.
 Compliance with laws and regulations.
 Reliability, complete and accurate financial information.
 Safeguard of assets.

Internal control helps in detecting fraud and organization resources. Resources are
directed monitored and measured. Internal control if it is assigned towards business entity
it is called as business controls.

Objectives of Internal Control

1. Internal control is ensured to meet the organization goal sand objectives.

2. Maintenance of documents adheres to the laws and regulations.
3. Use of resources is effective and also enhances the safety of assets,
4. Proper documentation enables reliable information to the auditors.

Evaluation of Internal Control

 It helps to certain the controls and procedures of the objectives.

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 Decides the nature of audit procedure which to be expanded and which to be
curtailed.
 Identifies management assertion to check whether the transaction is complete
 Recommend the ways to improve internal control
 Helps in detection of error and other material misstatements

Components of Internal Control

Internal control consists of five components such as.

 Control environment.
 Risk assessment.
 Information and communication.
 Control activities.
 Monitoring.

1. Control environment
Influence the control consciousness of people. It is the foundation of all the other
elements of internal control. Includes
 Ethical values,
 Leadership philosophy,
 Operating style,
 Polices and Procedures.
Assigns authority and responsibility to organize and develop its people.

2. Risk assessment
Identification and management of risk in achieving the objectives. Changing
economic and operating scenarios enables the organization to identify risk. Risk
assessment should be done at all levels in the organization for an effective internal
control system. Associate the risk pertaining to the financial statements in compliance
with the GAAP.
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3. Information and communication

Proper information should be identified and organized for the organization
responsibilities. Clear and unambiguous message about the responsibilities should
flow from the top to bottom level management. Information should be clear stating
the nature of activity that is to be performed. It contains both operational and
financial information.

4. Control activities
Activities like polices and procedures that are caused out by the management. It
ensures about the action taken to achieve the risky objectives. It includes various
activities such as verification, reconciliations, and reviews of operating performance
and safeguarding of assets. They include establishing a policy and taking necessary
procedures to implement the policy. Activities should be implemented consciously
and thoughtfully.

5. Monitoring
Internal control polices and procedures should be monitored. Supervisory
activities are to be taken for the ongoing performance of the internal control system.
Monitoring of the policies should be done over time. It should be monitored in
reference to the changing environment scenario. Result in identifying the internal
control which is relevant and adhere to the objective.

Types of internal controls

Internal Controls are of two types they are

1. Internal Accounting Controls
2. Administrative Accounting Controls

Internal accounting controls

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Guidelines and procedures relating to fair presentation of the books of records and
accounts. It gives a reasonable assurance that.
• Transactions are transacted based on the accounting principles and standards.
• Liabilities have been identified and properly accounted.
• Accounting transaction meets all the legislative and legal requirements.

Administrative accounting controls

The accounting transactions are processed in accordance with the management’s
responsibilities and authorization. It ensures for effective segregation of duties.
• Proper maintenance of assets
• Safeguard of assets.
• Transactions to be authorized properly.
• Data inputs in conformity with the internal control procedures.

Limitations of Internal Control

1. Unusual transactions are ignored.
2. Change in the degree of risk is not adaptable by the internal control.
3. Management override of internal activities weakens the system.
4. Internal control system provides only reasonable assurance and not absolute
assurance.
5. If the staffs are inefficient then there is no chance of effective internal control.
6. Internal control provides only timely information of the objective, achievement
of the objective is not granted.
7. Human action is necessary in internal control. This leads to many errors in
processing
8. If the system adopted for effective control is inflexible then it may lead to
ineffective internal control evaluation.

Internal Control Procedures

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It is a procedure derived by the management giving the assurance that the
accounting objective of the organization is achieved. It helps to identify the risk of
material misstatement in the financial report. Accounting information may be different
for various organization but they do have a common objective of producing reliable
information at times. Accounting control system procedures provides complete, reliable
and valid information.

Internal control whether it is general a specific control auditor first gather

effective and reliable evidence on the operating effectiveness of the control procedure.

Internal control procedures are of two types.

1. General control procedures.
2. Specific control procedures.

General control procedures

It provides assurance as to the overall completeness, validity and reliability of the
accounting objective. It also provides assurance about one or more application of internal
control that is best suited for a particular environment to operate effectively. Therefore it
is also called as environment controls.

Categories of internal control procedures are

 Organizational independence
It exists when no one in an organization is in position to perform the duty
of detecting material misstatements or any fraud apart from his normal work of
duties. If organizational independence does not exist chance of fraud will be more.
Segregation of duty is an important function to be adopted. Segregation of the
following function such as accounting, authorization and operational function enables
the organization to achieve its goal. Person assigned the duties with the particular

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function should perform only the one pertinent to him and not responsible for any
other function.

Rotation of various functions and jobs is possible only with adequate training and
knowledge in all fields. If the organizational independence is ineffective the auditor
will have no control on the procedures performed by the organization.

 Supervision
Persons assigned with the responsible to perform any activity should be
supervised. The functions performed by him should be reviewed, corrected and
checked before submission. If the procedures carried out are not supervised then the
auditor will not have control over work done.

 Competence of Personnel
Persons assigned with the responsibility should be competent in performing the
accounting, operational and financial procedures.

 Authorization
Set limit to authority. They should have certain limit in authorization of
transactions and other documents.

 Restricted access to resources

Persons who have access to resources only should be allowed to authorize
transactions. Unauthorized persons should not be allowed to use it.

 Information system development

Assurance on new and existing application software indicating that it is
functioning in an effective manner. Controls over system do include change,
maintenance and listing controls.

Specific control procedures

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Designed to achieve specific accounting objectives of the organization. It checks
for accurate valid and reliability of the accounting information provided. They provide
assurance in respect to:

1. Data processing
Information related to input. Processing and output stages.
2. Accounting information system
Cash receipts, disbursements etc.
3. Control objective
To check for complete, valid and accurate information.
Operationally effective internal control procedure gives assurance that the
accounting information for specific procedure is achieved with completeness accuracy
and validity.

Internal control structure

Organization internal control structure minimizes the threat of risks in order to
meet its objective. It can only minimize the risk, it cannot structure minimizes the risks; it
cannot remove the risk completely. However the control structure minimizes the risk by
giving only reasonable assurance and not absolute assurance.

Components of internal control structure

1. Control environment.
2. Accounting system.
3. Control procedures.

1. Control environment
It is the control consciousness of the people. Foundation of all other internal
controls and structure.
Control environment factors of internal control structure do include.

 Management’s philosophy and operating style

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Some organization takes risk in their new business whereas others may be
cautious or conservative. Their philosophy and operating style has a considerable
influence over the control activities.
 New employees to the organization should be aware of their values and rules.
 Evaluation and promotion should be done effectively and with utmost
confidentiality
 Disciplinary actions should be maintained consistently.
 Information regarding the changes in tax and other accounting system should
be communicated properly as they influence the control environment.

 Integrity and ethical values

Organization should have collective integrity and ethical values. They should
develop a strong code of conduct and measure that it is followed by all shareholders.
Any code of conduct is out of date or the management does not take steps to
communicate it proper action is to be taken to correct the deficiency. Strong internal
audit function is one of the major components of control environment to impose
integrity and ethical value in the organization.

 Audit committee
Committee should be active and independent for a safe control environment.
Polices, procedures have to be set by the board which constitute the top level
management for an effective control environment.

 Commitment to Competence
Required competence levels are to be identified for various tasks. Employees
should have adequate abilities and skills to carry out the task. Assessment of their
ability should be done as and when needed.

 Human resources polices and procedures

It is an important element considered by the internal control system during
performance reviews of the people, polices and procedures
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2. Accounting system
Internal control structure takes care of accounting. It identifies and evaluates
all the accounting transactions of the organization. Should check for the validity
completeness and accuracy of the accounting information’s
Internal control evaluates for:
 Monetary value – whether it is properly entered.
 To identify if there is any abnormal account balances.
 Verifies the submission of all financial transactions and books of accounts.

3. Control procedures
It reduces the error in the system. Don’t encourage people to commit fraud

Categories of co control procedure.

 Segregation of duties
Each individual assigned the duty to carry out the required tasks.

 Documentation of Records
Internal control enables the control procedure to have a proper
documentation of the records for a reasonable assurance of the control system
objectives.

 Safeguard of assets
Safety of fixed assets is ensured. They take care of both fixed and floating
assets by having a fixed responsibility on both.

 Performance verification of the documents

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It is done by internal auditors. Performance is maintained based on the
comparison of the accounts with books of assets.

 Authority
Authorization to individual to certify transaction. Necessary
documentation is necessary to avoid any material misstatements.

Foreign Corrupt Practices Act (FCPA)

It is an U.S. act formulated in 1977 and revised in the year 1988. It prohibits
bribery of foreign government officials for the purpose of obtaining or retaining business.
FCPA also formulate transparency in the accounting requirements. It makes a necessity
for companies to desire and maintain accounting system to have a tight control in the
position and disposal of assets. They also prohibit illegal payments. Any organization
found for violating the accounting transactions may be penalized for monetary fines.

Foreign corrupt practices act do include Persons such as

o Issuers
U.S. or foreign that is listed under the securities and exchange commission.
o Domestic concerns
Any individual a organization entity having their principle business at duties
states.
o Persons covering both individual and organization.

Corrupt payments can be avoided by

• Due Diligence
• Precautionary care to ensure that they have for a commercial relationship.

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FCPA makes it illegal towards any corrupt payments to foreign parties. Payment
through intermediary is considered illegal. Foreign companies should maintain a written
code of conduct and ethics towards their foreign polices. They should abandon selling
goods directly to foreign companies.

• Proper accounting system is to be maintained as per the standards and principles

of GAAP.
• Books of account should reflect the requirement and it should be transparent.
• Any individual involved in corrupt practices is subject to a fine of $10,000 or
imprisonment of 5years or both.

There are some exceptional cases involved in anti bribery prohibition such as.
• Water supply, phone and power.
• Protecting perishable products.
• Loading cargo and unloading.
• Cross country transit of goods.
• Police protection

Penalties offered for violating FCPA are

 For Company’s → fine up to $2,000,000
Individual’s → fine up to $1, 00,000
 SEC suspends the individual or organization from the security industry
for any violation of FCPA.
 Individuals or organization will be considered ineligible for export
licenses.
 They may be excluded from the business with the federal government.

FCPA overlooks the organization or any individual for any violations of the
policy. Any awareness of the people or employees towards the violation of act should
promptly report it to the regional management and legal department.

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Internal Audit
It is an activity to achieve the objective of the organization. Internal audit is
performed by internal auditors for performing internal audit activity in the organization.
Objectives of the organization is achieved through systematic approach in order to
evaluate the effectiveness of the organization with regard to risk management and other
control process

Internal auditing helps to

• Verify the internal control and financial records.
• Increases the efficiency and effectiveness of the operations.
• Management system designed to ensure that it is in compliance with the rules
and regulations polices and procedures of the organization.
• Reliability and integrity of the financial information is reviewed.
• Enhance a positive relationship with the internal auditor, agency staff and audit
committee.

Objective of internal audit

1. Reasonable assurance to the managerial stating that the financial statements and
records are reliable and accurate.
2. Appraise the economy and efficiency of resource utilization.
3. Assist members for successful performance of the responsibilities by giving them
pertinent information about the activities.
4. Control cost is effective and promoted at a reasonable cost.
5. Detects fraud from the organization.
6. Audit efforts are coordinated through internal audit.
7. Operational procedures of existing internal control are evaluated and also give
necessary guidance for new internal control polices.
8. Ensure safety of assets.
/

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Scope of internal audit
1. Checks for adequacy of the financial operations in relation to business risk.
2. Weaknesses identified should be used by having a constant follow up actions.
3. Company’s corporate governance, risk management should be properly overseen.
4. Any issues relating to internal control can be solved by producing consulting
services.
5. Review of the internal audit to be done by another internal audit function a by an
internal auditors.

Authority and Responsibilities of Internal Auditing

Internal audit conducts a board and comprehensive program of audits to
accomplish the audit objectives. They review all the financial records of the organization
and checks for compliance with the code of conduct and ethical standards. Information
which is obtained from such control activities is confidential. Various internal activities
are coordinated in order to achieve the audit objectives of the organization. Audit
committee meetings are conducted regularly to present the audit services. Internal audit
staff does not have direct control over the reviewing of activities.

 Independence
Internal auditor should be independent of the control activities they audit. They
should not be under the pressure of any individual or separate department. Independence
in auditing implies in providing impartial and activated judgment of the control activities.

 Management
Internal audit should detect, investigate and prevent any fraud from the
management. Responsibility of the management also relies upon safeguarding of assets.
Objective of the management can be accomplished by
 Installing effective accounting system
 Employees are in with the relevant codes of conduct
 To meet the legal requirements of the organization.

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 Compliance
Ensure in compliance with the polices, procedures, laws and regulations

 Safeguarding of assets
Safeguard assets in order to protect it from any theft, loss or any illegal activity.

 Due professional care

It calls for the application of the care and skill of a reasonably prudent and
competent internal auditor in the same or similar circumstances.

Types of internal audit

1. Financial audit
Review of all financial records to check whether the assets and liabilities
are properly recorded. Information obtained from financial audit are normally
used in decision making process. It ensures that the funds are properly secured
and maintained. Financial audit do include activities such as.
 Risk assessment.
 Financial analysis of cash flow statement.
 Compliance.
They verify the revenues, sales, bank deposits, loans and advances and
other assets. The financial statements is assessed to find out the accuracy of
the financial statements and operations

2. Operational audit
It is review of department operating procedure and internal controls. It
covers the evaluation of internal control, compliance with the laws and
regulation, reliability and integrity of information, effective and efficient use of
resources. Operational audit information is gathered from past history,
operating standards, operating reports and from senior management.

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3. Compliance audit
Programs and other audit measurement comply with the rules, regulations,
polices and procedures. Certain established criteria should be set by the
organization against which the policies and procedures can be measured.

4. Environmental audit
It is the review of the activities operation and regulations to meet the
environmental requirements. Team is engaged to have a comprehensive
examination of the plant or factory to see whether it complies with the
environmental requirements. It also assesses the environmental risk associated
with the operations. Environmental audit programs do have number of
characteristics. They require adequate allocations resources & hire and train
employees.

5. Fraud audit
It encourages detection and prevention of fraud in the transaction. Person
conducting fraud audit should identify the source of evidence, areas of fraud
opportunity etc. They locate the accounting regulations, code of conduct and
other exceptions. Fraud detection may be reactive and proactive. Reactive
auditing responds complaints, suspension and managements intuition.
Proactive auditing ensures controls through periodic audits and intelligence
gathering.
6. Quality audit
It is an independent examination of the quality related activities to comply
with the quality standards. It helps to achieve a quality based corporate culture.
It focuses on system and processes rather than outcomes.

7. Performance audit

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It involves in determining the management objectives that lead to
effectiveness and efficiency. Performance audit helps to determine the key
performance indicator to use and control objectives that is to be achieved.

8. Information system audit

Information system audit object is to determine the safety of assets,
integrity of data to achieve organizational goals and objectives. It helps to
prevent and detect fraud.
Information system helps to
 Review the system to ensure security
 Organizational reviews so as to achieve the organizational goals
 Technological reviews to ensure security and controls.

9. Grant audit
They focus mainly on the compliance of the financial system with specific
grant agreements. It helps to review the funds based on grants given and
received.
• It receives the reporting requirement and determines if it satisfies the
process that is required for the requirements.
• Amount of grant received and deposited is reviewed
• If any funds are unused it ensures that it is returned to the grant agency.

10.Due diligence
It investigates and evaluates the management philosophy prior to the
commencement of the business. Due diligence is the entire process that covers
the investment analysis and investigation of the investment undertaken. Results
that are obtained from investigation and analysis is developed in a report called
as Due diligence report. Risk identified may be asked by the investor to
eliminate or weaken the risk.

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Investigation of the report done in the basis of
 Media reports
 Legal and regulating issues.

Internal controls on an accounting information system

Computerized information of internal control minimizes the chance of risk

and fraud. Internal control system depends on the integrity compulsory and confidentially
of the control activities for information system.

General control
They cover the entire information system they include planning,
management, system software acquisition and integrity of the information
system. It ensures for correct date file processing, auditing to the personalized
standards and back up of files taken for to present any disaster. If also ensures
for physical security and measures to reduce the risk of vandalism and
destruction of networks.
General control may be:
 Data center
Control over operating activities and back up and recovery procedure.

 Access security controls

Protect the system from unauthorized access and hackers. Firewall
security is provided to restrict access to assets and other networks.

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 System software controls
It includes control over maintenance acquisition and development of the
software.

 Application system development

It proceeds with safe development systems and modification of existing
systems.

Application controls
They include computer program and access and other activities for
budgets and processing. They check the accuracy, validity and reliability of the
accounting information.
Application controls are:
 Inputs controls
 Processing controls
 Output controls
It ensures for the accuracy and conceptacles of the data processed. They
detect and prevent any errors or regalities. It checks for the security of the
system and ensures that the process data are in an efficient manner.
Electronic data interchange and expert system are the applications of the
control.

Input control
Ensure for complete and accurate recording of transactions only by
authorized users. Examples are fold checks, error listings and sequence
checks.

Processing controls
Completeness and accuracy of processing of authorized transactions.
Example: run controls, concurrency controls and audit tracks.

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Output controls
Ensures the completeness and accuracy of the results obtained. Example:
file changes and distribution register.

Administrative controls
They ensure the proper organization and processing of data.
Administrative controls are

Division of duties
Duties are assigned to different persons. Control is divided to
different persons according their capabilities. This is done in order to eliminate
fraud and to make the organization independent of all activities.

Files control
Fraud and errors can be eliminated using file control. This can be done
by.
• Procedure for issuing and return of files.
• Labeling and indexing.
• Back up copies of files.
• Skilled personal to maintain file control.

Operation controls
It determines the nature and procedure of the work system. Therefore
they should be controlled. It can be.
• Maintenance of attendance.
• Proper record for rotation of shifts.
• Computer logs.
Proper maintenance of the operation control helps the auditor to detect any fraud
or error.

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System development controls
Relate to design and implementation of the system. Various system
development controls are.
 Standardization
Standards are laid down for the proper operation of the system. It
includes complete documentation. It helps the auditor to spot out any error
and also advises any improvement on the system that it works.
 Testing
It tests the system thoroughly before it is operational. It tests the
system and validates for any error or fraud. Bench marks in testing can be
compared with that of the previous benchmark to check for any tampering of
data.
 Management involvement:
Management involved in the system to have a feasibility study n
preparation of budget. They involve finding out whether the system is reliable
and cost effective.
 Training
Staffs should be properly trained to run the system. Trained staff helps to
reduce the number of errors.
 Processing of old and new system
Comparison of old with the new system helps, to find out any fraud or
error with the new or existing system.

Procedural controls
They are the controls that are set on the day to day running of the system
they may be
 Input controls
 Processing controls
 Output controls

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 Input controls
They are placed in the input data. They may be
 Validating check
 Authorization procedures
They check the data entry for completeness and information.
 Processing controls
They check the data duty the processing stage. Processing control
may be of two types
 Validation tests
 File checks.
Validation checks for the validation of data. They do include.
• Check digit verification
• Check files size and code.
File checks check for the integrity of the file data they include
Arithmetic validation of one file with the other record file
 Output controls
Ensure completeness and accuracy over the output file printed.
Control procedures are.
• Output given only to authorized persons.
• Output verified against input data fed in
• Feed back system so as to ensure that any error occurred is
reported.

Ethical Guidelines for Management Accountants:

The Institute of Management Accountants prescribe Ethical Guidelines to the

Management Accountants which is reproduced below:

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Members of IMA shall behave ethically. A commitment to ethical professional practice
includes overarching principles that express our values, and standards that guide our
conduct.

PRINCIPLES
IMA's overarching ethical principles include: Honesty, Fairness, Objectivity, and
Responsibility. Members shall act in accordance with these principles and shall
encourage others within their organizations to adhere to them.

STANDARDS
A member's failure to comply with the following standards may result in disciplinary
action.

I. COMPETENCE
Each member has a responsibility to:

1. Maintain an appropriate level of professional expertise by continually developing

knowledge and skills.
2. Perform professional duties in accordance with relevant laws, regulations, and
technical standards.
3. Provide decision support information and recommendations that are accurate,
clear, concise, and timely.
4. Recognize and communicate professional limitations or other constraints that
would preclude responsible judgment or successful performance of an activity.

II. CONFIDENTIALITY
Each member has a responsibility to:

1. Keep information confidential except when disclosure is authorized or legally

required.
2. Inform all relevant parties regarding appropriate use of confidential information.
Monitor subordinates' activities to ensure compliance.
3. Refrain from using confidential information for unethical or illegal advantage.

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III. INTEGRITY
Each member has a responsibility to:

1. Mitigate actual conflicts of interest, regularly communicate with business

associates to avoid apparent conflicts of interest. Advise all parties of any
potential conflicts.
2. Refrain from engaging in any conduct that would prejudice carrying out duties
ethically.
3. Abstain from engaging in or supporting any activity that might discredit the
profession.

IV. CREDIBILITY
Each member has a responsibility to:

1. Communicate information fairly and objectively.

2. Disclose all relevant information that could reasonably be expected to influence
an intended user's understanding of the reports, analyses, or recommendations.
3. Disclose delays or deficiencies in information, timeliness, processing, or internal
controls in conformance with organization policy and/or applicable law.

RESOLUTION OF ETHICAL CONFLICT

In applying the Standards of Ethical Professional Practice, you may encounter problems
identifying unethical behavior or resolving an ethical conflict. When faced with ethical
issues, you should follow your organization's established policies on the resolution of
such conflict. If these policies do not resolve the ethical conflict, you should consider the
following courses of action:

1. Discuss the issue with your immediate supervisor except when it appears that the
supervisor is involved. In that case, present the issue to the next level. If you
cannot achieve a satisfactory resolution, submit the issue to the next management
level. If your immediate superior is the chief executive officer or equivalent, the
acceptable reviewing authority may be a group such as the audit committee,
executive committee, board of directors, board of trustees, or owners. Contact

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with levels above the immediate superior should be initiated only with your
superior's knowledge, assuming he or she is not involved. Communication of such
problems to authorities or individuals not employed or engaged by the
organization is not considered appropriate, unless you believe there is a clear
violation of the law.
2. Clarify relevant ethical issues by initiating a confidential discussion with an IMA
Ethics Counselor or other impartial advisor to obtain a better understanding of
possible courses of action.
3. Consult your own attorney as to legal obligations and rights concerning the ethical
conflict

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