CIMA P3 2020 Notes
CIMA P3 2020 Notes
CIMA P3 2020 Notes
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CIMA P3
Risk Management
Overview of Paper P3 3
1. The types of risk facing an organisation 5
2. Responses to risk 11
3. Enterprise risk management 23
4. Some quantitative techniques 31
5. Corporate governance 43
6. Internal control and auditing 49
7. Ethical considerations 65
8. Cyber risks 69
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OVERVIEW OF PAPER P3
A Enterprise risk This looks at the types of risk that organisations are subject to, how
those risks can be assessed and how the risks can be dealt with.
B Strategic risk Strategic risk relates to long term risk: wrong products, wrong
market location, effects of technology and other long term
changes.
C Internal controls Internal controls enable organisations to be managed and directed
in a coherent way. Transactions are properly recorded, assets are
safeguarded and information used by management is accurate.
The operation of internal controls can be investigated by internal
audit.
D Cyber risks With more and more reliance on IT for both recording transactions
and as the mechanism by which value is delivered to shareholders,
it is imperative that cyber risks (ie risks relating to IT) are properly
addressed.
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Chapter 1
THE TYPES OF RISK FACING AN
ORGANISATION
1. What is risk?
‘Risk is a condition in which there exists a quantifiable dispersion in the possible outcomes
from any activity. It can be classified in a number of ways.’
CIMA Official Terminology, 2005
The key word in this definition is ‘quantifiable’. Both the probabilities that a particular outcome
occurs and its impact must be known. If the probabilities of different outcomes occurring are not
known then we are working under conditions of uncertainty, not risk.
Note that the strict definition of risk allows for good outcomes as well as bad
For example, insurance companies mostly deal with risk. For example, they maintain detailed
statistics of the following:
If probabilities, or the chance of an event occurring are not known (uncertainty) then organisations
and individuals are working much more in the dark.
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2. Types of risk
Risk can be categorised using the following terms:
๏ Pure risk: this is where there is the chance of loss but no chance of a gain. It is also known as
‘downside risk’. Often when risk is mentioned, this is the type of risk meant, but remember
that, strictly ‘risk’ is the spread of all results, good and bad. Examples of pure risk include: fire
destroying a factory, an IT system being hacked, an employee being injured at work and
fraudulent transactions by an employee.
๏ Speculative risk: this is where there can be both good and bad outcomes. It might
occasionally be called ‘two-way risk’. Examples include developing a new product, entering
a new market, buying a more advanced machine and developing a new web-site. Each of
these good go well or badly.
๏ Upside risk: the possibility of making a gain.
Favourable outcomes for the organisation and its stakeholders are not available unless risks are
undertaken. The key is the balance between the risk and the organisation’s performance.
Performance:
Conformance:
takes advantages
controls the
of opportunities to
downside risk
increase returns
IFAC: seek to balance conformance and performance. Compliance is necessary to avoid failure, but
it does not produce success.
Higher risks are needed if you are to produce higher returns. Compliance with rules, regulations
and controls does not of itself make an organisation successful. However, poor conformance with
controls and risk management strategies can certainly lead to organisational failure.
The aim of risk management is not to eliminate all risks: it is to understand and manage risks in line
with shareholders’ expectations about both risk and return.
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Risk
Low High
Low
Routine Avoid
Return/
Competitive
advantage
Identify and develop Cautiously examine
High
๏ Routine: extending moderate credit to a new customer. The maximum write-off of a debt
would be small and the customer will provide some income.
๏ Avoid: entering a joint venture with a company that has a poor reputation. Returns might be
small compared with the risk of the company’s goodwill being tarnished.
๏ Identify and develop: support of a well-known charity or sporting event to improve the
company’s reputation. This could create a very large increase in competitive advantage and
the risk would be low provided the third party were carefully chosen
๏ Examine cautiously: opening operations in a new country. There are considerable risks that
the expansion might fail, but is it is successful the rewards could be huge.
4. Categorisation of risks
There are many ways in which risks can be categorised. In many ways this isn’t important for its
own sake but the categories can act a checklists when trying to identify and anticipate risks.
๏ Strategic risks: these arise from long term effects such as those relating to
the nature and type of business, changes in competitive
and legal environments, poor long-term decisions being
made. For example, a supermarket which did not respond
to the growing popularity of on-line shopping would have
opened itself to a long-term decline in profits.
๏ Operational risks: short-term, day-to-day problems. For example, a machine
breaking down, a key employee leaving, a fire breaking out
in the warehouse or a fraud occurring.
๏ Reporting risks: risks arising because internal and external reporting are not
reliable. For example, management accounts containing
errors can lead to incorrect analysis and decisions.
๏ Compliance risks: the risks arising form not complying with rules and
regulations. Penalties, loss or reputation and removal of
operating licenses can all result.
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Some major risks are set out below, just to give you an idea of the wide variety of risks that
organisations might have to deal with. Each type of risk has one example given:
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Some people are risk seekers and like to gamble; others are risk averse. So, if betting on a horse
race, the risk seekers might be attracted to gamble on the high odds 100 to 1 horse. The risk averse
person would tend not to consider that sort of gamble. They have different attitudes to risk.
However, let’s say both people has $100,000 in the bank and were being asked to bet $100. Even
the risk averse person might be tempted to go for 100 to 1 odds. In this situation they have high
risk capacity because losing $100 is of little consequence. But what if each person had only $100 in
the bank? There’s a fair chance that neither would bet $100 because the consequences of losing
are so serious: they have very low risk capacity.
So, overall their appetite for risk (ie their appetite for the gamble) depends on their own attitudes
plus the risk capacity.
Remember organisations should obtain an acceptable balance between risk and return.
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Chapter 2
RESPONSES TO RISK
Establish risk
management group
and set goals
Identify risk areas
Ultimately risk management is the responsibility of the board (or, more broadly, those
charged with governance). However, like many functions in organisations the board is likely
to delegate responsibility to a sub-group of suitable specialists. The board should set goals
which reflect the risk appetite of the organisation. For example, if the organisation is an
airline, the board would set goals of Zero accidents but it might be prepared to tolerate a
degree of risk of bad publicity from over-booking flights.
It is important not to be complacent about risks. Some will be obvious and well-known but
others might be undiscovered until something goes wrong. We will see later in this Chapter
methods that might help to discover potential risks.
Not all risks are equal. Some risks that are discovered might be judged a being of little
consequence; others could be of major significance. Techniques will be covered later.
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Having identified and assessed the risks decisions have to be made about what to do about
them. The TARA approach will be explained later.
Simply identifying risks and working out suitable responses will not reduce risk: proper
actions have to be specified must to be consistently carried out. For example, ensuring that
the safety of machines is monitored or that customer credit limits are regularly reviewed.
Individuals have to be put in charge of risk management strategies and procedures and must
be held accountable for failures.
Controls must then be implemented. For example, setting out dates by which risks have to be
addressed, ensuring that inspections are done at regular intervals or by sending staff on
training courses. It is very important to document risk reduction strategies and how those
strategies are realised.
Of course, the solutions implemented to deal with identified risks are unlikely to work
perfectly the first time. They will often need to be improved. But it is also very important to
realise that nothing stand still: risks will be evolving all the time and the organisation must
keep them under constant review to ensure that all are properly addressed.
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Methods include:
๏ Physical inspection and observation (for example, that safety equipment is still used on
machinery).
๏ Inspect documents (for example, the accident log book).
๏ Internal audit. Internal auditors are employees of the company (usually) who examine and
report on the organisation systems of internal control. Not only do they report on financial
controls but they can also be required to examine systems such as quality control accident
reporting and so on.
๏ Outside consultants brought in to audit procedures (for example, security consultants to
advise on IT security).
๏ Observation of competitors’ procedures (question why they carry out operations in a
particular way).
๏ Enquiries (for example, ask employees, customers and suppliers about problems).
๏ Brainstorming (wide-ranging discussions to anticipate potential problems).
๏ Checklists (for example, use a checklist to evaluate how a job went and consider action where
there had been problems).
๏ Benchmarking (falling short of targets can imply that things are going wrong).
๏ External events (for example, be alert for economic events that could affect the organisation).
๏ Internal events (for example, high staff turnover can indicate problems with employments
conditions).
๏ Leading event indicators (for example, if a customer takes longer and longer to pay each
month then there would appear to be a risk of non-payment).
๏ Escalation triggers (for example, if you are twice late filing a tax return, then the third default
could be very serious).
๏ Event interdependencies (for example, a major customer going into liquidation could cause
excess inventory problems).
๏ Scenario planning and stress testing (see below)
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Scenario planning looks at all the things that could happen (and there can be many permutations
of future events) and from those builds viable scenarios: a number of believable, internally
consistent futures. This greatly reduces the number of ‘universes’ that need to be considered and
allows the organisation to focus on the relatively few most likely scenarios.
It operates on the principle that, for some decisions, thinking in terms of multiple possible futures,
or scenarios, is more effective than relying on single-point forecasts about the future.
For example, out political horizon might suggest that either Government 1 or Government 2 will be
elected within the next year. Our economic predictions might suggest that interest rates will be
either 3% or 5%. However, if Government 1 favours high public expenditure then this make 5%
interest rates much more likely as high interest rates are offered to allow government borrowing. If
Government 2 favours austerity, then interest rated are likely to stay at 3%. Therefore, the only two
viable scenarios are:
Government 1 Government 2
๏ Government 1; 5%
๏ Government 2; 3%
1. Define the scope, for example: What time horizon? Which part of the business? Which
country (for multi-national organisations)?
6. How should the organisation respond? For example, it could decide to retreat to an
Internet-only presence, it could move up-market/down-market, or it could withdraw
from the market.
7. Go back and recheck assumptions and scenarios in the light of decision made as some
decisions might affect these.
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๏ It can be very time-consuming: identification of all the relevant variables, collection of data
and the distillation to a few plausible, internally consistent scenarios.
๏ It is important to use experts who can assess possible outcomes – and the cost of experts‘
time can be considerable.
๏ It is important not to eliminate all scenarios except the most likely one or the most attractive
one. The point of scenario planning is to obtain a range of possibilities – both favourable and
unfavourable - and to plan for those.
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A stress test is, therefore, an assessment of how a system or strategy is likely to function if severe
adverse events occur. For example, would your company survive if your major customer went into
liquidation? What would happen if a major product had to be withdrawn (at the time of writing
Boeing has had to ground all its 737 Max 8 jets after two similar accidents involving nearly new
planes and, no doubt, airlines using those planes will ask for compensation). What would happen if
a monopoly supplier of a vital component were taken over by one of your rivals?
Stress tests should be carried out on all strategies, whether an existing strategy is being followed
(perhaps it has become high risk) or a new strategy is planned.
Of course, there will always be a problem envisioning all the things that can go wrong and deciding
if their probabilities are significant and many organisations can disapprove of the Jeremiahs in their
midst who think about calamity when the rest of the organisation is expected to embrace
enthusiastically and, perhaps sycophantically, the board’s new strategy.
It is therefore important that in the rules and culture of the organisation stress-testing becomes a
mandatory and valued.
There are many potential approaches to stress testing, but the following list is as helpful as any:
๏ Look to the future. What consumer trends, technical developments and political changes
might occur and which will affect the business. Going through the PESTEL headings and
projecting these into their possible future effects on the business can be a good start. Don’t
flinch from unpleasant possibilities or engage in wishful thinking: evaluate events’ likelihood
and their effects.
๏ Understand what makes your business currently successful. Understand your value chain and
what you are good at. What would happen if your unique capability in an important area
were to disappear? For example, if you were a pharmaceutical firm, what will happen when
your patent on a block-buster drug runs out? If you are a car manufacturer, what would
happen if a competitor discovers a battery technology that increases range by a factor of 10?
What happens if you a firm of lawyers and artificial intelligence develops to such a degree
that reliable advice can be offered on line and perhaps even disputes can be judged on-line?
๏ Does the strategy embody objectives? If there are no objectives (eg following the SMART
pattern of specific, measurable, achievable, relevant and time-limited) then the strategy is
useless as it will not be achieved.
๏ Is the strategy an incremental change to the current strategy (relatively safe) or a radical
departure (relatively dangerous)? Sometimes a radical approach is needed to save businesses
but be aware that the company is then venturing into areas where it will have little expertise
or market knowledge. Assumptions and feasibility have to be examined much more critically.
๏ Have stakeholders bought into the strategy? If there are powerful dissenters then the strategy
will probably not work.e
๏ Does the new strategy offer the hope of adding value for customers?
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๏ Set up a financial model and change the parameters and assumptions used to examine how
sensitive success or survival is to each. We can all produce cash flow forecasts on a
spreadsheet which allows our company to live within its overdraft limit. Simply change
assumptions about sales, costs etc until you get the required answer. But that is no way to
stress test? Be at least realistic, then be pessimistic. No reward will come without risk, but at
least understand the risks arising from the strategy.
So, questions that could be asked and scenarios that could be played out could include:
These can be built into sets of viable, if unpleasant, scenarios and the company can then respond
however it sees fit.
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Of course, these will be estimates, particularly the probability of an event occurring. However,
precise figures are not needed, just an idea of whether they are ‘high’ or ‘low’. Nevertheless you will
see some mathematical techniques that can be used to quantify events.
A very standard tool to assess the scale of the risk is a risk map (or assurance map):
Severity/impact
Low High
Low
Complete breakdown of IT
Loss of a mobile phone
system
Frequency/
probability
Note that there is nothing absolute about the categorisation of these risks. For example, the chance
of flight disruption has been assessed as high, but that depends on the airports used. Similarly, the
loss of a mobile has been categorised as being of low impact – but this wouldn’t be correct if that
mobile was the only place where important contact data is held.
Obviously, great attention should be given to risks in the bottom right hand quadrant (high/high)
whereas those risks in the top left quadrant are less important.
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6. Risk response
The risk responses can be remembered by the TARA approach:
Avoid The risk has been assessed as being so serious that all possibility of the event
occurring should be avoided.
Reduce Take steps to mitigate the risk. For example, instead of installing a new
computer system in every branch over one weekend, run a pilot operation
then gradually extend.
Accept Don’t do anything about the risk. It’s just part of everyday business
(You might occasionally see these approaches referred to as the 4Ts: Transfer, terminate, treat,
tolerate.)
The four responses can be mapped onto the risk map diagram a follows:
Severity/impact
Low High
Low
Complete breakdown of IT
Loss of a mobile phone
system
ACCEPT
Frequency/ TRANSFER
probability
Flight disruption because of
Routine staff turnover
bad weather
REDUCE
ABANDON
High
So, phones are lost (or stolen) from time to time and most people live with that risk (though
insurance is always a possibility and might be taken out foe very expensive hones).
The complete breakdown of an IT system could be dealt with by outsourcing the system so the
supplier shoulders the risk.
Routine staff turnover has costs associated with it (recruitment and training) so better employment
policies might be worthwhile to reduce the cost and disruption.
Flights to an airport with very bad weather or safety records might simply be abandoned because
they cause more trouble than they are worth.
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Gross risk = the risk before any mitigation (reduction) procedures. Gross risk is sometimes referred
to as inherent risk.
๏ The asset: what you are trying to protect. For example, property, cash, people, reputation
and so on.
๏ The threat: what you are trying to protect against. For example, destruction of property, theft
of cash, injury to people, damage to reputation.
๏ The vulnerability: weaknesses or gaps that can be exploited. For example, no fire alarms,
cash not banked, no hand rails on stairs, poor PR.
The gross risk can be reduced to a lower net risk, or residual risk by reducing any of these variables
through the application of counter-values or counter-measures.
Management must then decide whether the residual risk is within the organisation’s risk
appetite.
Examples:
Asset: the inventory in warehouse; threat: fire; vulnerability: full of inflammable material
Vulnerability: install smoke detectors and a fire suppression system that is suitable for the type of
inventory stored.
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Asset: valuable sales manager; threat: moves to a competitor; vulnerability: enticing offers from
competitors.
Asset: divide sales over two managers (each person is half as valuable).
Threat: impose contracts that require 3 – 6 months’ notice to make moving more difficult
The board and risk management committee should take an active interest in the risk register to
ensure that identified risks have been satisfactorily dealt with.
9. Assurance mapping
Risk identification and risk mapping identify the problems and their severity, but those processes
are a waste of time if suitable responses are not made. The risk register is one way to record risks
and to assign responsibilities for mitigating the risks where necessary. Another approach to ensure
that risks are properly dealt with is to construct an assurance map. The aim of an assurance map is
to identify where the safeguards against risks are to be found.
Assurance maps identify that an organisation has various lines of defences against risk. Typically
these are:
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1st line of defence Management-based assurance. For example, board policies and
management review.
2nd line of defence Internal procedures and legal-based assurance. For example,
health and safety legislation, risk registers, compliance with
reporting requirements, procedures and quality control tests.
3rd line of defence Independent assurance. For example, internal audit, external
audit, actuaries, consulting engineers, legal opinions.
Note that some organisations might identify slightly different lines of defence.
A table is then drawn up listing the risks, their importance and how the lines of defence deal with
those risks. For example
Human resources
etc
Here, black depicts strong assurance, grey depicts middle assurance and white depicts no
assurance.
Sometime an additional column is added to show the desired amount of defence against risks.
Each row is then scrutinised to ensure that the appropriate defences are in place somewhere in the
lines of defences to provide sufficient overall assurance that each risk has been sufficiently
countered.
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Chapter 3
ENTERPRISE RISK MANAGEMENT
1. Introduction
The CIMA Official Terminology uses the COSO (Committee of Sponsoring Organisations) definition.
Across the top of the cube are all the categories of risk that an enterprise can suffer from: strategic,
operations, reporting and compliance. These have already been discussed.
Down the side, going “into” the paper the enterprise is considered at various levels of operation:
the whole entity (think of group level); divisional level (Eg European, USA and Asian divisions); then
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business units (such as cars and commercial vehicles); finally subsidiaries (for example, different
marques of car).
Some risks will be felt at entity level – for example, the Volkswagen exhaust emission scandal. Other
risks will be more limited - for example, one make and model of vehicle that has to be recalled for
repair, or a subsidiary dealing with consumer finance for new vehicles not complying with lending
regulations.
Risk consolidation is the process of aggregating divisional/subsidiary risks at the corporate level.
Some risks can be handled together and be subject to a common approach, or they might even
substantially cancel.
For example, many organisations will organise insurance at the group level to cover injury to
employees anywhere in the group. This approach will usually be cheaper than insuring small
groups of employees separately.
Similarly, if one subsidiary is exporting and receiving US$, whilst another is importing and spends
US$, the net exposure to US$ currency movement might be very low and can be ignored at the
group level.
Down the front of the cube are the elements of a risk management approach:
๏ Internal environment
This can be regarded as the outlook and culture of the organisation, including its enthusiasm
for risk management and its risk appetite.
For example, some organisations are a bit happy-go-lucky when it comes to risk management
whereas others are extremely strict and want things to be done by the book.
๏ Objective setting
Objectives must exist before management can identify potential events affecting their
achievement. Enterprise risk management ensures that management has in place a process
to set objectives and that the chosen objectives support and align with the entity’s mission
and are consistent with its risk appetite.
For example, the objectives of a military operation might be to capture a town and to do that,
certain risks will be experienced and have to be assessed and evaluated.
The objectives of a research and development department in a business will establish the
risks that it suffers (such as a development failing to work).
The objectives of a marketing department will, again be quite different, and will be judged
against their risks such as the failure of a marketing campaign (or too much uptake on special
offers!)
๏ Event identification
As discussed earlier, there are internal and external events (both positive and negative) which
affect the achievement of an entity’s objectives and must be identified.
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๏ Risk assessment
As already discussed, risks are analysed to consider their likelihood and impact as a basis for
determining how they should be managed.
๏ Risk response
Management selects risk response(s) to transfer, avoid, reduce or accept risk (TARA).
The aim is to align risks with the entity’s risk tolerance and risk appetite. Risk tolerance is the
acceptable variation in outcome compared to an original objective. In setting risk tolerance,
management considers the relative importance of the related objective. So, if an objective is
particularly important, risk tolerances might be higher to recognise that achieving something
really worthwhile is worth accepting more risk.
๏ Control activities
Policies, procedures and control methods help to ensure risk responses are properly carried
out. Examples of control activities include authorisation of transactions, reconciliations,
segregation of duties (splitting a transaction so that several people are involved), physical
controls (such as locking away valuable inventory), the comparison of actual results to
budgets. IT controls can also be very important.
Information that monitors or identifies risks must be identified, recorded and communicated
quickly enough and in a way that lets people carry out their responsibilities by making
decisions. For example, if a product’s sales are lower than expected, this information must be
available quickly enough to change prices, alter the advertising campaign – or to withdraw
the product.
๏ Monitoring
The entire ERM process must be monitored and modifications made as necessary, to improve
current methodologies and to adapt to emerging risks, so that the system stays relevant.
3. Risk reports
UK quoted companies are now required to include risk reports as part of their annual reports. This
informs shareholders and others about the organisations’ main risks and what the company is
doing about them.
https://www.unilever.com/Images/governance_and_financial_report_ar15_tcm244-477381_en.pdf
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There may be other risks that could emerge in the future. We have also commented below on
certain mitigating actions that we believe help us to manage these risks. However, we may not be
successful in deploying some or all of these mitigating actions.
If the circumstances in these risks occur or are not successfully mitigated, our cash flow, operating
results, financial position, business and reputation could be materially adversely affected. In
addition, risks and uncertainties could cause actual results to vary from those described, which may
include forward-looking statements, or could affect our ability to meet our targets or be
detrimental to our profitability or reputation.
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Our supply chain network is exposed These contingency plans also extend to an
to potentially adverse events such as physical ability to intervene directly to support a key
disruptions, environmental and industrial supplier should it for any reason find itself in
accidents or bankruptcy of a key supplier which difficulty or be at risk of negatively affecting a
could impact our ability to deliver orders to our Unilever product.
customers.
We have policies and procedures designed to
The cost of our products can be significantly ensure the health and safety of our employees
affected by the cost of the underlying and the products in our facilities, and to deal
commodities and materials from which they with major incidents including business
are made. Fluctuations in these costs cannot continuity and disaster recovery.
always be passed on to the consumer through
pricing. Commodity price risk is actively managed
through forward buying of traded commodities
and other hedging mechanisms. Trends are
monitored and modelled regularly and
integrated into our forecasting process.
SAFE AND HIGH QUALITY PRODUCTS Our product quality processes and controls are
comprehensive, from product design to
The quality and safety of our products are of customer shelf. They are verified annually, and
paramount importance for our brands and regularly monitored through performance
our reputation. indicators that drive continuous improvement
activities. Our key suppliers are externally
The risk that raw materials are accidentally or certified and the quality of material received is
maliciously contaminated throughout the regularly monitored to ensure that it meets the
supply chain or that other product defects rigorous quality standards that our products
occur due to human error, equipment failure or require.
other factors cannot be excluded.
In the event of an incident relating to the safety
of our consumers or the quality of our
products, incident management teams are
activated in the affected markets under the
direction of our product quality, science, and
communication experts, to ensure timely and
effective market place action.
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Everyone is wise with hindsight and no-one in the organisations concerned would have wanted
these events to happen (though someone in VW was responsible for incorrect reporting).
However, as always, there is a balance to be struck between risk and performance. Quite obviously
there would be no oil spills if no company drilled for oil. BP had safety procedures in place but
either they were inadequate or BP suffered exceptional bad luck. Not only did the company have to
pay huge fines and compensation (about $60Bn) but it suffered severe reputational damage.
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Companies suffer reputation risk if their products or information gathering cause damage. The
unauthorised release of data can cause financial damage to customers.
Poor recruitment policies leave companies open to accusations of discrimination and this can cause
both reputational damage and can lead to legal claims.
Poor diversity policies can cause poor business results as products, services and employees no
longer match up to what customers expect.
Ethical issues
For example, a pharmaceutical company is developing a new drug. Some of the ethical issues
arising from this are:
How much testing should be done before the drug is marketed? The more testing the greater the
delay in releasing a drug very effective in treating a disease but, balancing that, more testing means
less chance of undiscovered side effects.
What price should the drug be sold at? A high price might please shareholders and could enable
more money to be spent on research and development of more drugs. However, a high price
would mean that some patients and health services could not afford the drug. Should different
prices be charged for the same drug in different countries depending on the country’s wealth?
Poor ethical choices present risks, particularly reputational and compliance.
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Chapter 4
SOME QUANTITATIVE TECHNIQUES
1. Introduction
This chapter looks at some techniques which can be used to assess the probability or effect of a risk
event.
๏ Expected values
๏ Value at risk
๏ Sensitivity analysis
๏ Risk adjusted discount rates
๏ Certainty equivalents
๏ Linear regression
๏ Simulation modelling
2. Expected values
Here is a simple expected values example. The expected value outcome is the sum of individual
outcome weighted by the probability of each occurring. So here there are two states of the world
(such as the economy doing well or poorly) and two once-off projects the company could invest in.
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The conventional advice as to which project to invest in would be to invest in Project A as it has the
higher expected value. However, you need to be careful about a number of factors:
(1) How have the probabilities been assessed? This must be very difficult in practice. Think about
how inaccurate opinion polls are at predicting election results.
(2) For a once-off projected the expected value is often (as here) not expected. The expected
incomes are $2,000 or $10,000 for Project A and $4,000 or $6,500 for Project B
(3) Expected values conceal risk. Say that each project cost $3,800. There is no prospect (as far as
is estimated) of Project B making a loss whereas Project A has a better than evens chance of
earning only $2,000 so that it would then make a loss of $1,800 – which could be fatal for the
company.
Because risk is concealed in expected values it is perhaps not the best tool to use for project
appraisal
Instead of using the probability estimates of 0.6 and 0.4, let them be p and 1 – p (note that they
must add back to 1 to ensure all outcomes have been included). Project A can now be represented
as:
If the project is to break=-even, the expected value of the outcome will equal to its cost of $3,800.
P = 0.775
So if the probability of state of the world I occurring rose from 0.6 to 0.775, Project A would break
even in present value terms. If the probability rose further, Project As expected value would be less
than the cost of the project.
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Mean, µ
If the possible results are closely clustered around the mean the standard deviation of the
distribution is small; if the results are very spread out, the standard deviation of the distribution is
large.
So if the mean daily value of a share is $30 and the standard deviation of its value is $1 the share is
rarely valued very far from $30. If, however, the standard deviation were $10, then the share’s value
would be very volatile, often worth more than, say, $40 and less than say $20.
Because all normal curves are of the same basic shape, they can be described using a set of tables,
as set out below.
The area under the curve holds all possible results and the table gives the proportion of those
results between the mean and Z standard deviations above (or below) the mean
Note, Z is the distance above or below the mean expressed as a number of standard deviations, so
for a value x, Z is:
x–μ
Z=
σ
So, if the mean height of a population was 178 cm with a standard deviation of 4cm, we can work
out what proportion of the population is 178 – 181 cm tall.
181 – 178
Z= = 0.75
4
Look up the table value for Z = 0.75 by going down the left hand column until you get to 0.7, then
across until you get to 0.05 and the table figure is 0.2734. That means 27.34% of the population is in
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the height range 178 – 181 cm tall. Because the curve is symmetrical, the same proportion of
people would be 175 – 178 cm tall.
x–μ
Z=
σ
μ x
Z 0.00 0.01 0.02 0.03 0.04 0.05 0.06 0.07 0.08 0.09
0.0 0.0000 0.0040 0.0080 0.0120 0.0160 0.0199 0.0239 0.0279 0.0319 0.0359
0.1 0.0398 0.0438 0.0478 0.0517 0.0557 0.0596 0.0636 0.0675 0.0714 0.0753
0.2 0.0793 0.0832 0.0871 0.0910 0.0948 0.0987 0.1026 0.1064 0.1103 0.1141
0.3 0.1179 0.1217 0.1255 0.1293 0.1331 0.1368 0.1406 0.1443 0.1480 0.1517
0.4 0.1554 0.1591 0.1628 0.1664 0.1700 0.1736 0.1772 0.1808 0.1844 0.1879
0.5 0.1915 0.1950 0.1985 0.2019 0.2054 0.2088 0.2123 0.2157 0.2190 0.2224
0.6 0.2257 0.2291 0.2324 0.2357 0.2389 0.2422 0.2454 0.2486 0.2517 0.2549
0.7 0.2580 0.2611 0.2642 0.2673 0.2704 0.2734 0.2764 0.2794 0.2823 0.2852
0.8 0.2881 0.2910 0.2939 0.2967 0.2995 0.3023 0.3051 0.3078 0.3106 0.3133
0.9 0.3159 0.3186 0.3212 0.3238 0.3264 0.3289 0.3315 0.3340 0.3365 0.3389
1.0 0.3413 0.3438 0.3461 0.3485 0.3508 0.3531 0.3554 0.3577 0.3599 0.3621
1.1 0.3643 0.3665 0.3686 0.3708 0.3729 0.3749 0.3770 0.3790 0.3810 0.3830
1.2 0.3849 0.3869 0.3888 0.3907 0.3925 0.3944 0.3962 0.3980 0.3997 0.4015
1.3 0.4032 0.4049 0.4066 0.4082 0.4099 0.4115 0.4131 0.4147 0.4162 0.4177
1.4 0.4192 0.4207 0.4222 0.4236 0.4251 0.4265 0.4279 0.4292 0.4306 0.4319
1.5 0.4332 0.4345 0.4357 0.4370 0.4382 0.4394 0.4406 0.4418 0.4429 0.4441
1.6 0.4452 0.4463 0.4474 0.4484 0.4495 0.4505 0.4515 0.4525 0.4535 0.4545
1.7 0.4554 0.4564 0.4573 0.4582 0.4591 0.4599 0.4608 0.4616 0.4625 0.4633
1.8 0.4641 0.4649 0.4656 0.4664 0.4671 0.4678 0.4686 0.4693 0.4699 0.4706
1.9 0.4713 0.4719 0.4726 0.4732 0.4738 0.4744 0.4750 0.4756 0.4761 0.4767
2.0 0.4772 0.4778 0.4783 0.4788 0.4793 0.4798 0.4803 0.4808 0.4812 0.4817
2.1 0.4821 0.4826 0.4830 0.4834 0.4838 0.4842 0.4846 0.4850 0.4854 0.4857
2.2 0.4861 0.4864 0.4868 0.4871 0.4875 0.4878 0.4881 0.4884 0.4887 0.4890
2.3 0.4893 0.4896 0.4898 0.4901 0.4904 0.4906 0.4909 0.4911 0.4913 0.4916
2.4 0.4918 0.4920 0.4922 0.4925 0.4927 0.4929 0.4931 0.4932 0.4934 0.4936
2.5 0.4938 0.4940 0.4941 0.4943 0.4945 0.4946 0.4948 0.4949 0.4951 0.4952
2.6 0.4953 0.4955 0.4956 0.4957 0.4959 0.4960 0.4961 0.4962 0.4963 0.4964
2.7 0.4965 0.4966 0.4967 0.4968 0.4969 0.4970 0.4971 0.4972 0.4973 0.4974
2.8 0.4974 0.4975 0.4976 0.4977 0.4977 0.4978 0.4979 0.4979 0.4980 0.4981
2.9 0.4981 0.4982 0.4982 0.4983 0.4984 0.4984 0.4985 0.4985 0.4986 0.4986
3.0 0.4987 0.4987 0.4987 0.4988 0.4988 0.4989 0.4989 0.4989 0.4990 0.4990
The use of the tables can be turned round to answer a question such as in what height range are
the 20% of who are people just taller than the mean. This means that the shaded area in the
diagram shown as part of the table has to be 0.2 as that represents the 20% of people just taller
than the mean.
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To solve this go to the ‘body’ of the table and look for 0.2. You will see that this is somewhere
between Z = 0.52 and 0.53 (areas = 0.1985 and 0.2019). In fact, 20% seems almost mid-way, so Z
would be estimated at 0.525.
x – 178
Z= 0.525 = = 0.75
4
So,
Therefore the 20% of people just taller than the mean of 178 cm will be in the height range 178 –
180.1 cm.
45% 50%
5%
Mean, µ
We are looking for where the cut-off is to leave only the 5% lowest values.
Let’s say that a shareholding has a mean value of $80,000 and the daily has a standard deviation of
$5,000. The shareholding could easily have a value of $81,000, $78,000 and so on but you would
have had some bad luck if tomorrow’s value were only $60,000. However, that low value would be
possible.
5% splits the left hand side of the curve into 5%/45%, or 0.05/0.45. The normal curve tables give the
area under the curve from the mean down or the mean up so would indicate the Z value for an area
of 0.45.
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Looking at the body of the tables for an area of 0.45, you will see that Z = 1.645 (mid-way between
1.64 and 1.65).
So, there is only a 5% chance that after one day the shares will be worth less than $71,775. There is
a 95% chance that the shares will be worth more than that.
Another way of expressing that is to say that we are 95% confident that the shares will not be
worth less than $71,775.
The value at risk (VAR) at the 95% confidence level is the maximum you stand to lose with a 95%
confidence, so that figure is:
If you were asked to calculate the VAR to the 99% confidence level, then you are splitting the curve
into 0.01, 0.49, 0.50 areas
49% 50%
1%
Mean, µ
The 49% (or 0.49) area needs to be found in the body of the tables (remember tables only give the
area from the mean up or down) and the Z value for 0.49 is about 2.33.
So, there is only a 1% chance of the shares being worth less than $68,350.
The value at risk to the 99% confidence level is 80,000 – 68,350 = $11,650
This means that there is only a 1% chance of the shares losing more than $11,650 in the course of a
day.
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What we need now is a standard deviation for share value for 10 days.
σperiod = σday √n
So, is the standard deviation of share value for 1 day is $5,000, for 10 days it would be:
So the value at risk to the 95% confidence level over 10 days would be:
Obviously, the value at risk over ten days must be greater than over just one day as there could be a
sequence of 10 days of ‘bad luck’.
7. Sensitivity analysis
Sensitivity analysis examines how a decision might change if one variable at a time is changed. It
is usually measured with respect to where a project or opportunity hits break-even point.
You might first have coma across the principle in contribution analysis:
So, the actual output could fall from its budgeted level of 10,000 units to 3,000 before a loss starts
to be made. The margin of safety (or sensitivity to volume) is 7,000 units or 70%.
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Sensitivity is often used to assess net present value calculations. Look at this example:
Example
Here is a project appraised at a discount rate of 10%. Sales volume is estimated at 1,000 units per
year.
Time $ 10% discount factor DCF $
0 Cost (130,000) 1 (130,000)
1 – 4 Sales 1,000@$100 = $100,000 3.17 317,000
1 -4 Marginal costs 1,000@$60 = ($60,000) 3.17 (190,200)
4 Scrap 25,000 0.683 17,075
NPV 13,875
The NPV is positive so the conventional advice would be to accept the project. However, the
sensitivity of this recommendation to the various assumptions should be examined. This is done by
seeing how far an assumption can change before the NPV = 0. Each assumption has to be assessed
separately.
Required
Examine the sensitivity of the solution to:
(a) Initial cost
(b) Selling price
(c) Sales volume
(d) Scrap value
(e) Discount rate
Solution
(a) If the NPV is to be zero, the cost must rise by $13,875 to extinguish the NPV.
Sensitivity = 13,875/130,000 = 10.7%
(b) Selling price affects the revenue figure. If its PV of $317,000 falls 13,875 then NPV = 0.
Sensitivity = 13,875/317,000 = 4.4%
(c) Sales volume affects both revenue and marginal costs: 317,000 – 190,200 = 126,800
Sensitivity = 13,875/126,800 = 10.9%
(d) The PV of the scrap value must fall by $13,875 to produce a zero NPV.
Sensitivity = 13,875/17,075 = 82%
(e) To work out the sensitivity to the discount rate, the IRR has to be calculated. So, NPV at 20%:
By interpolation
IRR = 10 + (20 – 10) x13,875/(13,875 + 14,350) = 14.9, or around 15%
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So, the NPV is very sensitive to the selling price, which only needs to fall by about 4.4% before the
project just breaks even. Not only is 4.4% small, but the selling price is probably difficult to
estimate.
The cost could rise by about 10%. Not a large over-run, but at least cost is easier to predict and
control than future flows.
Scrap value could fall by 82% - a large fall, but it will usually be difficult to predict the scrap amount.
The discount rate can rise from 10% to 15% (50%) and that would probably be judged unlikely.
Note
๏ Sensitivity analysis allow only one variable to be changed at a time, whereas some changes
might well be linked.
๏ It also say nothing about how likely a variable is to change. We have said that the project is
very sensitive to selling price (4.4%), but if the selling prices had been already agreed for a
four year contract, that 4.4% drop is unlikely to happen.
9. Certainty equivalents
Another way to account for future inflows being uncertain is to reduce them to their certainty
equivalent, which can be defined as:
“the guaranteed amount of money that an individual would view as equally desirable as a risky
asset.”
So, the flows being received at each of times 1, 2, 3 might be reduced to 90%, 75% and 60% of their
‘face values’ to account for further off flows being less certain.
There is no set way to reduce future flows. For example, for a particular project the reductions
might be to 80%, 70% and 50%
The resulting cash flows would then be discounted the risk free discount rate. Do not reduce the
flows to their certainty equivalence AND use a risk adjusted discount rate as that would be double
counting.
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The predictions that might be made can be used by organisations to plan better and this will
reduce risk. For example, if a company is think of reducing its selling price, it needs to have an idea
of the volume of goods that will sell otherwise it risks not being able to meet demand and of
alienating customers.
Linear regression will give constants which fit a line of the type:
y = ax + b
where:
The constant ‘a’, for example, could be the additional cost for each additional unit made; ‘b’ would
be the cost even if no units were made (the fixed cost).
However, be warned: linear regression will give the best line it can through any set of points.
For example, if you numbered the days in the year 1 – 365 and you noted the day each person was
born and the amount of money they had in their bank account, linear regression would suggest the
best relationship it could between these variables. Obviously there would not actually be a good
relationship.
To test the relationship you must calculate the coefficient of correlation (r), or the coefficient of
determination (r2). r can vary between:
r = +1, meaning perfect positive correlation where all points lie on the line and as one variable
increases, so does the other.
r = -1, meaning perfect negative correlation where all points lie on the line and as one variable
increases, the other decreases.
r = 0 means no correlation.
If r = 0.7, r2 = 0.49 or about 50%. This means that 50% of the change in one variable is explained by
the change in the other.
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You should be aware of the following before you rely on any prediction based on linear
regression:
๏ If r2 is low, then one variable is not well-associated with the other, so any predictions are liable
to be poor.
๏ The more points (readings) the better: simply more evidence for the association.
๏ Extrapolation (predicting outside the range examined) is dangerous as we have no direct
evidence of what happens in other regions. For example, costs might suddenly increase.
๏ Other known influences (such as inflation) should be removed before the analysis.
๏ Even good correlation does no prove cause and effect: both variables might have moved
together under the influence of another variable.
For example:
If the market grows 10% in one year, there is a 75% chance that it will grow 10% the following year
and a 25% chance that it will decline 10%. Similarly, decline of 10% in one year gives a 75% chance
of 10% decline the next and a 25% chance of 10% growth.
To set up the simulation ranges of numbers are assigned to mimic the probabilities:
๏ If there is growth one year then for the next year: 00 – 75 = further growth; 76 – 99 = decline
๏ If there is a decline one year then for the next year: 00 – 75 = further decline; 76 – 99 growth.
Let’s start with sales of 1000 units and assume that the previous year showed growth. Random
numbers are then generated. For example: 63, 41, 5, 67, 98, 37, 74, 3, 12, 34 , 95… and so on
Random number 63 41 85 67 98 37 74 83 12 95
Growth/decline +/- 10% G G D D G G G D D G
Sales 1100 1210 1089 980 1078 1186 1305 1175 1057 1163
This allows typical trading patterns to be examined and would allow the company to see what
might happen if it had several years of decline in a row.
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Chapter 5
CORPORATE GOVERNANCE
The problem is that although the shareholders own companies, the day-to-day management and
direction of companies is given to the Board of Directors. In large companies, many shareholders
are relatively passive and the Board of Directors are given more or less free rein to make whatever
decisions they wish.
Auditing was instituted so at least once a year, when the accounts were presented to the members
of the company, the auditors would examine the accounts and give some expression of opinion to
the members of the company as to whether the accounts were true and fair. Without that
assurance the members of the company really would have a little idea as to whether or not the
accounts were worth relying on. The auditors therefore examine the financial statements and this
adds credibility to those statements, the shareholders have a much better idea of the performance
of the directors and the company.
Appoint independent
Auditor
Adds
credibility
Measure
performance
Financial Statements
Prepare FS
Appoint
Shareholders Directors
Own Manage
Company
Note that shareholders appoint the independent auditors, they also appoint the directors. The
problem is however that once directors were appointed, shareholders often didn’t take much
further interests in what the directors were doing. Scandals such as Enron, Worldcom in the early
2000’s and perhaps banking problems in 2008 showed that this hands-off approach was entirely
inadequate and additional safeguards have been instituted to try to ensure that directors act in the
best interests of the members of the company.
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The code states that the purpose of corporate governance is to facilitate effective entrepreneurial
and prudent management that can deliver long-term success of the company. It then goes on to
list the main principles of the code:
Main principles
๏ Leadership
๏ Effectiveness
๏ Accountability
๏ Remuneration
๏ Relations with shareholders
Comply or explain
The code has no force in law and is enforced on listed companies through the Stock Exchange.
Listed companies are expected ‘‘comply or explain’’ and this approach is the trademark of
corporate governance in the UK. Listed companies have to state that they have complied with the
code or else explain to shareholders why they haven’t. This allows some flexibility and non-
compliance might be acceptable in some circumstances.
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Leadership
๏ Every company should be headed by an effective board which is collectively responsible for
the long-term success of the company.
๏ There should be a clear division … between the running of the board and the executive
responsibility for the running of the company’s business. No one individual should have
unfettered powers of decision. This means that the roles of CEO and chairman should not be
performed by one person as that concentrates too much power in that person.
๏ The chairman is responsible for leadership of the board
๏ Non-executive directors (NEDs) must be appointed to the board and they should
constructively challenge and help develop proposals on strategy. NEDs sit in at board
meeting and have full voting rights, but do not have day-to day executive or managerial
responsibility. Their function is to monitor, advise and warn the executive directors.
Effectiveness
๏ The board should have an appropriate balance of skills, experience, independence and
knowledge. In large companies NEDS should be at least 50% of the board; in small companies
there should be at least 2 NEDS.
๏ New directors should be appointed by a Nomination Committee to ensure a formal, rigorous
and transparent procedure for their appointment. The Nomination Committee consists of
NEDs. This provision is to prevent directors appointing their friends and colleagues to the
board and ensures that the best people for the job are considered and appointed.
๏ All directors should be able to allocate sufficient time to company business
๏ There should be induction on joining the board and a programme to update and refresh
directors’ skills and knowledge.
๏ The board should be supplied in a timely manner with necessary information
๏ The board should undertake a formal and rigorous annual evaluation of its own performance
and that of its committees and individual directors.
๏ All directors should be submitted for re-election at regular intervals
๏ The board should present a balanced and u
Accountability
๏ The board should present a balanced and understandable assessment of the company’s
position and prospects.
๏ The board is responsible for determining the … significant risks …and should maintain sound
risk management and internal control systems.
๏ The board should establish formal and transparent arrangements for applying the corporate
reporting, risk management and internal control principles, and for maintaining an
appropriate relationship with the company’s auditor. This means that an Audit Committee
(NEDs again) should be established to liaise with both internal and external auditors. Before
audit committees, the finance director liaised with auditors, but this was not satisfactory
because the finance director was often the person responsible for accounting problems.
Therefore auditors were often reporting problems to the person who caused them. The
directors are responsible for establishing an internal control system and must review the
need for internal audit.
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Remuneration
Note the point that a significant proportion of executive directors’ remuneration should be related
to the profit or other success of the company. A long term relationship is really what’s wanted so
that directors cannot manipulate profits in the short term to manufacture bonuses for themselves.
Share option schemes can be very effective methods of remuneration. For example, if the current
share price is $8, offer share options at $15, available after four years (the vesting period). If, after
four years, the share price has risen above $15, directors will exercise their options to buy at $15 as
this will produce a profit for them. If the share price were only $12, the options would not be
exercised. Therefore, the scheme encourages directors to act in a way that increases the long-term
share price of the company – precisely what the shareholders would want then to do.
One of the problems with achieving good corporate was encouraging shareholders to take an
active interest in the company. Too often they did not fully participate at AGMs and would wave
through motions. This passive attitude might well have been encouraged by directors to move
power towards them and away from members.
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Special investigations
Liaison with external auditors:
• Scope of external audit
• Forum to link directors/auditors
• Deal with auditors’ reservations
• Obtain information for auditors.
The committee should be dominated by non-executive directors. The functions are as follows:
๏ They will review the work of internal audit. Companies don’t have to be an internal audit
department, but corporate governance rules now stated management should keep the need
for internal audit on the review.
๏ The audit committee will review the system of internal control. Corporate governance now
imposes on management the requirement that they implement a system of internal control.
๏ From time to time the audit committee may launch special investigations. For example, if a
fraud had been discovered within the organization the audit committee may ask for a report
on how it happened and how to prevent it in the future.
๏ Liaison with external auditors. It used to be that external auditors would communicate almost
exclusively with the finance director, but of course the finance director may not be sufficiently
independent of the finance function and the system of internal control. Now, the audit
committee will set the scope for the external audit. They act as a forum to link directors and
auditors. Auditors will typically write to the audit committee about any problems they may be
having on the audit or obtaining all the information they require. If the auditors are worried in
someway about the financial statements they will raise those concerns with the audit
committee.
๏ If the auditors can’t find information in any other way and feel perhaps they are being
obstructed, they can go to the audit committee and explain the problem and the audit
committee can try to investigate on their behalf.
๏ Liaise on the process of appointing auditors and setting their fees. (Note that the external
auditors are appointed by members in general meeting, but the audit committee is likely to
make recommendations.)
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Chapter 6
INTERNAL CONTROL AND AUDITING
Internal control:
‘The management system of controls, financial and otherwise, established in order to provide
reasonable assurance of: (a) effective and efficient operation (b) internal financial control (c)
compliance with laws and regulations’
Examples if the three areas of internal control mentioned in this definition are:
Note that the term encompasses more than just financial controls - though it is financial controls
that auditors will concentrate on.
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You might remember the front face of the COSO cube on enterprise risk management. That set out
how risks should be managed. It is worth repeating that here to see the similarities between the
COC elements of risk management and the ISA elements of internal control.
๏ Internal environment
This can be regarded as the outlook and culture of the organisation, including its enthusiasm
for risk management and its risk appetite.
For example, some organisations are a bit happy-go-lucky when it comes to risk management
whereas others are extremely strict and want things to be done by the book.
๏ Objective setting
Objectives must exist before management can identify potential events affecting their
achievement. Enterprise risk management ensures that management has in place a process
to set objectives and that the chosen objectives support and align with the entity’s mission
and are consistent with its risk appetite.
The objectives of a manufacturing department is to make the right goods to the right quality
and at the right cost. The department cannot be managed without objectives and
performance measurement.
The objectives the accounts receivable department will be to achieve a certain collection
period and to minimise bad debts. Again, objectives and targets are needed to manage and
appraise this process.
Similarly, with regard to minimum wages, unless those are defined and compared to actual
wages, no control is possible.
๏ Event identification
There are internal and external events (both positive and negative) which affect the
achievement of an entity’s objectives and must be identified. For example, there must be a
way of accounting for waste and quality control failures.
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๏ Risk assessment
Risks must be analysed to consider their likelihood and impact as a basis for determining how
they should be managed. The results of this exercise should be noted on the risk register and
the assurance mapping document.
๏ Risk response
Management selects risk response(s) to transfer, avoid, reduce or accept risk (TARA).
The aim is to align risks with the entity’s risk tolerance and risk appetite. Risk tolerance is the
acceptable variation in outcome compared to an original objective. In setting risk tolerance,
management considers the relative importance of the related objective. So, if an objective is
particularly important, risk tolerances might be higher to recognise that achieving something
really worthwhile is worth accepting more risk.
๏ Control activities
Policies, procedures and control methods help to ensure risk responses are properly carried
out. Examples of control activities include authorisation of transactions, reconciliations,
segregation of duties (splitting a transaction so that several people are involved), physical
controls (such as locking away valuable inventory), the comparison of actual results to
budgets. IT controls can also be very important.
Information that monitors or identifies risks must be identified, recorded and communicated
quickly enough and in a way that lets people carry out their responsibilities by making
decisions. For example, if a product’s sales are lower than expected, this information must be
available quickly enough to change prices, alter the advertising campaign – or to withdraw
the product.
๏ Monitoring
The entire process must be monitored and modifications made as necessary, to improve
current methodologies and to adapt to emerging risks, so that the system stays relevant. For
example, if the company starts to trade on the internet a whole new set of risks arises. For
example, their system could be ‘hacked’. More on this in a later chapter.
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3. Responsibilities
The UK Corporate Governance Code states that it is the responsibility of the board of directors
to establish procedures to manage risk, oversee the internal control framework and
determine the nature and extent of the principle risks that the company is willing to take in
order to achieve its ling-term strategic objectives.
It is then the responsibility of the audit committee (a sub-committee of the board) to review
the company’s internal financial controls and internal control and risk management systems
unless expressly addressed by a separate board risk committee composed of non-executive
directors or the board itself.
The audit committee should review the effectiveness of the company’s internal audit function
or, if there isn’t one considering annually whether one is needed and making a
recommendation to the board.
The audit committee must also review the effectiveness of the external audit process.
๏ Segregation of duties: split up the stages of a transaction so that one person doesn’t carry out
every step. This helps to stop fraud and also means that several minds are involved in
ensuring the transaction is correct.
๏ Physical: for example, lock cash and inventory away.
๏ Authorisation and approval: for example, overtime claims are signed by managers as
approval.
๏ Management and supervision: managers and supervisors keep an eye on what’s going on.
๏ Organisation: for example, ensuring that the sales team can’t decide on sales prices to boost
demand and their commissions.
๏ Arithmetic and accounting: reperform calculations. Carry out reconciliations.
Internal control systems should be set out in a procedures manual and internal auditors will assess:
๏ Not cancelling suppliers invoices when posted/paid (they could go round the system again).
๏ Employees self-certifying time sheets and expense claim forms
๏ Ability of junior staff to write off debts (or to carry out other journal entries).
๏ Not ensuring that cash receipts are promptly banked
๏ Not establishing credit limits for customers and not following up slow payers
๏ Not approving orders for material so that too much of the wrong type can be ordered
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External audit:
‘A periodic examination of the books of account and records of an entity carried out by an
independent third party (the auditor), to ensure that they have been properly maintained, are
accurate and comply with established concepts, principles, accounting standards, legal
requirements and give a true and fair view of the financial state of the entity.’
There is a statutory requirement for all but the smallest company’s to have an external audit each
year. This reports to the members (shareholders) on whether or not the financial statements (in the
opinion of the auditor) show a ‘true and fair’ view.
Internal audit:
‘An independent appraisal activity established within an organisation as a service to it. It is a
control which functions by examining and evaluating the adequacy and effectiveness of
other controls; a management tool which analyses the effectiveness of all parts of an entity’s
operations and management.’
(CIMA’s Management Accounting Official Terminology)
CIMA members and the P3 exam are primarily focussed on internal audit.
Whereas external auditors are employed by an independent firm (such as one of the ‘big four: PWC,
KPMG, EY and Deloittes) internal auditors (IA) are usually employees of the company (though the
process of internal audit can be outsourced) and this can interfere with the independence and of
the internal audit function. IA might fall under the control of the finance director and then IA staff
would potentially have to report problems with financial internal control to the director who has
prime responsibility for internal control. It is easy to see how the finance director might like
problems to be minimised or ‘hushed up’. It is therefore strongly recommended that IA reports to
the audit committee, chief executive officer and board of directors rather than to the finance
director.
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AR = IR x CR x DR
Audit Risk
Control risk
The audit risk model sets out the current, risk-based, approach to auditing.
Audit risk is the risk that the auditor comes to a wrong conclusion about a figure in the financial
statements or the accounting system. For example, the auditor, whether internal or external,
concludes that an amount is correct when, in fact, it is wrong.
๏ Inherent risk: this is the risk that an error is made in the first place before the application of
any controls of checks. Inherent risk is increased by factors such as:
‣ Inexperienced staff
‣ Time pressure
‣ Complex transactions
‣ Figures requiring a high degree of estimation
‣ Pressure to perform well eg to make results look good.
‣ Control risk: this is the risk that the organisations system of internal control does not
prevent or detect the error. For example, a junior employee might have committed an
error (inherent risk), but good supervision and checking of that person’s work should
detect and correct the error.
If both of these occur, then a wrong figure is in the financial statements or in the accounting
records.
๏ Detection risk: this is the last line of defence and this refers to work the auditor does. If the
auditor performs a lot of work, detection risk will be low as there is a good chance that the
audit work detects the problem. If the auditor does relatively little work, then the chance of
picking up an error will be low.
Auditors can’t alter inherent risk or control risk in the short term (though they should certainly
be able to influence control risk in the long term). Therefore, to keep the audit risk low (and
this is essential), if the auditor perceives high inherent and control risk, a large amount of
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audit work will have to be performed. If, however, the auditor perceives inherent and
control risk to be low, the auditor will perform much less audit work yet still achieve a
reasonable degree of assurance about the figures in the accounting system.
9. Audit planning
The first step in any audit is to plan: what are the main risks? How will they be addressed? How
many auditors do we need and with what experience? How long will it take? How many locations
do we need to visit?
Knowledge of the business. For example, a jewellery business will have high risk in inventory (small,
high-valued items).
๏ Talking to staff. For example, they might tell the auditor of an accounting problems or that
the new IT system was giving problems.
๏ Analytical procedures or analytical review. Compare this period’s results with last period’s
results and with budgets. Analytical reviews are quick to carry out and can be used to
highlight areas where something might have gone wrong and therefore where risk is high.
For example, if receivables collection periods have increased from 34 days to 56 days the
auditors need to know why. Is it a deliberate change to the credit terms? Are there more
export customers where the transportation of the goods can take time so that payment is
delayed? Has the credit control department become sloppy? Is it an error? Is there a large
unrecoverable amount that should perhaps be written off? Another example would be if the
gross profit percentage had risen from 30% to 40%. How can that happen in a competitive
market? Perhaps the company had a technical breakthrough so that it could make and sell a
uniquely good product? However, it might be more likely that an accounting error or change
in accounting policy is the cause. Remember, supermarkets get quite excited if their like for
like sales rise by just a few percentage points over a year so a GP% jump from 30% to 40% is
remarkable..
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Even very small businesses will usually maintain their computer records on computer. There are
many advantages to this, not least that trial balances will usually balance and control accounts will
reconcile to the underlying detailed records. However, the absence of as many hand-written data
and documents data can make auditing more difficult. For example, it can be difficult to test
whether a computer is carrying out a procedure correctly and it can be more difficult to ‘see’ and
examine the information and records than in a manual system.
Computer Assisted Audit Techniques (CAAT) have been developed to assist the auditor when the
client maintains computerised records.
Audit software (or audit programs) is software developed and used by auditors. Audit software
allows clients’ accounting data files to be read and examined.
๏ Adding up the records. For example, inventory values and receivables balances. The totals are
the amounts that should appear in the statement of financial position.
๏ Performing calculations for analytical reviews.
๏ Identifying and printing details of unusual items for further investigation, such as credit
balances on a receivables ledger or negative inventory balances.
๏ Picking samples. For example, that audit software can be programmed to create a stratified
sample or a pure random sample.
๏ Picking all items with particular characteristics, such as all sales orders approved by a certain
employee.
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Once it is set up, audit software can quickly, efficiently and economically examine every item on a
data file. This which would often be difficult or impossible if attempted manually. It can greatly
speed up audit completion and reduce costs.
Test data is auditor’s data that is operated on by client’s program. It is used to test the workings and
resilience of programs.
Is processed by
Auditor’s Test data Client’s programs
The results produced by client programs are compared with predictions of what should happen
and any discrepancies are investigated.
๏ Test that calculations are carried out correctly by client software. For example, enter time
sheet data of 50 hours worked and ensure that the correct wages and tax are calculated.
๏ Test that programmed controls and procedures are carried out correctly. For example, if a
client’s system should reject orders from customer over their credit limit, test that such orders
are indeed rejected by entering an order that should be rejected. Another example of a
programmed control would be testing that only staff members who are allocated certain
privileges can log-on and change someone’s salary: log-on with what should be inadequate
rights and ensure that you cannot change a salary.
๏ Test how resilient software is against input errors. For example, test what happens if an
account number is entered incorrectly, or a negative amount of stock id ordered, or an
impossible date is entered.
Test data might be the only way in which certain controls can be verified. For example, a company
web-site might properly reject an order from a customer, but there might be no permanent record
available to the auditors to verify that this control is happening.
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Details about the nature of the The possible effects of these Suggestions for fixing the
internal control deficiency and deficiencies and departures problems
departures from the specified
internal control procedures
๏ Qualified
๏ Experienced
๏ Independent
๏ Professional
Although ultimately they report to the board this will often be through the audit committee. Even
then, because of the employer/employee relationship it might be difficult for internal auditors to
criticise internal controls set up by the finance director.
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It is increasingly common for the internal audit function to be outsourced (ie internal audit
functions are externally supplied). Advantages and disadvantages of this are as follows:
Advantages Disadvantages
No recruitment, staffing or training worries Less knowledge and expertise about the
business
Specialist services will be available from large Cost – external providers will charge quite high
external suppliers that might be difficult to hourly rates.
provide in-house eg forensic investigations
Flexibility to carry out special investigations There can be ethical complications if external
that are urgent auditors are used in an internal audit function
Quicker to set up initially
14. Fraud
14.1. Introduction
๏ Fraudulent financial reporting. For example, overstating profits to generate high directors’
bonuses, boost the share price or to achieve a good sale price for the company.
๏ Misappropriation of assets. For example theft of cash or inventory.
Managers and those charges with governance are responsible for the prevention or detection of
fraud. Auditors should always be aware of an organisation’s susceptibility to fraud.
๏ It is often carried out by repeatedly misappropriating small amounts that escape individual
scrutiny.
๏ Fraudsters take steps to conceal their actions, for example, forging documents. These can be
very difficult to identify.
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๏ Incentive
๏ Opportunity
๏ Attitude/dishonesty
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๏ prevention
๏ detection
๏ response
Deterrence is the result of prevention (too difficult to get to the inventory to steal it), detection (you
will be subject to random searches as you leave the factory), response (you will definitely be
prosecuted).
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Chapter 7
ETHICAL CONSIDERATIONS
1. Ethics
1.1. Introduction
Ethics is concerned with distinguishing between good and evil, between right and wrong human
actions, and between virtuous and non-virtuous characteristics of people and organisations, and
the rules and principles that ought to govern behaviour.
There is, of course, a range of views on what constitutes ethical behaviour. Different individuals and
people from different cultural backgrounds might disagree on what constitutes acceptable
behaviour in business. For example, in Japan punctuality is extremely important and to be late for a
meeting is simply unacceptable. People from some other countries assume that a meeting starting
at 2pm probably won’t start until 3pm and punctuality is almost seen as a peculiarity. Ethical
judgements also differ on matters such as:
We do not need to get into how or why certain actions are considered ethical or unethical, but if
investors, governments and customers or employees think, for whatever reason, that a company
has acted unethically then the company will be damaged because of reputational loss, regulatory
and legal sanctions, and also the fear that if one instance of unethical behaviour has been
discovered how many other instances might still be hidden.
Perhaps what is most important is that stakeholders are informed about a company’s ethical
position on a number of issues so that there is openness and that everyone understands the
company’s ethical stance. Corporate codes of ethics can help to achieve this and therefore
manage risks arising form unethical behaviour. These are documents issued to employees that
attempt to establish ethical rules or guidelines so that employees know how to behave if, for
example, offered a bribe by a supplier or they see a machine in a dangerous condition, or they are
considering whom promote.
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Often these guidelines are made available to outside stakeholders to advertise the company’s
ethical stance. For example, the Coca Cola ethical guide can be found at:
http://assets.coca-colacompany.com/45/59/f85d53a84ec597f74c754003450c/COBC_English.pdf
Here is a short extract from the section dealing with treatment of customers, suppliers and
consumers:
“Always deal fairly with customers, suppliers and consumers, treating them honestly and with
respect:
Employee training and full support from the top of the organisation is needed if an ethical culture is
to be adopted. There is little point in handing employees the organisation’s Ethical Guide if they are
not taught how to apply it or if directors and managers ignore it.
Even if stakeholder disagrees about what appropriate ethics are, the importance of an organisation
being ethical can be linked to its profitability or its financial viability. Organisations might obtain
advantages by being unethical (for example to encourage sales a pharmaceutical company could
conceal a drug’s side effects) but most ethical breaches are discovered and then huge damage is
done both financially and reputationally. Good ethics therefore:
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The Code of Ethics sets out certain fundamental principles about how its members should behave.
It also recognises how its members could be subject to certain threats which would compromise
their behaviour and suggests ways in which members can safeguard themselves against the
operation of those threats.
The guide applies to all members of CIMA working in industry, commerce and public practice. It
also applies to all CIMA students. Note that its operation is not restricted to auditors and covers
CIMA members working in industry and commerce. The fundamental ethical principles are:
Compliance with the ethical guidelines is continually threatened. For example, integrity and
objectivity can be threatened by personal relationships which could mean that an accountant does
not want to report errors made by colleagues. Accountants have to ensure that threats are reduced
to acceptable levels.
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Chapter 8
CYBER RISKS
Cyber risk can be defined as any risk of financial loss, disruption or damage to the reputation
of an organisation by some sort of failure of its information technology systems.
Before we address specific risks and how they might be defended against it is worth looking first
briefly at how organisations use computers and the various physical arrangements that IT systems
can adopt.
Corporate /
Strategic Level
Business / Management
Control
Operational Control
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๏ Forward-looking (at this high level of management, people should be planning for the future)
and historical.
๏ Often has to deal with estimates
๏ Often not to the last degree of accuracy – perhaps dealing with the nearest $1m.
๏ Outward-looking (how are competitors, countries economies and technologies developing?)
๏ Supports unstructured decision-making ie where there is no definitive way at arriving at the
right answer. For example, should we open an operation in Brazil?
๏ Non-routine/ad hoc.
๏ Historical
๏ Routine
๏ Internal
๏ Very accurate
๏ Supports structured decisions such as don’t accept an order if over a customer’s credit limit)
Information for business and management control (in the middle) is:
๏ Moderately forward looking (for example, will the division reach this year’s budget?)
๏ Semi-structured decisions (such as should we manufacture more stock?)
๏ Reasonably accurate.
Disruption of IT at any level can be devastating for a company. For example, the routine processing
of sales orders, whether they are received via the company’s internet site or through the post is
part of the operational level. Obviously things could go wrong in either case, but the opportunities
for chaos are much greater in the Internet system because once a company is connected to the
Internet, the Internet and all its users, many of whom might be malicious, are connected to the
company.
As you go up through the hierarchy, into the corporate and strategic level, the information is more
likely to deal with the company’s future plans. So if board minutes are held on computer and these
become available to outsiders and competitors (through industrial espionage) very serious long-
term damage can be inflicted on the company.
Perhaps, the specifications of designs, chemical formulae for pharmaceuticals in clinical trials,
databases about suppliers are held in the middle, managerial level. Any leakage of that information
(industrial espionage again) can again seriously impact an organisation’s profitability and its
chance of survival.
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Only the very smallest of businesses will have stand-alone computers ie computers not connected
to other computers. Even in small businesses employees need to share data and very soon after
personal computers were invented networks of computers were introduced.
๏ Local area network (LAN): Here the network extends over only a relatively small area, such
as an office, a university campus or a hospital. The small area means that these networks use
specially installed wiring to connect the machines.
๏ Wide area networks (WAN): Here the network can extend between several cities and
countries. Each office would have its LAN, but that connects to LANs in other offices and
countries using commercial, public communications systems. At one time this would have
been done by the organisation leasing telephone lines for their private use to transmit data
from office to office. However, this is expensive and inflexible and the common system now
used is known as a virtual private network (VPN).
๏ The presentation tier: this is what you see on your computer screen: information, boxes in
which to input data, buttons to click on, drop-down menus to choose from. This will be on
the client machine.
๏ Application tier: this tier, sometimes known as the logic or business logic tier, is where
processing takes place. It can be on the client machine or in the cloud. (see later).
๏ Data tier: where the data is stored, typically a database. It will normally be on the server
machine or in the cloud.
So, if you are posting a supplier’s invoice, you will enter the account number into the presentation
tier, the application will access the data tier, fetch the customer name and this will be shown to you
in the presentation tier. You will enter the amount and nominal code in the presentation tier, the
application tier might split out VAT automatically, then post the amounts to the appropriate files in
the data tier.
๏ A presentation tier might be hijacked so that it looks like, for example, your bank’s web-page,
but it is actually a page mocked up to look official (phishing)
๏ The application tier might be changed to calculate invoices incorrectly.
๏ The data tier might be accessed so that confidential data is stolen or records altered.
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VPN’s allow data to be transmitted securely over the internet between any two locations.
Information will pass over many different circuits and connections but the system gives the
impression that you are operating over a dedicated, private communications link: hence the name:
virtual private network. For example, an employee working from home or a hotel can access the
company system as though being in the office. Because data is being transmitted over public
systems it is particularly vulnerable to interception and it is very important that adequate security
measures are in place to safeguard the data.
(1) Access control and authentication – this ensures that unauthorized users do not access the
system. Typically this will be accomplished through a log-in procedure.
(2) Confidentiality – this ensures that data cannot be intercepted and read by a third party
whilst being transmitted. This is achieved using encryption.
(3) Data integrity – this ensures that the data has not been altered or distorted whilst in transit.
To ensure this, the message could have special check digits added to ensure that the data
complies with a mathematical rule.
Consider an office local area network. There are three main ways in which the data and processing
can be arranged: centralised, decentralised (distributed) and hybrid.
Centralised systems.
In these systems there is a powerful central computer which holds the data and which carries out
the processing.
๏ Security: all data can be stored in a secure data centre so that, for example, access to the data
and back-up routines are easier to control.
๏ One copy of the data: all users see the same version of the data.
๏ Lower capital and operational costs: minimal hardware is needed at each sites. There is also
less administrative overhead.
๏ The central computer can be very powerful: this will suit in processing-intensive applications.
๏ They allow a centralised approach to management. For example, a chain of shops needs to
keep track of inventory in each shop and to transfer it as needed. There is little point in a shop
that is running low ordering more if another branch has a surplus.
๏ Highly dependent on links to the centralised processing facility. If that machine fails or
communication is disrupted then all users are affected.
๏ Processing speed: will decrease as more users log-on
๏ Lack of flexibility: local offices are dependent on suitable software and data being loaded
centrally.
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In these systems, each user has local processing power and will hold data locally.
๏ More difficult to control: data storage and processing are in many locations and correct
access, processing and back-up of data are more difficult to enforce.
๏ Multiple versions of data: user might have their own version of data that should be uniform.
๏ Potentially higher costs: each local computer has to have sufficient processing power and
each location might require an IT expert.
This is relatively new approach but one that is growing in popularity. There is only one copy of the
software on the server within a web-based interface. Users log into the web system and their
processing is then carried out on the server or a ‘cloud’ of servers. It appears to each user that they
have a local version of the software, but what they are really seeing is the program operating in the
server. As more processing is needed more cloud resources can be used and this gives users great
flexibility.
Client machines can be ‘thin-clients’ (ie not powerful) as they do not have to store much data and
software nor do they have to carry out much processing. Hardware, software and maintenance
costs are greatly reduced, though the system is vulnerable to service disruption.
It can be particularly useful where a company’s processing needs are very volatile. For example, a
design or engineering company might need very high computing power only when rendering (ie
producing detailed graphics) work. Much of the time processing needs are small. Therefore, instead
of having a large computer of its own, the design company’s work is hosted by a cloud-based
computer (whose use is shared). That computer will be powerful enough to deal with intensive
processing as needed. Also, designers can work at home, for example, on laptops. The relatively
low powered laptop provides the interface but the bulk of the processing is done elsewhere.
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4. Risks in IT systems
IT poses particular risks to organisations’ internal control and information systems and
organisations must try to safeguard their data and IT systems otherwise problems can lead to their
operations being severely disrupted and subsequently to lost sales, increased costs, incorrect
decisions and reputational damage. Some security breaches might leave an organisation open to
prosecution.
Risks include:
๏ Reliance on systems or programs that are inaccurately processing data, processing inaccurate
data so that they report inaccurate, misleading results. For example, in 2018 a UK bank, TSB,
transferred its customers’ accounts to another computer system run by Sabadell, TSB’s
Spanish owner. Many customers then had great difficulty accessing their accounts over the
Internet or via ATM machines. In 2012 RBS, another British bank carried out a routine update
of its software, but the update had been corrupted. Again, customers could not carry out
transactions for up to week.
๏ Unauthorised access to data leading to destruction of data, improper changes to data, or
inaccurate recording of transactions. In 2018, British Airways and Amazon both suffered data
hacks which meant that customers’ details being stolen.
๏ Particular risks may arise where multiple users access a common database on which everyone
in the organisation relies. The data could be incorrectly amended and all users will be
affected.
๏ Web application attacks. When you visit a website, you might simply access a static web-page
which, for example, shows the name and address of the company which own the web-site.
Alternatively, the web-site might load Java script (a programming language) into your
browser and this is capable of carrying out processing. What you then have is a web
application. For example, when you enter your credit card details into a site like Amazon, the
validity of your card is checked locally because your card number has to comply with certain
construction rules. Validity checking is carried out on your machine within your browser
running a web application. Web application attacks might therefore try to interfere with the
functionality of the web app you are running. For example, whilst checking the validity of
your credit card, the altered application might now send details to the hacker.
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๏ Malware is a term that covers all software intentionally designed to cause damage to a
client computer, a server, the network or data. Malware includes:
‣ Virus: a malicious program that inserts itself into another program and which then
spreads by infecting other computers and data files.
‣ Worm: can self replicate and which are stand-alone.
‣ Trojan: a piece of software that looks harmless but which causes damage or
inconvenience when run
‣ Ransomware: threatens to publish the victim’s data or which scrambles data until a
ransom is paid.
‣ Bots: derived from ‘robot, this is a piece of software that carries out automated
processes. For example, emails or posts on social media can be generated to give the
appearance of support for particular causes.
‣ Spyware. For example, a piece of malware that records you activity on the Internet and
sends that information to an unauthorised third party.
‣ Denial of service (DOS) attacks. Typically, the overwhelming of internet sites with
demands for responses so that legitimate users are denied service.
‣ Backdoors. Undocumented ways into a system so that normal log-on, password and
security checks are bypassed.
๏ The possibility of IT personnel gaining access privileges beyond those necessary to perform
their assigned duties.
๏ Human error.
๏ Physical damage, such as fire or water damage.
๏ Industrial espionage.
๏ Fraud. Often easier by computer as it can be easier for the perpetrator to be disguised and
small, almost trivial, amounts can be stolen many times so that the total becomes significant.
IT fraud generally depends on either changing data or programs. For example, a person could
commit a salary fraud either by changing their salary (ie altering data) or changing the salary
program to boost net salary when a particular employee is being dealt with (a program
fraud).
๏ Unauthorised changes to data in master files. For example, changing a selling prices or credit
limit.
๏ Unauthorised changes to systems or programs so that they no longer operate correctly and
reliably.
๏ Failure to make necessary changes to systems or programs to keep them up-to-date and in
line with legal and business requirements.
๏ Potential loss of data or inability to access data as required. This could prevent, for example,
the processing of internet sales.
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5. Cyber security
In the UK, a Government organisation called the National Cyber Security Centre gives guidance on
implementing the EU Directive on the security of network and information systems. It sets out a
number of objectives for cyber security:
๏ Managing security risk
๏ Protecting against cyber attack
๏ Detecting cybersecurity events
๏ Minimising the impact of cyber security event
Earlier we explained the process of risk identification, a risk register and assurance mapping. We
also mentioned the severe reputational damage that can occur as a result of unethical behaviour.
Digital resources are now so important and significant to many businesses that the risks that
potentially arise from poor cyber security are enormous so organisations should have formal
procedures in place to regularly:
๏ Identify potential cyber security risks. For example regularly review access control, stay aware
of new threats, employ consultants to try to ‘break into’ the system. Analyse past problems as
these will remain problems unless changes are made.
๏ Protect against those risks. For example, strict rules for changing passwords, anti-virus
software, firewalls and staff training.
๏ Detect when breaches have occurred. For example, review customer reports, analyse data
flows, analyse processing patterns, continually monitor network statistics.
๏ Respond to breached in cyber security. For example, assess the effect of any breach, start
using back-up systems, reassure stakeholders, pay compensation to those affected, take
measures to block any reoccurrence of the breach.
System security needs to assessed regularly and proactively and not just as a reaction to a breach.
Therefore, management should appoint a specialist committee or team whose brief is to manage
cyber risks. Identified should be recorded in a risk register where decisions and actions will also be
recorded.
It is common for organisations to also issue customers withe a privacy policy statement explaining
what data is held and how it is used. Some also issue a website security document. The British
Airways web-page can be seen here:
www.britishairways.com/en-gb/information/legal/website-security
This gives advice to customers about how to take care when on-line and also sets out the measures
taken by the company. Obviously, not every detail of BA’s precautions will be made public.
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For example, there should be procedures in place to ensure that software patches to counter
flaws in software design are promptly implemented. Features should be kept under review
and removed if not required. Users must be trained to avoid serious user error, such as
leaving laptops unattended in cars.
๏ Resilient networks. For example, are networks well-designed with, perhaps, built-in spare
capacity. Is a parallel system running at a remote location so that it can be switched to if the
main system breaks down? Is the bandwidth of the network high enough to comfortably deal
with peak demand?
๏ Staff awareness and training. Staff behaviour should be in line with the organisation’s data
protection policies and procedures and training is needed to ensure that this happens. It is
also important to foster a security culture in which staff take an active role in maintaining and
improving security.
An effective monitoring system must be in place so that security breaches and attempted security
breaches are discovered. Once discovered there should be appropriate processes in place to make
appropriate responses. For example, organisations can monitor the web addresses that employees
are accessing. Email traffic might allow phishing attacks (where a malicious site poses as a
legitimate one). Threat intelligence can be used to identify connections to IP addresses of sites
known to be dangerous,
In addition to monitoring known indicators of cyber threats, organisations should also develop the
capability of identifying unknown or expected threats. For example, unusual patterns of data flows
around the network, user activity outside normal hours, the retrieval of a large volume of design
documents.
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First there should be response and recovery planning and there should be an incident response
plan (for extreme incidents, sometimes known as a disaster recovery plan). Amongst other things,
this plan should indicate how to assess the seriousness of the incident, how the effects of the
incident might be minimised, allocate staff responsibilities and the steps they should take, how a
back-up or stand by system can be switched to, how public and customer relations should be
managed.
It is also important to assess how the incident occurred and what measures might prevent a repeat
in the future.
6. IS27001
ISO27001 sets out international standards on information technology security techniques. It is a
detailed document which lists 114 controls in 14 sections. We will list the14 sections with just a few
examples of the controls that might be relevant:
1 Information security policies A set of policies should be defined, approved, published and
communicated to staff.
2 Organisation of information All information security responsibilities shall be defined and
security allocated.
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7 Physical and environmental Secure areas shall be protected by appropriate entry controls.
security
Physical protection against natural disasters, malicious attack
and accidents shall be designed and applied.
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‘Forensic’ implies that findings will be presented in a court of law or possibly some legal argument
or negotiation such as the amount of compensation that can be claimed under an insurance
arrangement.
Computer forensics techniques discover, preserve and analyse information on computer systems.
This involves more than just switching on the computer and searching the hard drive. Simply
opening a file to read it changes it (for example date and time accessed) and therefore evidence
has been changed by the action of the investigator. Therefore, when computers are seized by the
police, their first action will be to remove the hard drive and to preserve the data in a completely
unchanged state.
Forensic analysis will also, for example, extend to network analysis where the results can show was
logged on to the system at any time, what operations they carried out, what web-sites were
accessed etc.
Malware analysis often uses reverse engineering, decompilation and disassembly. What does that
mean? Well, when computers are running a program, the instructions they follow have usually
been converted from source code (the language they were written in) to object code (for example,
a series of 1s and 0s that the computer uses ie, binary code). Therefore, malware, when it is found,
will rarely be in human-readable form. The malware analyst has to take the sequences of binary
code and work back to the original programming statements so that the operation of the malware
can be understood.
Compilation
Decompilation/disassembly/
reverse engineering
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Penetration testing (‘a pen test’) is an authorised simulated cyber attack on a computer system. It is
a controlled form of hacking where the hackers act on behalf of the client to probe the system for
vulnerabilities. Once vulnerabilities have been found and reported, the client must take acton to
remedy the weaknesses and the penetration test should be repeated to see if the measures taken
have been successful.
Sometimes the terms ‘black hat’ and ‘white hat’ are used to describe hackers:
๏ Black hat hackers: these are the baddies, illegally hacking systems for personal gain, political
reasons or just for fun.
๏ White hat hackers: these are the good guys who try to penetrate systems on behalf of the
systems owners so that system security can be improved.
Some white hat hackers may have started as black hat trackers but then decided to switch from the
dark side, perhaps after a brush with the law and the opportunity to study the inside of a prison
cell.
Software security means trying to protect software (ie programs) against malicious attacks so that
the software continues to operate in the way it was designed to. For example, a progam accessing
a database could potentially be altered so that data was harvested, changed or deleted.
Software security can be enhanced by using good programming techniques, firewalls and intruder
protection. New or amended software should be used only after strict authorisation and testing.
Master copies of programs can be held off-line (so not subject to network attack) and the user
copies of the software can be compared form time-to-time ti the master copies to identify any
changes.
Software security can be designed in layers with security set at an appropriate level for the
processing being carried out and data being accessed. For example:
Tier Description
So, a university might use the following security layers for applications
Tier Description
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8. Practical controls
Controls in computer systems can be categorised as general controls and application controls.
These are policies and procedures that relate to the computer environment and which are
therefore relevant to all applications. They support the effective functioning of application controls
by helping to ensure the continued proper operation of information systems.
General IT controls that maintain the integrity of information and security of data commonly
include controls over the following:
๏ Data centre and network operations. A data centre is a central repository of data and it is
important that controls there include back-up procedures, anti-virus software and firewalls to
prevent hackers gaining access. Organisations should also have disaster recovery plans in
place to minimise damage caused by events such as floods, fire and terrorist activities.
๏ System software acquisition, change and maintenance. System software refers to operating
systems, such as Windows or Apple’s OS. These systems often undergo updates as problems
and vulnerabilities are identified and it is important for updates to be implemented promptly.
๏ Application system acquisition, development, and maintenance. Applications systems are
programs that carry out specific operations needed by the company – such as calculating
wages and invoices and forecasting inventory usage. Just as much damage can be done by
the incorrect operation of software as by entering incorrect data. For example, think of the
damage that could be done if sales analyses were incorrectly calculated and presented.
Management could be led to withdraw products that are, in fact, very popular. All software
amendments must be carefully specified and tested before implementation.
๏ Access security. Physical access to file servers should be carefully controlled. This is where the
company keeps it data and it is essential that this is safeguarded: data will usually endow
companies with competitive advantage. Access to processing should also be restricted,
typically through using log-on procedures and passwords.
These controls help ensure that transactions are authorised, and are completely and accurately
recorded, processed and reported. Examples include:
๏ Edit checks of input data. For example, range tests can be applied to reject data outside an
allowed range; format checks ensure that data is input in the correct format (credit card
numbers should be 12 digits long; dependency checks where one piece of data implies
something about another (you have probably had a travel booking rejected because you
inadvertently had a return date earlier than the outward date); check digits, where a number,
such as an account number, is specially constructed to comply with mathematical rules.
๏ Numerical sequence checks to ensure that all accountable documents have been processed.
๏ Drop down menus which constrain choices and ensure only allowable entries can be made.
๏ Batch total checks.
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On-line, real time systems can pose particular risks because any number of employees could be
authorised to process certain transactions. Anonymity raises the prospect of both carelessness and
fraud so it is important to be able to trace all transactions to their originator. This can be done by
tagging each transactions with the identity of the person responsible.
Cyber-espionage is also a growing threat. Governments, competitors and criminals attempt to steal
intellectual property or information about customers and contracts. Quite obviously the theft of
valuable know-how will undermine a company’s competitive advantage and it is essential that for
organisations to defend themselves as far as possible against these threats.
๏ Nature of the business and operations. Naturally, many of the risks that organisations are
exposed to depend on their business and operations. For example, an aircraft manufacturer
will possess valuable intellectual property and there is a cyber risk that this will be stolen. On
the other hand, supermarkets are less likely to have that type of data.
๏ Nature of the information at risk. Following on from above, organisation will list the principle
types of data it stores, uses and transmits.
๏ Risk management programme objectives. This sets out what degree of risk mitigation the
organisation wants to achieve for each item of data. For example, data showing customers
credit card details needs a very high level of security. Data about wages and salaries, though
personal and sensitive, is less likely to lead to losses or theft.
๏ Specific factors affecting cybersecurity risks. For example, a company in which each
employees has a laptop which they take to clients and perhaps take home, runs specific risks
relating to laptop theft and therefore theft of the data it contains. Stakeholders would expect
all sensitive data on the laptops to be encrypted. Another example is where an organisation
holds very sensitive data about patients medical histories. There, you would normally expect
a complex password system so that hospital staff (which includes administrators) see only the
data they need to carry out their jobs.
๏ Cyber risk governance structure. Board oversight, risk committees, procedures for identifying
risks and dealing with breaches, ethical commitment, training, ensuring staff are up-to-date
and properly qualified.
There follow several examples of how large company have reported cyber risks in the risk section
of their annual reports
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There are many definition the term ‘big data’ but most suggest something like the following:
“Extremely large collections of data (data sets) that may be analysed to reveal patterns, trends, and
associations, especially relating to human behaviour and interactions.”
In addition, many definitions also state that the data sets are so large that conventional methods of
storing and processing the data will not work.
In 2001 Doug Laney, an analyst with Gartner (a large US IT consultancy company) stated that big
data has the following characteristics, known as the 3Vs:
๏ Volume
๏ Variety
๏ Velocity
These characteristics, and sometimes additional ones, have been generally adopted as essential
qualities of big data.
Variety:
disparate non-uniform data of different
sizes, sources, shape, arriving irregularly,
some from internal sources and some from
external sources, some structured, but
much of it is unstructured
Characteristics
of big data
(Laney)
Velocity: Volume:
data arrives continually and a very large amount of data. More
often has to be processed very than can be easily handled by a
quickly to yield useful results single computer, spreadsheet or
conventional database system
The commonest fourth ‘V’ that is sometimes added is veracity: Is the data true? Can its accuracy be
relied upon?
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10.1.Volume
The volume of big data held by large companies such as Walmart (supermarkets), Apple and eBay is
measured in multiple petabytes. What’s a petabyte? It’s 1015 bytes (characters) of information. A
typical disc on a personal computer (PC) holds 109 bytes (a gigabyte), so the big data depositories
of these companies hold at least the data that could typically be held on 1 million PCs, perhaps
even 10 to 20 million PCs.
These numbers probably mean little even when converted into equivalent PCs. It is more
instructive to list some of the types of data that large companies will typically store.
๏ Retailers:
‣ Via loyalty cards being swiped at checkouts: details of all purchases you make, when,
where, how you pay, use of coupons.
‣ Via websites: every product you have every looked at, every page you have visited,
every product you have ever bought. (To paraphrase a Sting song “Every click you make
I’ll be watching you”.)
‣ Social media (such as Facebook and Twitter)
Friends and contacts, postings made, your location when postings are made, photographs
(that can be scanned for identification), any other data you might choose to reveal to the
universe.
Numbers you ring, texts you send (which can be automatically scanned for key words), every
location your phone has ever been whilst switched on (to an accuracy of a few metres), your
browsing habits. Voice mails.
Every site and every page you visit. Information about all downloads and all emails (again
these are routinely scanned to provide insights into your interests). Search terms you enter.
๏ Banking systems
Every receipt, payment, credit card payment information (amount, date, retailer, location),
location of ATM machines used.
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10.2.Variety
Some of the variety of information can be seen from the examples listed above. In particular, the
following types of information are held:
Financial transactions
๏ Interests
๏ Buying habits
๏ Reaction to ads on the internet or to advertising emails
๏ Geographical information
๏ Information about social and business contacts
๏ Text
๏ Numerical information
๏ Graphical information (such as photographs)
๏ Oral information (such as voice mails)
๏ Technical information, such as jet engine vibration and temperature analysis
Structured data: this data is stored within defined fields (numerical, text, date etc) often with
defined lengths, within a defined record, in a file of similar records. Structured data requires a
model of the types and format of business data that will be recorded and how the data will be
stored, processed and accessed. This is called a data model. Designing the model defines and limits
the data that can be collected and stored, and the processing that can be performed on it.
An example of structured data is found in banking systems, which record the receipts and
payments from your current account: date, amount, receipt/payment, short explanations such as
payee or source of the money.
Unstructured data: refers to information that does not have a pre-defined data-model. It comes in
all shapes and sizes and this variety and irregularities make it difficult to store it in a way that will
allow it to be analysed, searched or otherwise used. An often quoted statistic is that 80% of
business data is unstructured, residing it in word processor documents, spreadsheets, PowerPoint
files, audio, video, social media interactions and map data.
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10.1.Velocity
Information must be provided quickly enough to be of use in decision making. For example, in the
above store scenario, there would be little use in obtaining the price-comparison information and
texting customers once they had left the store. If facial recognition is going to be used by shops
and hotels, it has to be more-or less instant so that guests can be welcomed by name.
You will understand that the volume and variety conspire against the third, velocity. Methods have
to be found to process huge quantities of non-uniform, awkward data in real-time.
The processing of big data is generally known as big data analytics and includes:
๏ Better marketing
๏ Better customer service and relationship management
๏ Increased customer loyalty
๏ Increased competitive strength
๏ Increased operational efficiency
๏ The discovery of new sources of revenue.
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Despite the examples of the use of big data in commerce, particularly for marketing and customer
relationship management, there are some potential dangers and drawbacks.
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RBS was fined ₤56m by the Financial Conduct Authority (FCA) and the Prudential Regulation
Authority (PRA) as a result.
Companies should have disaster plans that will first offer some protection against problems but
which will then allow the company’s IT system to be up and running (at least the most vital
elements of the system) a soon as possible.
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