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Internal Control System:


Vital Tool for Cooperative Governance
Cooperative Day
In Celebration of the Accountancy Week
PHILIPPINE INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS
July 20, 2012
Hotel Intercontinental Manila, Makati City

RUFO R. MENDOZA, PhD


Certified Public Accountant
Development and Governance Adviser
Research and Training Consultant

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Bank of Credit
and
Commerce
International
Barings Bank

Maxwell
Communications
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Corporate Governance

has had a history of reacting to

scandal and abuse

rather than being

PROACTIVE
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Citibank exec goes missing;


millions stolen

abs-cbnNEWS.com
(August 20, 2010)

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Inaccurate Financial
Missing Documents
Reports

Lack of Written Procedures Customer Complaints

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Causes of the Failure of Cooperatives in


the Philippines
• Incompetent management • Lack of adequate safeguard
• Lack of proper understanding against unscrupulous officers
of the principles, practices true • Dominance of the
aims, and purposes individualistic attitude
• Improper use of credits • Inability to secure adequate
• Defective securities capital
• Political interference • Dependence on alien suppliers
• Lack of compensation of and distributors
officers • Ineffectiveness of the
• Inadequate character and government and promotion of
moral responsibility cooperative organizations
• Inadequate marketing facilities

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Internal Control Frameworks

• COSO
• CoCo
• Cadburry Report
• COBIT
• ISO

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1970’s
• 1977 - Foreign Corrupt Practices Act
• 1985 – National Commission on
Fraudulent Financial Reporting
– Treadway Commission

!Committee of Sponsoring Organizations


(COSO)

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COSO A voluntary private sector organization dedicated to


improving the quality of financial reporting through
Committee of business ethics, effective internal controls, and
Sponsoring corporate governance

Organizations
1992 Issued the Internal Control-
Integrated Framework

1994 Amended the framework


to expand the scope to
address additional
controls pertaining to
safeguarding of assets

2006 Issued the Internal


Control over Financial
Reporting- Guidance for
Smaller Public Companies
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Key Internal Control Concepts


" Internal control is a process. It is a means to an end,
not an end in itself.
" Internal control is affected by people. It’s not merely
policy, manuals, and forms, but people at every level
of an organization.
" Internal control can be expected to provide only
reasonable assurance, not absolute assurance, to an
entity’s management and board.
" Internal control is geared to the achievement of
objectives in one or more separate but overlapping
categories.

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Internal Control
• A process effected by an entity’s board of
directors, management and other personnel,
designed to provide reasonable assurance
regarding the achievement of objectives in the
following categories:

– Effectiveness and efficiency of operations

– Reliability of operations

– Compliance with applicable laws and regulations


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COSO
Internal Three Objectives
Control
Framework Units or
Activities
of an
Entity

Five Components

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COCO
Criteria of Control
• actions that foster the best result for an
organization
• contribute to the achievement of the
organization’s objectives, focus on:
– effectiveness and efficiency of operations;
– reliability of internal and external reporting;
– compliance with applicable laws and regulations
and internal policies.

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COCO
Criteria of Control
• Internal control comprises those elements of an
organization. including
– resources
– systems
– processes
– culture
– structure
– Tasks
taken together, support people in the achievement of
the organization’s objectives

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Purpose
A sense of direction.
What are we here for?

Monitoring and Commitment


Learning A sense of identity
A sense of evolution. and values.
What Progress? Do we want to do
What Next? a good job?

ACTION
Capability
A sense of competence.
What action do we need to
take?

COSO CoCo
a process, effected by an those elements of an
entity’s board of directors, organization (including its
management, and other resources, systems, processes,
personnel, designed to provide culture, structure and tasks)
reasonable assurance regarding that, taken together, support
the achievement of objectives. people in the achievement of
the objectives.
• effectiveness and efficiency • effectiveness and efficiency
of operations; of operations
• reliability of financial • reliability of internal and
reporting; and external reporting; and
• compliance with applicable • compliance with applicable
laws and regulations laws and regulations and
internal policies
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Cadburry Report
1992
Three Basic Recommendations
• CEO and Chairman of companies should be
separated
• Boards should have at least three non-
executive directors, two of whom should
have no financial or personal ties to
executives
• Each board should have an audit committee
composed of non-executive directors

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COBIT
Control Objectives for Information and
Related Technology
1996

• Focuses primarily on efficiently and effectively


monitoring information systems
• Emphasizes the role and impact of IT control as
it relates to business processes
• Can be used by management to develop clear
policy and good practice for control of IT

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COBIT
Control Objectives for Information and
Related Technology
1996

Definition of Internal Control

The policies, procedures, practices, and organizational


structures are designed to provide reasonable
assurance that business objectives will be achieved
and that undesired events will be prevented or
detected and corrected.

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Internal Audit is part of the organization that


helps achieve organizational goals.

ORGANIZATION RISKS
Internal
Audit
INTERNAL The achievement of
CONTROLS organizational goals is
hindered by risks.

What is an internal What is a risk?


Organizations have
control?
goals which they
A risk is a set of
aim to achieve.
Internal control is a circumstances that
process which hinder the achievement
addresses the risk. of goals or objectives.

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CONTROLS
INTERNAL AUDIT
Controls exist
to manage risks • Assists management
on controls and risks
RISKS

promote

GOVERNANCE

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Reasonable Assurance

Internal control, no matter how


well designed and operated,
can provide only reasonable
assurance regarding
achievement of an entity’s
objectives. The likelihood of
100%
achievement is affected by
limitations inherent in all
internal control systems.

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Changing View on
Internal Controls

AGENCY/
BUSINESS
INTERNAL
ACCOUNTING CONTROLS
CONTROL

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Who is Everyone in
responsible for the
internal control? Organization!!!
Board of Directors:
• Governance, guidance,
and oversight

Management:
• Owner

Other Employees:
• Information and
Communication

Internal Auditors:
• Monitoring and Evaluation

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Roles and Responsibilities

1. Board of directors and audit


committee
2. Management
3. Other entity personnel
4. Internal auditors
5. Independent auditors
6. Other external parties

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How Much Do Internal Controls Cost?

The cost of Sometimes there


implementing a is no out-of-pocket
specific control should
not exceed the
cost to establish
expected benefit of the an adequate
control. control.

The potential loss • Realignment of duty or


assignments
of a computer
printer may justify • Voided receipts are
the cost of a door approved by someone
(manager) other than the
lock but not an one preparing the
alarm system. receipts

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Five Components
of Internal Control

Control Environment

Risk Control Information and


Monitoring
Assessment Activities Communication

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COMPONENT
1 The Control Environment

• The control environment sets the tone of an


organization, influencing the control
consciousness of its people.

• It is the foundation for all other components of


internal control, providing discipline and
structure.

• It represents an organization’s first line of


defense to mitigate the risks.

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The Control Environment

Integrity and ethical values Organizational structure

Commitment to competence Assignment of authority


and responsibility

Management’s philosophy Human resources


and operating style policies and practices

Board of directors or audit


committee participation
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COMPONENT
RISK ASSESSMENT
2

Every entity faces a variety of risks from external


and internal sources that must be assessed. A
precondition to risk assessment is establishment of
objectives, linked at different levels and internally
consistent.

Risk assessment is the identification and analysis of


relevant risks to achievement of objectives, forming a
basis for determining how the risks should be
managed.

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Objective- Risk Managing


Setting Identification Change
and Analysis
• Operations • External • Changed Operating
Environment
• Financial • Internal • New Personnel
Reporting • New or Revamped
• Likelihood Information System
• Compliance or • New Technology
Frequency • New Lines, Products, and
Activities
• Impact • Corporate Restructuring
• Foreign Operations
Entity-Level
Functional or Business Unit Level
Activity Level

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COMPONENT
CONTROL ACTIVITIES
3

Control activities are policies and procedures


that help ensure that management directives
are carried out.

They help ensure that necessary actions are


taken to address risks to achievement of the
entity’s objectives.

Control activities have various objectives and


are applied at various organizational and
functional levels.

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CONTROL ACTIVITIES

a. Proper Authorization Procedures


b. Adequate Segregation of Duties
c. Information Processing Controls
d. Physical Controls
e. Adequate Documents and Records
f. Verification
g. Reconciliation
h. Independent Performance Reviews
i. Supervision

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1 2 3 4
Authorization Custody of Recording Review and
of Assets Transactions Reconciliation
Transactions

1. Separation of authorization to execute transactions from the


custody of related assets

2. Separation of custody of assets from recording

3. Separation of recording from operational responsibility

4. Total separation of review and reconciliation

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Four kinds of functional responsibilities that should be


performed by different work units, or at a minimum, by
different persons within the same unit:

1. Authorization to execute transactions: This


duty belongs to persons with authority and
responsibility to initiate and execute
transactions.
– General authorization
– Specific authorization

2. Recording transactions: This duty refers to


the accounting or recordkeeping function, which
in most organizations, is accomplished by
entering data into a computer system.

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Four kinds of functional responsibilities that should be


performed by different work units, or at a minimum, by
different persons within the same unit:

3. Custody of assets involved in the


transactions: This duty refers to the actual
physical possession or effective physical
control/safekeeping of property.

4. Periodic reviews and reconciliation of


existing assets to recorded amounts: This
duty refers to making comparisons at regular
intervals and taking appropriate action to
resolve differences.

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Adequate Separation
of Duties

Custody of assets Accounting


Authorization The custody of
of transactions related assets
Operational Record-keeping
responsibility responsibility
IT Duties User departments

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Traditional Segregation of Duties

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IT Functions Requiring Segregation

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c. Information Processing Control

• General controls—those that apply to computer


information systems as a whole and include controls
related matters such as data centre organization,
hardware and systems software acquisition and
maintenance, and back up and recovery procedures.

• Application controls—those that apply to processing


of specific types of transactions such as invoicing,
paying suppliers, and preparing payroll.

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c. Physical Control Over Assets And Records

Physical precautions

Controls related to IT equipment,


programs, and data files

Backup and
Physical Access
recovery
controls controls
procedures
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Document/Form Design

Prenumbered consecutively
Prepared at the time of transaction
Simple enough to ensure understanding
Designed for multiple uses
Constructed to encourage correct preparation

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f. Independent Checks or Verification

These involve the verification of work performed by other people or


departments, or the proper measurement of recorded amounts.

The need for independent checks


arises because the operation of internal
controls tends to change over time unless
there is a mechanism for frequent review.

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g. Periodic Reconciliations

Managers should provide for periodic comparison of


recorded amounts with independent evidence of
existence and valuation. The individuals to do this,
however, should not also have responsibility for
authorization of the related transactions, accounting
or recordkeeping, or custodial responsibility for the
assets.

Periodic comparisons may include reconciliation of bank


statements, inventory counting, confirmation of
accounts receivable and accounts payable. The more
frequent the comparisons, the greater the opportunity
to detect errors. For other records, the frequency of
periodic comparisons must be balanced against the
costs and benefits.

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h. Performance Reviews

These involve managers’ participation in the supervision of


operation. Frequent performance reviews give managers a
great chance of detecting errors, and can include
management review and analysis of:

– Reports that summarize the detail of account balances


such as aged trial balance of accounts receivable or
report of sales activity by division, product, or
salesperson

– Actual performance compared with budgets, forecasts


or previous period amounts.

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i. Supervision

• The effectiveness of any system of internal control depends on


continuous, qualified supervision of all staff. In fulfilling their
responsibilities, managers and supervisors should:
– Assign tasks and establish written procedures for completing
assignments.
– Systematically review each staff member's work.
– Approve work at critical points to ensure quality and
accuracy.
– Provide guidance and training when necessary.
– Provide documentation of supervision and review (e.g.,
initialing examined work).
• Adequate and timely supervision is especially important in small
departments, where limited personnel make it difficult to
establish a complete segregation of duties.

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TYPES OF INTERNAL
CONTROL ACTIVITIES

PREVENTIVE DETECTIVE CORRECTIVE


CONTROLS CONTROLS CONTROLS

Designed to Designed to Designed to


discourage identify an error remedy the
errors or or irregularity effects caused
irregularities after it has by adverse
occurred events

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Examples of Preventive Controls

• Reading and understanding


applicable areas of the entity’s
Policy Manual

• A manager’s review of purchases for


a proper business purpose prior to
approval

• A computer application that


requires password protection

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Examples of Detective Controls

• An exception report from the


electronic timekeeping system

• A comparison of transactions on
monthly operating reports with
departmental source documents

• A manager’s review of long


distance telephone charges

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Examples of Corrective Controls

• Changing recruitment policies to


attract qualified personnel.

• Disciplining an employee for


violating a “No Smoking” safety
regulations in hazardous areas.

• Revising a report you have


written because you are
dissatisfied with it.

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COMPONENT INFORMATION AND


4 COMMUNICATION
• Pertinent information must be identified, captured and
communicated in a form and timeframe that enable people to
carry out their responsibilities.

• Information systems produce reports, containing operational,


financial and compliance-related information, that make it
possible to run and control the business.

• They deal not only with internally generated data, but also
information about external events, activities and conditions
necessary to informed business decision-making and external
reporting.

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INFORMATION AND COMMUNICATION

• Effective communication must occur in a broader sense, flowing


down, across and up the organization.

• All personnel must receive a clear message from top


management that control responsibilities must be taken
seriously. They must understand their own role in the internal
control system, as well as how individual activities relate to the
work of others. They must have a means of communicating
significant information upstream.

• There also needs to be effective communication with external


parties, such as customers, suppliers, regulators and
shareholders.

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COMPONENT
5 MONITORING
Process of assessing the quality of internal control performance over
time. It involves assessing the design and operation of controls on a
timely basis and taking the necessary corrective actions. It is done to
ensure that controls continue to operate effectively.

Management’s ongoing and periodic assessment


of the quality of internal control performance …
to determine whether controls are operating
as intended and modified when needed.

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Monitoring Component

Ongoing Monitoring
Management, supervisory, and other monitoring activities in the
ordinary course of operations that assess the quality of internal
controls

Separate Monitoring
Evaluation focusing directly on system effectiveness with a scope
and frequency dependent on the assessment of risks, and
ongoing monitoring

Reporting Deficiencies
Upstream reporting of internal control deficiencies, with certain
matters reported to top management and the board

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Hard Controls
Soft Controls
“Activities”
“People”
Reviews
Openness
Inspections
Shared Values
Policies
Clarity
Reconciliations
Commitment to
Competence Structure
Honesty Limits of Authority
High Expectations User Aids and
Password
Communications
Physical Counts

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LIMITATIONS OF INTERNAL CONTROL


1. Internal control must be attained at reasonable
cost

2. Not full-proof

3. Susceptibility to human fallibility

4. Affected by organizational changes

5. Effectiveness depends on compliance or


implementation

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Factors that Reduce or Eliminate


Effectiveness of Controls

• Errors in human judgments (since decisions


must be made based on available information
and on time, sometimes under pressures;
personal carelessness; distraction or fatigue
of personnel performing a control
procedure)

• Breakdowns (due to misunderstanding of


instructions or technology errors)

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Factors that Reduce or Eliminate


Effectiveness of Controls

• Management override of certain policies


and procedures

• Collusion among individuals to circumvent


control procedures

• Excessive controls is costly and


counterproductive; but too little control
presents undue risk

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What happens if the Internal Control System is


Weak?

• Wasteful and inefficient use of resources

• Poor management decisions

• Unintentional errors in recording/ processing data

• Accidental loss or destruction of data

• Loss of assets or resources through carelessness or


pilferage

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Possible Hazards Arising from Weak Internal


Control System

• Lack of compliance with laws, rules and regulations


and other management policies

• Embezzlement (theft or misappropriation of agency


resources accompanied by falsification of records or
documents to conceal theft)

• Other illegal acts of members of organization

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COSO Enterprise Risk Management Model/Framework

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