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​Doing the Right Thing

Today’s boards are taking a closer look at corporate culture.

Brian Christensen, Executive Vice President — Global Internal Audit, Protiviti

Tracey Keele, Partner, Internal Audit and Enterprise Risk Services, KPMG LLP

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​In light of recent, well-publicized corporate culture failings, what are boards doing to address culture?

Christensen We definitely see the concept of culture gaining traction in the boardroom. More than ever, directors are acutely aware that culture plays a role in delivering outcomes — both good and bad — for the companies they serve. Because culture can break down anywhere in the company, it is important for directors to experience firsthand the real-world culture in the organization, rather than rely solely on boardroom discussions and management reports. One way to accomplish this is by engaging directly with operating personnel through site visits. Directors also should insist on observations regarding culture from the chief risk officer, chief compliance officer, chief information security officer, and human resources and environment, health, and safety personnel, as well as other independent second line-of-defense functions. Boards also expect internal audit to weigh in as the third-line assurance provider.

Keele Boards are asking more directed questions: What is the risk of this happening in our company? What steps have we taken to prevent/detect this type of misconduct? Do we apply our processes consistently? How does the organization respond to a finding of inappropriate or unethical behavior — is everyone held accountable, or are certain individuals given a pass? Do we have a crisis management plan to respond to an event? Boards also should be consistently asking the broader questions that get at the current state of the organization’s culture: Are expectations for what constitutes unacceptable behavior clear and understood? Is the workplace safe and respectful? Do individuals feel they can speak up without retaliation, expect they will be heard, and have their concerns investigated?

What do boards need to understand about their role in overseeing culture?

Keele Most boards now understand that culture is important, but determining what to do about it is another matter. Like management, boards are not entirely sure how to confirm whether the culture they want is the culture they have. Because measuring and overseeing culture isn’t easy, there is a risk of defaulting to seemingly simple, check-the-box solutions. Further, there is a risk of over-relying on hard controls — policies, training, and systems that only provide a partial view of risk management. Understanding the drivers of conduct — soft controls — and whether the “walk” matches the “talk” is fundamental to understanding culture and risk.

Boards also should guard against focusing on today’s expectations, without considering how they may differ tomorrow. Technological, social, economic, regulatory, and political changes are occurring faster than ever. How do organizations evolve quickly, focus on both the spirit and the letter of the law, and anticipate change to enhance resiliency, grow, and build trust with stakeholders?

Christensen Culture is a vital enterprise asset that must be cultivated, nurtured, and maintained. Directors need to be curious enough to probe on culture issues. First and foremost, the board must want to know whether there are any concerns pertaining to culture warranting its attention. Board members must address two fundamental questions: How do we know what we need to know regarding culture? Is our understanding representative of the entire organization or just certain areas? No director wants to be on a board that ends up asking itself: How did this happen and why didn’t we know?

​Cultural Misalignment

Christensen and Keele say these red flags may indicate that the tone in the middle isn’t aligned with the tone at the top.

  • Nobody is talking about culture.
  • Controversial deals and encouragement of risk taking to hit short-term targets.
  • Complex and unclear legal and reporting structures that obscure transparency.
  • Poorly executed takeovers that allow pockets of bad behavior to thrive.
  • Lack of financial discipline.
  • Employees constantly fear being fired.
  • Employees execute projects without a clear vision from company leaders.
  • Lack of knowledge sharing among employees.
  • A focus on blame or covering for each other rather than fixing the problem.
  • A perceived disconnect between words and action.
  • A focus on the letter rather than the spirit of the law and regulations.
  • Risk management and controls are regarded as an inconvenience.
  • Lack of prompt follow through on commitments.
  • Failure to escalate identified issues and active concealment of problems.
  • Dress rehearsals for leadership visits that are focused on appearance.

What can internal audit do to inform the board about the organization’s culture?

Christensen Internal audit, the third line of defense,  is well-positioned to perform a culture audit, evaluating the processes used across the entity by first- and second-line personnel to assess culture. Ironically, it is internal audit — the objective eye of the organization — that is uniquely qualified to bring “a systematic, disciplined approach” to a potentially subjective process like measuring culture. Internal auditors should “connect the dots,” considering the findings and gratuitous observations from multiple audits to ascertain whether any meaningful patterns exist. With everyone having a stake in evaluating the enterprise’s culture, the board should be privy to the results of all evaluations — particularly from independent second-line functions and internal audit.

Keele Internal auditors can play a critical role in understanding and enhancing culture. Internal audit can act as “the eyes and ears” of the organization, helping the board deepen its understanding of culture to better fulfill its culture oversight responsibilities. Evaluating and evolving audit skills and capabilities, initiating and promoting dialogue within the organization, garnering organizational permissions and support, and understanding the organization’s culture expectations, initiatives, and current state are important first steps for establishing internal audit’s role in culture.

What tools and techniques should internal audit use to audit culture?

Keele The tools and techniques used in traditional audits also are relevant to culture audits — interviews, data review and analysis, and walk-throughs. Also, the use of surveys, facilitated workshops, focus groups, and advanced analytical techniques like sentiment analysis can be extremely valuable, deepening the understanding of employee experiences and perceptions. Internal audit should think expansively about data that exists within and outside the organization to support improved risk assessment and audit execution. Procedures should be tailored based on the organization’s culture maturity and appetite for improvement, and internal audit’s capability and ambition.

Christensen Survey results can validate themes from stakeholder interactions to gauge consistency of views regarding the company’s culture. Relevant data metrics should supplement insights from surveys and direct interactions with stakeholders. These include risk metrics, conduct-related compliance data, issue escalation and resolution data, human resources data and reports, whistleblower reports, turnover data, ethics hotline reports, unstructured social media data, and employee demographic data. These and other metrics should be used as supplements to performance measures linked to the strategy to drive the type of organizational culture that management and the board would like stakeholders to experience when they interact with it.

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