Auditors: Market concentration and their role - Economic Affairs Committee Contents


Memorandum by the Institute of Chartered Accountants of Scotland (ADT 7)

INTRODUCTION AND KEY POINTS

Introduction

  The Institute of Chartered Accountants of Scotland welcomes the opportunity to submit evidence to the House of Lords Economic Affairs Committee inquiry on Auditors: Market Concentration and their Role.

  The Institute is the first incorporated professional accountancy body in the world. The Institute's Charter requires it to act primarily in the public interest, and our responses to consultations are therefore intended to place the general public interest first. Our Charter also requires us to represent our members' views and protect their interests, but in the rare cases where these are at odds with the public interest, it is the public interest which must be paramount.

Key Points

    — This is a global issue and is not restricted to the UK listed company audit market.

    — We do not believe that there is a lack of competition in the listed company audit market but rather that the level of market concentration is not dissimilar to that found in certain other sectors. However, we do believe that if the level of competition was to contract further, for whatever reason, that there would be a problem. We therefore believe that it is imperative that a change to the auditor liability regime is made in early course. Auditors should only be held accountable for their share of the blame in relation to any successful negligence claim against them and that is why we favour the introduction of a mandatory proportionate liability regime.

    — An ICAS Working Group is currently considering the role of the auditor and whether this needs to be developed further. Recent research[8] has indicated that there is significant demand from the investment community for at least some degree of external assurance on the management commentary section of the annual report. The Working Group's report is expected to be published before the end of the year and we will send a copy to you as soon as it is finalised.

    — We do not believe that the level of competition has any impact on the objectivity of the auditor.

    — We believe that the role of the audit committee is already well established within the listed company sector. It is our belief that it is the composition of the audit committee and the diligence of its members which is key. We do, however believe that there is a greater need for transparency over the work of the audit committee. Current reporting requirements on the work of the audit committee can often result in "boilerplate" disclosures which add little to the stakeholder's understanding of their role and their interaction with the external auditors. The audit committee plays a critical role in challenging management's judgements and more disclosure in the audit committee report could further the transparency of both the external audit process and the internal assurance processes within a company.

    — We believe the non-mandatory approach to internal audit to be appropriate. However, we also firmly believe that it is beneficial for listed companies to have an effective internal audit function. In order for the internal audit function to be effective it must have support at board level and not be seen as a mere compliance related function.

    — It should be noted that there are various different Government, regulatory and professional bodies currently reviewing the role of the auditor. These include, but are not limited to the following:

(i) the European Commission which is expected to publish its Green Paper on Auditing, in October.

(ii) the Financial Services Authority/Financial Reporting Council in their joint discussion paper 10/3 "Enhancing the Auditor's Contribution to Prudential Regulation".

(iii) the Auditing Practices Board in its discussion paper "Auditor Scepticism: Raising the bar".

(iv) the ICAS "Future of Assurance" Working Group which comprises stakeholders from the investment community, industry, academia, the media and the profession.

  We would therefore encourage the Committee to also consider the findings of the above consultations/projects before finalising its recommendations.

RESPONSES TO SPECIFIC QUESTIONS

1.   Why did auditing become so concentrated on four global firms? For example, do economies of scale make it too difficult for smaller firms to compete?

  Accountancy firms are businesses and like other businesses, firms have merged for similar reasons to mergers which have taken place in other sectors. The current market position arose over a number of years and as a result of various factors which we outline below. It needs to be highlighted that this is a global issue and is not unique to the UK listed company audit market.

  A number of major industry sectors have only 4 or fewer major dominant players. This does not necessarily indicate that a lack of competition exists eg the record industry in the UK only has four major players, there are four main food retailers in the UK, and the global private aircraft manufacturing sector only has two. Whilst we appreciate that in certain niche sectors entities may be restricted to less than four accountancy firms from which to choose their auditor, the vast majority of listed companies have access to greater choice. Additionally, for non quoted companies there is plenty of choice in the audit market.

  The factors which have led to the current level of concentration in the listed company audit market can be summarised as follows:

(i)  Growth of multi-national companies—responding to customer needs

  As companies began to expand their respective operations beyond their domestic markets, professional accountancy firms did likewise to enable them to provide the necessary services to support their clients. This client driven expansion partly explains the larger accountancy firms' initial international expansion which was effectively driven by the needs of British and US based multinationals for worldwide service in the 20th century. The larger accountancy firms responded:

    (a) by forming local partnerships in different jurisdictions or

    (b) by forming networks with local firms already in existence in the particular jurisdiction concerned.

  Even fairly recently, due to business demand, auditors needed to establish operations in China, where there was no established accountancy profession.

(ii)  Quality

  Linked to (i) above, is the need for an audit firm to be able to satisfy itself in relation to the quality of work undertaken, regardless of which jurisdiction the work is performed. Where clients had sizeable operations in different countries it was more difficult for audit firms to ensure the quality of audit work in such jurisdictions where the audit of some client affiliates (subsidiaries, associates etc) was undertaken by firms not connected to the parent company auditor. The need for the parent company auditor to ensure that firms in different countries audited to the same standards resulted in the establishment of networks to allow the sharing of knowledge, agreed methodologies, training requirements and quality assurance etc. It also made it easier to control the group audit when all significant affiliates of the company were audited by a member firm of the network. In this respect many clients would also rather only have to deal with one firm auditing all of the group entities.

(iii)  Barriers to Entry

  Per the figures in Appendix 1, there is a substantial gap between the revenue of the lowest of the Big Four firms and the revenue of the next accountancy firm on the list. Therefore, a fundamental change in the market or in the legal/regulatory environment would be required to foresee a situation where a firm not currently in the Big Four was to effectively challenge the market share of even the lowest ranked Big Four firm. The barriers to entry are substantial and are briefly summarised below.

Available Resources/ Breadth of Network

  In relation to servicing multi-national companies, not all networks have associate firms or sufficiently resourced associated firms in all key jurisdictions. Many large corporates therefore argue that only the Big Four firms provide the global reach that is required to service their particular operations. This will obviously depend on the nature and complexity of the entity's operations and the number of jurisdictions within which it operates, however, it is also not just the existence of a network firm in a particular jurisdiction but also the quality of the individual firms within that particular network which is key.

Litigation Risk

  The auditors of large multi-national companies are potentially exposed to legal claims the size of which could threaten the very existence of the firm. In theory, the larger the size of the firm the greater access it has to resources to meet any such successful claim.

Depth of Specialism

  On certain audits the depth of specialism required eg for the audit of a major bank, is unlikely to be present in sufficient volume outside of the Big Four firms.

Regulatory Costs

  The costs of having to comply with various different regulatory regimes across the globe are a significant barrier to entry for firms seeking to break into the listed company audit market.

(iv)  Growth by Merger/Acquisition

  Over the years many smaller firms have disappeared as firms have merged for a variety of reasons. Up until 1989, the audit market was dominated by the largest eight accountancy firms. Following further mergers the market was left with the Big Five which became four when Arthur Andersen collapsed due to the reputational damage suffered following the demise of Enron.

(v)  Economies of Scale

  Undoubtedly, accountancy firms would have viewed economies of scale as a potential benefit of a merger eg the savings in costs in relation to developing methodologies, systems, technical support, administration etc. However, significant costs had to be incurred to merge the working practices and systems of the firms involved.

2.   Does a lack of competition mean clients are charged excessive fees?

  To the best of our knowledge there is no evidence to suggest that clients are charged excessive fees. The Transparency reports produced by the larger accountancy firms show lower levels of profitability for assurance services than for other services provided. The vast majority of listed companies are in a position where they can instruct a number of audit firms and have the ability to put the audit out to tender on an annual basis, if they so wish. We do accept that in a few rare situations, conflicts of interest may restrict the choice to less than four firms due to the level of specialised knowledge required, particularly in certain niche sectors. Developments in corporate governance and in particular the increasingly important role of the audit committee also serve to prevent firms charging excessive fees. ICAS produced revised guidance in 2007 entitled: "Appraising Your Auditors"[9]. The Guide provides practical assistance to audit committees in handling the responsibilities recommended by the FRC Guidance on Audit Committees. In particular, the Guide helps audit committees in their critical roles of monitoring the relationship between company and auditor, overseeing the independence and objectivity of the auditors and, when appropriate, selecting new auditors.

  Additionally, surveys of audit fees in the FTSE sector are regularly undertaken and the price charged for an audit is specifically disclosed in the annual financial statements of a company. Therefore, the fee charged for an audit is transparent and companies can benchmark the cost of their audit versus that of their competitors.

We would also like to emphasise that the audit fee must be adequate to allow a full and proper audit to be undertaken in accordance with auditing standards.

3.   Does a narrow field of competition affect objectivity of advice provided?

  We do not believe that the existing field of competition impacts on the objectivity of the advice provided and we are not aware of any evidence to the contrary. Objectivity is a state of mind expected of a professional and in our view is not subject to improvement by increased competition.

4.   Alternatively, does limited competition make it easier for auditors to provide unwelcome advice to clients who have relatively few choices as there is less scope to take their business elsewhere?

  As with our response to the previous question a key ethical requirement is for auditors to be objective. We do not believe that the level of competition in the marketplace is a factor in an auditor's ability to challenge his client.

5.   What is the role of auditors and should it be changed?

Role of Auditor

  The role of the auditor is set out in sections 495-498 of the Companies Act 2006. This is summarised as follows:

    The auditor's primary role is to report to the company's shareholders on the truth and fairness of the company's annual statutory financial statements. The auditor also has to report on the consistency of the information contained in the directors' report with that contained in the financial statements. There are other related duties which can be found at the above sections of the Companies Act 2006. For listed companies, the auditor also has to report on whether the auditable part of the directors' remuneration report has been properly prepared and additionally review certain listing rules requirements.

Role of Auditor—recent developments

  Questions have been asked in recent times as to whether the role of the auditor is too narrowly defined eg paragraph 221 of the report of the Treasury Select Committee (TSC) "Banking Crisis: reforming corporate governance and pay in the City"[10] published in May 2009 stated:

    "We have received very little evidence that auditors failed to fulfill their duties as currently stipulated. The fact that some banks failed soon after receiving unqualified audits does not necessarily mean that these audits were deficient. But the fact that the audit process failed to highlight developing problems in the banking sector does cause us to question exactly how useful audit currently is. We are perturbed that the process results in `tunnel vision', where the big picture that shareholders want to see is lost in a sea of detail and regulatory disclosures. "

  Therefore, notably the TSC found little evidence to suggest that auditors had not properly performed their duties but questioned whether there was value in the audit. At a prestigious ICAS event "The Aileen Beattie Memorial Lecture"[11], held in April 2010, none of the panelists which included a senior investor representative and a FTSE 100 company executive, believed that the statutory audit should be abolished and assurance needs left to the market. They all expressed their support for the statutory audit and the role it plays although it was recognised that the auditor could be asked to do more in certain areas.

  Recent research undertaken on behalf of ICAS ("Meeting the needs? User views on external assurance and management commentary")[12] identified that there is significant demand for at least some degree of external assurance on the management commentary section of the annual report. This could therefore present an opportunity for additional assurance to be provided by the auditor.

  It would appear that there still remains an expectation gap between what certain stakeholders believe that the auditor is responsible for and what in fact his responsibilities are. In our view, moves could be made to meet some of these expectations but there are certain expectations which we do not believe can be met. To progress this issue, ICAS established a "Future of Assurance" Working Group earlier this year comprising representatives from the investment community, academia, the media, industry, regulators and the profession. The Working Group has now met twice and it is anticipated that it will publish its proposals before the end of the year. It is our intention to forward a copy of the final report to you once it is finalised. Matters that are being considered include the following:

    (i) Could the auditor do more in terms of reporting on "going concern"?

    (ii) Should the auditor provide assurance on the front end narrative section of the annual report?

    (iii) Would a more informative and discursive audit report be seen as beneficial?

6.   Were auditors sufficiently sceptical when auditing banks in the run-up to the financial crisis of 2008? If not, was the lack of competition in auditing a contributory factor?

  There is no specific evidence to answer this question in the affirmative or the negative. The Financial Services Authority and Financial Reporting Council have accused the auditing profession of lacking "professional scepticism" in its recent discussion paper[13] and the APB has published a paper[14] on this topic. However, the FSA/FRC paper does not contain any specific evidence to substantiate this claim.

  The auditor's role as stated above is to report on the truth and fairness, or otherwise, of the annual accounts. The auditor has to assess the assumptions and estimates made by management. This assessment is conducted against the requirements of the applicable accounting framework, with some accounting standards requiring a greater degree of judgement than others. Where management's judgement falls within the parameters of an accounting standard, it is difficult for the auditor to argue that their judgement is more appropriate than the judgement of management. Ultimately management is responsible for the preparation of the financial statements and they will naturally understand their own business in greater depth than their auditors. The auditor's role is to provide assurance that those financial statements are true and fair against the applicable financial reporting framework.

7.   What, if anything, could auditors have done to mitigate the banking crisis? How can auditors contribute to better supervision of banks?

  First and foremost, the auditing profession was not responsible for the banking crisis, as has been explained in various reports which have been published since the crisis eg the Turner Report[15].

    "At the core of the crisis lay an interplay between macro-imbalances which had grown rapidly in the last ten years, and financial market developments and innovations which have been underway for about 30 years but which accelerated over the last ten to 15, partly under the stimulus of the macro-imbalances. "

  Given the role of the auditor as discussed above, we are not aware of anything that auditors could have done to mitigate the banking crisis. Going forward, improvements could be made to the current regime by requiring regular meetings of all the auditors of large financial institutions with the body charged with monitoring financial stability.

8.   How much information should bank auditors share with the supervisory authorities and vice versa?

  As one of the issues in the years leading up to the credit crisis appears to have been the lack of meetings held between the FSA and auditors, it is essential that greater dialogue between these two parties is encouraged. It is therefore crucial that plans are introduced for regular meetings to be held to facilitate the sharing of relevant information where possible. Note we stress the "sharing of information" as we believe this has to be a "two-way" process and believe that increased dialogue can assist both parties in discharging their duties appropriately. Whist we have support for the concept of the proposed default position proposed by the FSA/FRC. "Both parties need to learn that, where there is a concern, the default should be to share the information unless there are restrictions that would prohibit this." we have concerns that there would still possibly be situations where the auditor is not made aware of something that might have a material impact on the audit. Therefore, in our opinion the best way to facilitate the appropriate sharing of information would be to introduce a reciprocal mandatory reporting obligation on the FSA to that which auditors are currently subject to.

9.   If need be, how could incentives to provide objective and, in some cases unwelcome, advice to clients be strengthened?

  We believe that there is no need to strengthen the current framework in this respect. Auditors do provide objective and on occasion unwelcome challenge to clients. Generally, the unwelcome challenge will be acted on by the board of directors rather than run the risk of having the audit report on their company's accounts qualified. Additionally, improvements have already been made to auditing standards and these will become effective for accounting periods ending on or after 15 December 2010. Likewise, revised ethical standards for auditors will become applicable early in 2011.

10.   Do conflicts of interest arise between audit and consultancy roles? If so, how should they be avoided or mitigated?

  Conflicts of interest can arise in certain situations eg where audit firms provide non-audit services to their audit clients. The extent of the conflict determines whether or not the auditor is able to provide the service in question. Some threats may be capable of being mitigated by the use of appropriate safeguards by the audit firm eg use of different personnel etc whilst others cannot be satisfactorily safeguarded and therefore the service cannot be provided.

  Following the aftermath of Enron et al, the Auditing Practices Board was tasked with producing ethical standards for auditors which audit firms are required to comply with. The APB published its standards in late 2004 (revised 2008) and they are one reason as to why the level of non-audit services provided by auditors to their listed audit clients has decreased significantly since 2001. The ratio of non-audit to audit services peaked in 2001 at a level around 3.1. By 2008, the ratio had fallen significantly to 0.7.

  In May 2009, Treasury Select Committee[16] recommended that:

    "We strongly believe that investor confidence, and trust in audit would be enhanced by a prohibition on audit firms conducting non-audit work for the same company, and recommend that the Financial Reporting Council consult on this proposal at the earliest opportunity. "

  The APB consulted late 2009/early 2010 on whether audit firms should be prohibited from providing all non-audit services to their listed audit clients. ICAS specifically set up a Working Group, comprised of representatives from the investment community, industry, academia and the profession to respond to the consultation. The Working Group also sought the views of leading investors and directors of listed companies and issued its paper in January[17]. Out of approximately 150 responses to the APB's consultation, only three were in favour of a complete prohibition being introduced. Therefore, the overwhelming message was that there should not be a complete prohibition on audit firms providing non-audit services to their listed clients. Additionally, the vast majority of respondents supported the "threats and safeguards" approach adopted by the APB in its standards. The APB however has taken the opportunity to make proposals which could further tighten up the types of the non-audit service that the auditor can provide. This consultation does not close until 23 October.

11   Should more competition be introduced into auditing? If so, how?

  ICAS supports the work undertaken by the FRC in raising the matter of limited choice in the audit market for listed companies, although we appreciate the limited impact that the proposals of the Market Participants Group have had to date. It is important that this is kept to the fore and the debates over the last year have certainly focused more attention on the issue. The ICAS view remains that the overriding priority in the short-term is to ensure that all of the big four firms remain in existence. In this respect we believe that reform of the current liability regime is urgently required. In 2007, the previous Government appeared to accept the argument for removing the "unlimited liability" regime for auditors. However, the optional contractual system put in place has had no impact on the market. There are no quick or easy measures, however, that can be put in place to bring forth another "very large auditor" and, of course, the issue is made more difficult as it goes beyond the UK.

  Other than legislation to introduce a fairer liability regime as indicated in our response in August 2006 to the FRC's initial consultation about choice in the UK audit market, we believe that this issue in general should be left to market forces. Market based measures are more likely to effect gradual and sustainable improvements than regulatory changes, which may have unintended consequences. We do not support regulatory intervention to artificially increase competition in the audit profession. As noted above the listed auditing market is not unique, there are a number of other industry sectors where the market is dominated by four or in some cases fewer major players. The possibility also exists that a new large accountancy firm might enter the market from one of the rapidly developing economies eg China or India.

  We have long argued that developing and implementing proportionate liability should assist in increasing auditor choice and that this should not be at the expense of audit quality. Companies need access to quality audits at a reasonable cost but there is a high risk attached to auditing multinational companies, which is due to the auditor being exposed to potentially very high claims compared to the profits of the auditing unit concerned and this acts as a deterrent to new entrants to the multinational market.

12.   Should the role of internal auditors be enhanced and how should they interact with external auditors?

  It should be realised from the outset that the roles of internal audit and that of the external auditors are entirely separate. The role of the external auditor as noted above is enshrined in legislation whereas there is no statutory requirement for any size of company to have an internal audit department although the majority of large listed companies do so. The role of the internal audit function is determined by those charged with governance of the organisation. Indeed the UK Code on Corporate Governance which listed companies are required to apply on a "comply or explain" basis implies that companies complying with the Code should have an internal audit committee in the accountability section of the Code.

  C.3.5  The audit committee should monitor and review the effectiveness of the internal audit activities. Where there is no internal audit function, the audit committee should consider annually whether there is a need for an internal audit function and make a recommendation to the board, and the reasons for the absence of such a function should be explained in the relevant section of the annual report.

  We believe this non-mandatory approach to internal audit to be appropriate. However, we also firmly believe that it is beneficial for listed companies to have an effective internal audit function. In order for the internal audit function to be effective it must have support at board level and not be seen as a mere compliance related function.

Interaction with External Auditor

  The matters which the external auditor should consider in situations where a client has an internal audit function are set out in International Standard on Auditing (UK and Ireland) 610 "Using the Work of Internal Auditors"[18]

    " (a)  To determine whether, and to what extent, to use specific work of the internal auditors; and

    (b)  If using the specific work of the internal auditors, to determine whether that work is adequate for the purposes of the audit. "

    In determining whether the work of the internal auditors is likely to be adequate for purposes of the audit, the external auditor shall evaluate:

    (a)  The objectivity of the internal audit function;

    (b)  The technical competence of the internal auditors;

    (c)  Whether the work of the internal auditors is likely to be carried out with due professional care; and

    (d)  Whether there is likely to be effective communication between the internal auditors and the external auditor. "

  The standard basically adopts the principle that it is for the auditor to decide to what extent he wishes to rely on the work undertaken by the internal audit function which at least to some degree will be determined by the nature of the work performed during the period by the internal audit function and the auditor's assessment of the quality of that work and independence of internal audit within the organisation. In our view this position is appropriate. We note that the International Auditing and Assurance Standards Board is currently revising this standard but we do not believe that the revision will alter the fundamental principle that it is for the auditor to decide to what extent he wishes to rely on the work of internal audit. We also support the function of internal audit as a mechanism for providing assurance within a company and as a basis for the directors to prepare their financial statements with confidence.

13.   Should the role of audit committees be enhanced?

  We believe that the role of the audit committee is already well established within the listed company sector. It is our belief that it is the composition of the audit committee and the diligence of its members which is key.

  We do, however believe that there is a greater need for transparency over the work of the Audit Committee. Current reporting requirements on the work of the Audit Committee can often result in "boilerplate" disclosures which add little to the stakeholder's understanding of their role and their interaction with the external auditors. The Audit Committee plays a critical role in challenging management's judgements and more disclosure in the Audit Committee Report could further the transparency of both the external audit process and the internal assurance processes within a company.

14.   Is the auditing profession well placed to promote improvement in corporate governance?

  Auditors can provide a mechanism for improving corporate governance. In isolation it is difficult to envisage how effective an audit firm could be in this respect without support from the other constituent parts ie the directors and the shareholders. Auditors are ideally placed to make recommendations to those charged with governance in relation to weaknesses in the governance framework in place within an entity but ultimately such recommendations need to be acted on by the company.

24 September 2010

APPENDIX 1 GLOBAL REVENUES OF THE 6 LARGEST ACCOUNTANCY FIRMS FOR YEARS ENDING 2009

GLOBAL REVENUES

PwC (1)Deloitte Touche

Tohmatsu (2)

Ernst &

Young (3)

KPMG (4)BDO (5) Grant

Thornton (6)

Year Ended31/05/2009 30/06/200930/09/2009 30/09/200930/09/2009


Global Revenues
$26.17b

($26.19b)

$26.1b

($27.4b)

$21.44b

($23.00)

$20.11b

(22.69b)

$5.026b

($5.144b)

$3.59b

($3.96b)

Assurance$13.14b

($13.81b)

$11.9b

($12.7b)

$10.14b

($10.83b)

$9.95b

($10.69b)

$3.02b

($2.89b)

$1.64b

($1.71b)


Sources

(1)  www.pwc.com

(2)  www.deloitte.com

(3)  www.ey.com

(4)  www.kpmg.com

(5)  www.bdo.com

(6)  www.gti.org


http://www.icas.org.uk/site/cms/contentviewarticle.asp?article=6852

http://www.icas.org.uk/site/cms/contentviewarticle.asp?article=5240

http://www.publications.parliament.uk/pa/cm200809/cmselect/cmtreasy/519/519.pdf

http://www.icas.org.uk/site/cms/download/AEB_Event_2010_Transcript.pdf

http://www.icas.org.uk/site/cms/contentviewarticle.asp?article=6852

http://www.fsa.gov.uk/pubs/discussion/dp10_03.pdf

http://www.fsa.gov.uk/pubs/other/turner_review.pdf

http://www.publications.parliament.uk/pa/cm200809/cmselect/cmtreasy/519/519.pdf

http://www.icas.org.uk/site/cms/contentviewarticle.asp?article=6645

http://www.frc.org.uk/images/uploaded/documents/ISA%20(UK%20and%20Ireland)%20610%20(final)%20.pdf




8   ICAS (2010), Meeting the needs? User views on external assurance and management commentary, Back

9   ICAS (2007), Appraising Your Auditors: A Guide to the Assessment and Appointment of Auditors, Back

10   House of Commons Treasury Committee (2009), "Banking Crisis: reforming corporate governance and pay in the city", Ninth report of Session 2008/9 HC 519, 15 May, The Stationery Office Limited, Back

11   ICAS (2010), Aileen Beattie Memorial Event-"Should Statutory Audit be Dropped and Assurance needs left to the Market", Back

12   ICAS (2010), "Meeting the needs? User views on external assurance and management commentary", Back

13   FSA/FRC (2010) Discussion Paper 10/3: "Enhancing the Auditor's Contribution to Prudential Regulation", Back

14   APB (2010, Discussion Paper, "Auditor Scepticism: Raising the Bar", http://www.frc.org.uk/apb/publications/exposure.cfm Back

15   FSA (2009), "The Turner Review-A regulatory response to the global banking crisis", Back

16   House of Commons Treasury Committee (2009), "Banking Crisis: reforming corporate governance and pay in the city", Ninth report of Session 2008/9 HC 519, 15 May, The Stationery Office Limited, Back

17   ICAS (2010), "The Provision of Non-audit Services by Audit firms to their listed company clients", Back

18   APB (2009)), International Standard on Auditing (UK and Ireland) 610 "Using the Work of Internal Auditors", Back


 
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