Over the past few years we have seen a number of changes to the rules governing the independence of auditors. This has had a profound impact on this profession and the way we do business and has affected all partners, directors and professional staff. As a consequence, the firm has introduced many systems and procedures over the years to govern our independence and to ensure that our commitment to full compliance is achieved.
More recently, the global firm has made amendments to the Deloitte Policy Manual (DPM) affecting the independence rules and has updated the policies governing conflict checking. We are currently in the process of updating our systems and processes to cater for these changes.
The firm’s growth initiatives have involved many enquiries and conflict checks by service lines contemplating entering into joint ventures with other parties, merging businesses or simply acquiring businesses. This brings about a number of challenges to ensure that these services, to our restricted entity clients, are permissible and that the business relationships we enter into with our audit clients are acceptable in terms of the very stringent independence rules relating thereto.
An ongoing project is the BRMS policy to cover the new Deloitte Policy Manual (DPM) rules governing directorships and other similar appointments and trusteeships and executorships. We have required all professional staff to resubmit application forms for approval for their “other” directorships and for all trusteeships held.
Apart from the BRMS system the National Reputation, Risk and Independence team are involved in the following other systems to assist all our professional people and the firm on independence matters:
Conflict Checking System – We performed 4 755 conflict and relationship checks in 2011 and 4 976 in 2010 using 14 different databases. These checks are designed to ensure that no services are rendered to restricted entities that might result in conflict or independence issues.
All of these systems have formalised learning facilities which include an associated e-learning module which has recently been developed using a Southern African platform.
Other independence presentations and training is provided throughout the year to professional staff and partners/directors to keep them up to date and informed. Independence Tips are also included in “The Daily Planet”, which includes constant reminders to partners/directors and professional staff of the rules and cover frequently asked questions.
There is constant monitoring of partners/directors and professional staff through independence inspection and testing and through the annual independence declaration process. All our partners and senior managers in National Reputation, Risk and Independence are available to be consulted on difficult and complex independence issues.