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Appointment of Accountancy Firms

APPOINTMENT OF ACCOUNTANCY FIRMS

Contents:

Scope

Key Points

Background

Procurement

Qualifications

Capping of Liability

Payments by Results

Internal / External Audit Relationship

Annex: Independent Accountants Qualifications Requirements


Scope

1. This section gives guidance on the appointment of accountancy firms to undertake non external audit work such as internal audit, consultancy and corporate finance.


Key Points

2. There should be a presumption against accountancy firms involved in the external audit of an organisation undertaking non external audit work for the same organisation. In line with best practice this policy should apply to Audit Scotland where a member of staff of Audit Scotland is appointed by the AGS to undertake the external audit.

3. Non external audit services should be acquired by competition unless there are convincing arguments to the contrary.

4. Restrictions on accountancy firms' liability are acceptable where they represent an appropriate balance of risk and cost.

5. Close working relationships should be established between the internal and external auditors.


Background

6. Under the terms of the Public Finance and Accountability (Scotland) Act (the PFA Act) the Auditor General for Scotland (AGS) is responsible for the external audit of Departments and other direct funded bodies and office-holders. The PFA Act also allowed for the modification of enactments making the AGS responsible for the external audit of most sponsored bodies. (Some bodies which are wholly or substantially dependent on public funds are themselves responsible for appointing their external auditors e.g. bodies which have been set up as limited companies.)

7. As well as carrying out the audit himself / herself the AGS may appoint any qualified person to undertake the external audit on his or her behalf which might mean a member of staff of Audit Scotland or an employee of a private sector accountancy firm. However, there should be a presumption against accountancy firms involved in the external audit of an organisation undertaking non external audit work for the same organisation. Arguments which support the separation of the external audit and non external audit work include the need to avoid conflicts of interest and the possible loss of objectivity and independence. In line with best practice this policy should apply to Audit Scotland where a member of staff of Audit Scotland is appointed by the AGS to undertake the external audit.

8. Accountancy firms involved in the external audit of an organisation may undertake non external audit work for the same organisation only in exceptional circumstances and any such proposals should be cleared in advance by Scottish Executive Finance.


Procurement

9. Non external audit services should be acquired by competition unless there are convincing arguments to the contrary. The procedures to be followed - including, where applicable, compliance with European Union rules - should be those adopted in respect of any public sector procurement and Departments should seek the advice of their procurement units. Accountancy firms involved in the external audit of Departments should not be invited to tender.


Qualifications

10. For non external audit assignments generally, there are no formal requirements relating to membership of a particular professional accountancy body, although Departments should ensure that the qualifications of the firm or person tendering for the assignment are appropriate to the task to be performed. Guidance on qualifications requirements for reports on grant claims or other forms of assistance are set out in the Annex to this section.


Capping of Liability

11. Accountancy firms may wish to include clauses in contracts which impose a limit on their financial obligations in the event of claims being made against them for negligence or other reasons. In the case of non external audit work Departments may negotiate with firms over the terms of any restrictions on liability but they should be satisfied that the contract represents an appropriate and acceptable balance of risk and cost.

12. For example, if a private sector firm was to carry out individual internal audits under the direction of the Head of Internal Audit, the degree of risk would be low, and the firm would have a limited prospect of being sued other than for a sum related to the job being done. It would therefore be reasonable to accept a limit on the firm's liability with consequent advantages to the fee charged for that assignment. However, if the firm was responsible for the full internal audit service, including drawing up an internal audit plan, advising on audit need and producing an annual internal audit opinion, it would have accepted a high level of risk with potentially high claims. To safeguard the interests of the Department, the presumption should be that the firm must accept no capping of its liability, or at least must accept a high level of liability.

13. Although it may be argued that firms will apply more quality control and supervision if they perceive that their exposure to financial loss is high, they are likely to charge more for their services if they bear a higher level of risk. Departments should therefore weigh up the potentially higher cost of the service provided against the greater confidence that the job will be well done. By reducing their exposure to financial risk, private sector firms are limiting the scope of Departments to seek compensation in the case of loss and a balance must be struck between the interests of the Department and those of the firm. The balance of consideration should tilt towards greater satisfaction that the work will be done properly so that the need for redress does not arise.


Payments by Results

14. Some consultants offer services on a payments by results basis. In certain circumstances such services could represent a good value for money option provided that appropriate safeguards are observed.


Internal / External Audit Relationship

15. Departments should ensure that close working relationships are established between the internal and external auditors. The two types of auditor should consult each other and co-operate in order to seek opportunities to avoid duplication of work and achieve an efficient use of audit resources.

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Page Published/ Updated on: 21st December 2001

Page updated: Saturday, May 7, 2005