What is independence and objectivity as they pertain to to internal auditors?

Here we look into distinguishing the difference between the two ethical concepts of independence and objectivity.

These ethical concepts have always enjoyed an element of interaction. In ICAEW’s 1987 Guide to Professional Ethics (now known as the Code of Ethics) the Statement on Professional Independence described it as a ‘concept fundamental to the accountancy profession’ and ‘an attitude of mind characterised by integrity and an objective approach’. This clearly explains objectivity as being part of independence.

In ICAEW’s 1997 Guide to Professional Ethics Statement 1.201 on Integrity, Objectivity and Independence referred to Objectivity as ‘independence of mind’.

Other more recent comments on the interaction have included independence being considered as ‘a measure of objectivity’, or to independence ‘enabling’ an objective conclusion. As we can see there is an element of circularity here.

Here we set out an analysis of current definitions, provide some practical illustrations of how they currently interact and share ICAEW’s thoughts on independence, drawing attention to ICAEW’s principles-based framework for resolving ethical problems.

In the current IESBA Code of Ethics 120.1 Objectivity ‘imposes an obligation on all professional accountants not to compromise their professional or business judgement because of bias, conflict of interest or the undue influence of others’.

The current IESBA Code of Ethics definition of Independence explains it as being made up of two elements: ‘Independence of mind’ and ‘independence of appearance’. The former is still defined to include integrity, objectivity and scepticism. The latter is defined as being free from ‘facts and circumstances’ that would lead a reasonable and informed third party to conclude that integrity, objectivity or scepticism was compromised.

This has been the extant definition for a number of years which perhaps explains why auditor independence is now largely viewed through the lens of compliance, with detailed rules to be followed rather than a more principles based threats and safeguards approach. Indeed, in contrast to what the 1987 document suggests, independence is now something that is only really a relevant consideration for an auditor or assurance provider, with the rest of profession concerned with objectivity.

As indicated above, independence has very much become a matter of regulatory compliance, where a checklist approach such as that illustrated below tends to be adopted to ensure that the auditor is free from (or at least manages) a prescribed list of circumstances under which independence is perceived to be compromised. The approach to auditor independence has increasingly become rules based rather than principles based.

Objectivity, on the other hand, is much more concerned with reasons and motivations behind certain decisions or behaviour. It is concerned with internal thought processes rather than lists of prohibitions. As such a framework such as the ICAEW framework for resolving ethical problems is more suitable for assessing objectivity than a checklist.

If we take the IESBA definition of independence, and regard objectivity and ‘independence of mind’ to be closely aligned (as was explicitly stated in early Guides to Professional Ethics) it stands to reason that both of the tools above are necessary to fully assess auditor independence.

(this is an example of an approach that has been adopted by some. It is not intended to be an exhaustive independence checklist and should not be treated as such).

  • Do staff have any direct/indirect financial interests in the audited entity? (290.102)
  • Do any partners or staff have personal, family or business relationships with officers or employees of the audited entity? (290.123 – 290.131)
  • Is there actual/threatened litigation between the firm and the audited entity? (290.228)
  • Have any staff received non-trivial gifts or hospitality from the audited entity or its staff? (290.227)
  • Are there any urgent reporting deadlines that may lead to resourcing issues and pressure from the management of the audited entity?
  • Does the audited entity have informed management? (290.163)
  • Has the audit fee exceeded 15% of the firm’s income for two consecutive years? (290.217)
  • Are there significant overdue fees from the audited entity? (290.220)
  • Is the firm adequately resourced to perform the audit?

The scenarios below illustrate the distinction (and interaction) between the concepts of independence and objectivity as defined by the IESBA Code of Ethics.

Auditor independence is, however, often an issue that finds its way into domestic legislation, and some countries take a slightly different (in some cases entirely rules based) approach. The different approach taken by countries to independence is illustrated in the following examples.

The UK FRC Ethical Standard defines independence as ‘freedom from conditions and relationships which, in the context of an engagement, would compromise the integrity or objectivity of the firm or covered persons’ (paragraph I23). It is described as underpinning objectivity but sufficiently distinct from it being concerned with the circumstances surrounding the relationship rather than the auditor’s state of mind.

This approach to independence is therefore very much more concerned with ‘independence of appearance’ rather than ‘independence of mind’, with a number of detailed regulatory requirements designed to ensure the former.

In Japan, independence requirements derive from the Japanese Institute of Certified Public Accountants (JICPA) Code and statute. They lay out detailed rules concerning financial interests, personal interests, scope of non-audit services and rotation of audit partners. The JICPA supplements this with some self-regulatory provisions however overall compliance is assessed by reference to a rules based approach.

The Swedish Auditors Act requires auditors to be independent, but the approach is very different and is much more principles based. The Act requires auditors to carry out a threats and safeguards analysis such that sufficient measures are taken to ensure that independence would not be questioned. There are five absolute prohibitions, far fewer than in the regulations of many other countries. The approach to auditor independence is therefore largely achieved through a principles based framework.

ICAEW advocates a framework approach to independence that:

  • Sets out fundamental ethical principles;
  • Provides a reasoned analysis of the possible threats to these principles; and
  • Gives guidance on the safeguards which may be necessary to mitigate these threats.

In short, we believe that this represents a more rigorous means of ensuring auditor independence. The most effective way to ensure the reality of independence is to provide guidance centered around a framework of principles rather than a detailed set of rules that can be complied with to the letter but circumvented in substance. Absolute requirements and prohibitions only have a place where no acceptable safeguard could reasonably be applied.

For example, a blanket prohibition on the provision of non-audit services to audit clients can be inefficient for the client and is neither necessary to ensure independence, nor helpful in contributing to the knowledge necessary to ensure the quality of the audit.

What is the difference between independence and objectivity as they pertain to internal auditors?

The approach to auditor independence has increasingly become rules based rather than principles based. Objectivity, on the other hand, is much more concerned with reasons and motivations behind certain decisions or behaviour. It is concerned with internal thought processes rather than lists of prohibitions.

What does independence mean for internal auditors?

In short, independence and objectivity means that internal auditors and the internal audit activity have, and maintain, the ability to make unbiased judgement and decisions based on the audit activities and facts and that they are free from any internal or external interference or obstruction with functional ...

What is the objectivity of internal auditors?

Objectivity is an unbiased mental attitude that allows internal auditors to perform engagements in such a manner that they believe in their work product and that no quality compromises are made. Objectivity requires that internal auditors do not subordinate their judgment on audit matters to others.

Why is objectivity and independence important in audit?

In auditing, perhaps more than in any other activity, there is a need for a readiness to recognise and avoid past mistakes. The auditor must adopt the objectivity and independence of mind to be able to acknowledge past errors or mistakes of judgement and report fairly and afresh.