A bit more on that audit consultation

Hmm....

ICGN

However, some of our members are concerned that these points could add to clutter without necessarily adding any meaningful disclosure. It could also result in standardised reporting on the process followed as opposed to more informed disclosures on how reliable the information is.

IMA

However, for boards to be required to state “the basis on which” they believe the annual report is so and provides users with information to assess the company’s performance, business model and strategy is likely to add clutter without necessarily enhancing transparency. Such disclosures could also become standardised on the process followed, as opposed to being informed disclosures on how reliable the information is, and certain of our members consider they would blur accountabilities and responsilbities between directors and auditors.

ICAEW

Disclosures regarding the basis of the board consideration may become boiler plate and add clutter to the annual report if companies provide a generic description of processes, without necessarily enhancing transparency.

ICGN

Though we stress, it is the full board that maintains the liability and accountability for ensure the integrity of financial reporting and for the annual report overall. Proposals for the committee to advise the board on the entire annual report could be seen as a delegation of power. It also places a further burden on the audit committee and does not take into account that some companies have committees that deal with particular aspects of the annual report such as risk committees

IMA

IMA considers it important that the audit committee does not undermine the role of the unitary board and its responsibility for the annual report overall. This proposal could be seen as a delegation of power. It also places a further burden on the audit committee and does not take account of the fact that some companies have committees that deal with particular aspects of the annual report such as risk committees.

ICAEW

The board already has full oversight responsibility for the accounts to give a true and fair view with or without the challenge from the audit committee. We wonder if this new requirement will be seen as placing an additional burden on audit committees and confuse the concept of the unitary board.

IMA

In summary, we consider the existing main and supporting principles under C.1 that: the board should present a fair, balanced and understandable assessment of the company's position and prospects in relevant reports, should be sufficient.

ICAEW

On that basis, we suggest that the existing main and supporting principles under C.1 should suffice: the board is responsible for presenting a fair, balanced and understandable assessment of the company's position and prospects in relevant reports.

IMA

We also support the enhanced communication over audit tenure, the period since the last tender, and the tender and selection processes. This information will be helpful for investors in assessing the frequency with which companies change their auditor.

ICAEW

Furthermore, we support enhanced communication over audit tenure, the period since the last tender, and tender and selection processes. The nature of this information is straightforward and should help meet the information needs of investors to assess the effectiveness of the external auditor.