a internal control & internal audit - teija korpiaho

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    21 February 2013 Page 1

    Internal Control and Internal AuditTeija KorpiahoMalta, 8/4/2010

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    CEIOPS

    21 February 2013 Page 2

    Index

    Internal Control

    Concept and elements1. Control environment

    2. Control activities

    3. Communication

    4. Monitoring

    Documentation

    Compliance function

    Internal Audit

    Duties and responsibilities Proportionality

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    CEIOPS

    CEIOPS

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    BUT BOTH ARE IMPORTANT ELEMENTS OF GOVERNANCE

    INTERNAL CONTROL

    INTERNAL AUDIT

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    CEIOPS

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    Article 41 - General governance requirements

    an effective system of governance . sound and prudent managementof the business.

    The system of governance shall be subject to regular internal review.

    The system of governance shall be proportionate to the nature, scale and

    complexity of the operations of the insurance or reinsurance undertaking.

    written policies in relation to internal control, internal audit

    Insurance and reinsurance undertakings shall take reasonable steps to

    ensure continuity and regularity in the performance of their activities, including

    the development of contingency plans.

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    CEIOPS

    Underwritingrisk

    Market

    Risk Credit Risk

    Operational

    risk

    Strategic risk

    SCR-std

    Risk ManagementORSA

    SRP

    Internal Control

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    Article 46 - Internal control

    1. undertaking shall have in place an effective internalcontrol system.

    The system shall at leastinclude

    administrative and accounting procedures,

    an internal control framework, appropriate reporting arrangements at all levels of the

    undertaking

    a compliance function.

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    Internal Control the concept

    A set of continually operating processes involving theadministrative, management or supervisory body and alllevels of personnel.

    Designed to secure at least the following:

    a) Effectiveness and efficiency of the undertakings operations inview of its risks and objectives;

    b) Availability and reliability of financial and non-financialinformation; and

    c) Compliance with applicable laws, regulations and administrativeprovisions.

    The more principles (and risk) based regulation the more isrequired from the internal control and risk management of

    the undertakings

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    Elements of Internal Control

    Control environment Integrity and Ethical values Competence

    Control activities To ensure that management directives are carried out:

    approvals, verifications, authorizations etc. Communication

    Reporting and communication lines All levels of the organization

    Monitoring Management and supervisory activities, activities by the

    personnel Recommendations by Internal and external auditors

    Compliance

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    Documentation

    A key element of Internal Control Well documented = written

    Approved by administrative or management body

    Updated at least annually

    Strategies on

    Business, risk management (incl. liquidity, concentration risk,credit risk, operational risk), underwriting and reserving,investment and ALM, reinsurance, internal audit

    Policies on

    risk management, underwriting, remuneration, investment and

    ALM, internal control, outsourcing, disclosure, information

    Plans on

    contingency and compliance

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    Article 46 - Internal control

    1. ..

    2. The compliance function shall include advising theadministrative or management body on compliancewith the laws, regulations and administrative

    provisions adopted pursuant to this Directive. It shallalso include an assessment of the possible impact ofany significant changes in the legal environment onthe operations of the undertaking concerned and theidentification and assessment of compliance risk.

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    Compliance Function

    Compliance risk = the risk of legal or regulatorysanctions, material financial loss or loss to reputation anundertaking may suffer as a result of not complying withlaws, regulations and administrative provisions asapplicable to its activities.

    Compliance function - to ensure the undertakingcomply with applicable laws and regulatoryrequirements.

    Compliance plan

    Reporting: to report any major compliance problems itidentifies to the administrative or management body.

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    CEIOPSCEIOPS

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    Make the internal control system right for your undertaking!

    CEIOPS

    The internal control system should take into consideration

    The risks of the undertaking

    The way undertaking is organized

    The information system in use

    The decision making system

    Etc. etc.

    One size does not fit all

    CEIOPS

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    Article 47 - Internal audit

    1. Insurance and reinsurance undertakings shall providefor an effective internal audit function.

    The internal audit function shall include an evaluationof the adequacy and effectiveness of the internal

    control system and other elements of the system ofgovernance.

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    CEIOPS

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    Article 47 - Internal audit

    2. The internal audit function shall be objective andindependent from the operational functions.

    3. Any findings and recommendations of the internalaudit shall be reported to the administrative,

    management or supervisory body which shalldetermine what actions shall be taken with respect toeach of the internal audit findings andrecommendations and shall ensure that these actionsare carried out.

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    CEIOPS

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    Internal Audit 1(2)

    Systematic approach to evaluate and improve

    Independent From audited activities Own initiative Free access to all information

    Under direct control of administrative, management orsupervisory body

    Direct communication with staff Free to express opinion

    Effective

    Resource, remuneration

    Objective

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    CEIOPS

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    Internal Audit 2(2)

    Audit charter

    The purpose, authority and responsibility

    Audit plan

    Audit work for next year(s)

    Based on risk analysis

    Annually reporting to the administrative, managementor supervisory body

    Follow up of the recommendations

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    CEIOPS

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    Proportionality

    1. All undertakings shall have internal audit function

    2. The requirements of the directive should beproportionate to the nature, scale and complexity ofthe risks inherent in the business of an insurance orreinsurance undertaking.

    Not the size of the undertaking!

    The function must be in place but outsourcing is possible

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    Thank you

    [email protected]