Entity-Level Controls: The Internal Auditor s Assessment of Management Tone at the Top

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1 Current Issues in Auditing Volume 3, Issue Pages A1 A13 DOI: /ciia A1 Entity-Level Controls: The Internal Auditor s Assessment of Management Tone at the Top James Hansen, Nathaniel M. Stephens, and David A. Wood SUMMARY: The internal audit function s IAF regular interaction with management and continual presence within the organization place it in a unique position to monitor the organization. Although the IAF has significant potential to evaluate and improve corporate governance, research has yet to explore how internal auditors assess an important component of corporate governance management tone at the top. This paper reports survey evidence of 578 practicing internal auditors related to 1 current internal auditing practices regarding assessing management s tone; 2 internal auditors current assessments of management s tone; and 3 potential future practices internal auditors could perform to improve management s tone. In addition, we examine whether the tone at the top is higher in organizations where internal auditors perform tone at the top assessments and if assessments differ based on what level of internal audit professional performs tone at the top assessments. Keywords: internal audit function; tone at the top; entity-level controls; corporate governance. INTRODUCTION In October of 1987, the National Commission on Fraudulent Financial Reporting NCFFR; later called the Treadway Commission issued a report with five recommendations for improving the overall financial reporting process and increasing the likelihood of preventing fraudulent financial reporting and detecting it earlier when it occurs NCFFR The first two recommendations for improving corporate governance suggested by this report are 1 to improve the tone at the top set by management, and 2 to improve the internal accounting and auditing functions. Although these two recommendations are seen as critical for improving the corporate governance of an organization, relatively little research and discussion has examined how these two recommendations may interact such that internal auditors could act to improve management s tone at the top. To help fill this void, this paper provides evidence related to 1 current internal auditing practices James Hansen is an Assistant Professor at the University of Illinois at Chicago, Nathaniel M. Stephens is an Assistant Professor at Utah State University, and David A. Wood is a Visiting Instructor at Brigham Young University. We thank Michelle Scott, Kenney Reynolds, and Doug Prawitt for comments and suggestions on how to improve this paper. We also thank Dana Hermanson and Scott Showalter, the co-editors, and two anonymous reviewers for their thoughtful feedback and insights. Mr. Wood expresses his appreciation and thanks to the Institute of Internal Auditors Research Foundation IIARF for financially supporting this research as part of the Sabbatical Opportunity for Academic Researchers SOAR program. Although financially supported by the IIARF, the views expressed in this paper are those of the authors and do not necessarily represent positions or opinions of the IIARF or The Institute of Internal Auditors IIA. Submitted: 8 August 2008 Accepted: 8 January 2009 Published: 19 March 2009

2 A2 regarding assessing management s tone; 2 internal auditors current assessments of management s tone; and 3 potential future practices internal auditors could perform to improve management s tone. In addition, we examine whether the tone at the top is higher in organizations where internal auditors perform tone at the top assessments and if assessments differ based on what level of internal audit professional performs tone at the top assessments. Tone at the top refers to the entity wide attitudes of integrity and control consciousness, as exhibited by the most senior executives of an organization Reding et al. 2007, It is widely recognized as a critical component of high-quality corporate governance and can have a significant impact on every aspect of a company s operations. Internal auditing standards state that the internal audit activity should assess and make appropriate recommendations for improving the governance process by promoting appropriate ethics and values within the organization and by effectively communicating risk and control information to appropriate areas of the organization IIA 2008b. This is interpreted, in part, to mean that the internal audit function IAF should encourage the audit committee and senior management to set the proper tone at the top Reding et al. 2007, 7 10 and that internal auditors should periodically assess the ethical climate in the context of organizational culture and the tone at the top Reding et al. 2007, Thus, current internal auditing standards and best practices suggest that the IAF may serve an important role in improving the tone at the top by performing tone assessments and by making recommendations to improve the tone at the top. The remainder of this article discusses previous research on tone at the top and internal auditing, followed by a discussion of the findings of a survey that examines internal auditor practices and actual assessments of management s tone at the top. PRIOR RESEARCH ON TONE AT THE TOP AND INTERNAL AUDITING As noted above, professional standards and literature suggest the importance of management setting an appropriate tone at the top. Academic research complements the professional literature in this regard. D Aquila 1998 provides evidence from CPAs practicing in industry that organizations that have a higher tone at the top are associated with higher financial reporting quality. D Aquila and Bean 2003 provide experimental evidence that personnel placed in a situation where tone at the top does not foster ethical decisions are more likely to make unethical decisions. Not only does a positive tone at the top improve financial reporting quality, academic research provides evidence that tone at the top can also affect operating performance. Booth and Schulz 2004 find that strong, ethical environments reduce managers tendency to continue failed projects. Verschoor 1998 provides evidence that corporations that emphasize ethics as a part of corporate governance have higher financial performance. Hosmer 1994 finds evidence that organizations that adhere to ethical precepts have a significantly better chance of success than those engaged in dishonest and unethical behavior. In addition to affecting operating performance, tone at the top can influence external auditors decisions and consequently external audit fees. Dickins et al provide interview evidence that tone at the top is an important factor in determining the riskiness of a client and that external auditors charge more for risky clients. Margheim and Label 1990 find that management integrity has an influence on external auditors reliance on work performed by the IAF. These findings suggest that in addition to contributing to reducing external audit fees through direct assistance or through performing work relevant to the external audit e.g., Gramling et al. 2004; Prawitt et al. 2009b, the IAF can reduce external audit fees by improving the tone at the top of the organization.

3 A3 Internal auditors should be interested in these two ways of adding value by improving the tone at the top, as the definition of internal auditing states that the IAF is designed to add value to an organization Reding et al. 2007, 1 2. As described above, improving tone at the top can improve an organization s operations and financial reporting quality. 1 In related research, Asare et al find that internal auditors are sensitive to management s incentive to misreport financial information and increase budgeted work hours when management has a high incentive to misreport. This suggests that internal auditors are aware of factors that may affect the tone in the organization and adjust their audit plans based on this information. Although Asare et al consider how internal auditors react to management incentives to misreport, Asare et al. 2008, along with other research, do not explicitly consider how internal auditing is related to tone at the top. We attempt to fill this void by providing initial, descriptive evidence of the relation between internal auditing and tone at the top. We are interested in understanding current practices related to 1 current internal auditing practices regarding assessing management s tone; 2 internal auditors current assessments of management s tone; and 3 potential future practices internal auditors could perform to improve management s tone. In addition, we consider whether tone at the top is higher in organizations where internal auditors assess tone at the top and if assessments differ based on what level of internal auditor staff performs tone at the top assessments. RESEARCH METHOD We surveyed 578 practicing internal auditors to address how internal auditing relates to management s tone. To solicit participation, we used the IIA s GAIN Flash Survey technology. 2 This technology allows researchers to send surveys via the Internet to IIA members who have previously volunteered to participate. Respondents were asked questions regarding current practices and future plans with respect to management tone at the top assessments, as well as information regarding the company s size, industry, and the position of the individual completing the survey. Questions were in the form of point and click responses or, in some cases, short answer responses. Before administration, survey questions were reviewed by several employees of the IIA, and also reviewed by two researchers not involved with the study, to ensure clarity and contribution of knowledge regarding internal auditing practice. The survey for this paper was conducted in November Table 1 presents demographic information about respondents. As seen in Table 1, Panels A through D, participants were from a variety of industries and company sizes. Nearly half of the respondents were from publicly traded companies, and 80 percent of the respondents were from organizations that had more than $100 million in revenue, with 47 percent of the respondents from organizations with more than $1 billion in revenue. The respondents were primarily experienced internal auditors with 90 percent of respondents holding the chief audit executive, the internal audit director, or the internal audit manager position. 1 Internal auditing also has a direct effect on improving financial reporting quality. Prawitt, Smith, and Wood 2009 find evidence that higher quality IAFs are associated with lower earnings management. Prawitt, Sharp, and Wood 2009a find some evidence that higher quality IAFs are associated with lower accounting risk, and that companies that outsourced their IAFs to their external auditors, pre-sox, have significantly lower accounting risk than companies that keep the IAF in-house or outsource to another third party. For a comprehensive review of internal auditors relation with corporate governance, see Gramling et al A request to participate in the survey was sent out via to 10,169 individuals; however, the IIA indicated that typically 15 percent are returned as not deliverable. Thus, we estimate that approximately 8,643 auditors received the request to participate, making our response rate 6.7 percent. The IIA will not send a second request if the response rate is deemed large enough from the first solicitation which it was for this project. In addition, we were not provided with the order of when participants responded so we are unable to test whether there was an early/late response bias.

4 A4 TABLE 1 Descriptive Statistics of Sample Panel A: Industry All Respondents Respondents Who Make Assessments Aerospace and defense Agriculture/forestry/fisheries Communication/telecommunication services Construction/engineering/architecture Consulting services Distribution Educational services Energy/oil and gas Financial services/banking/real estate Gaming/lotteries Health services Hospitality/entertainment/restaurant Insurance carriers/agents Local government Manufacturing Mining National/federal government Nonprofit sector Pharmaceuticals Public accounting/accounting services State/provincial government Technology Transportation Utilities Wholesale/retail Other Panel B: Revenues $ All Respondents Respondents Who Make Assessments Less than 10 million million to less than 50 million million to less than 100 million million to less than 500 million million to less than 1 billion (continued on next page)

5 A5 TABLE 1 continued All Respondents Respondents Who Make Assessments 1 billion to less than 10 billion billion or more Panel C: Additional Questions All Respondents Respondents Who Make Assessments Companies that are publicly traded Companies in the Fortune Panel D: Role in Organization of Respondents All Respondents Respondents Who Make Assessments Audit Director Audit Manager Audit Services Contractor Audit Staff Chief Audit Executive Corporate Management Educator IT Audit Director IT Audit Manager IT Audit Staff Management Consultant Other; please specify: Risk Management Sample sizes ranged from 578 for All Respondents to 402 for the firms that Make Assessments. RESULTS Current Practices Regarding Assessing Management s Tone Table 2 presents current practices regarding internal auditors assessment of management s tone Questions 1 4. The vast majority of internal auditors in our sample perform tone at the top assessments: 70 percent of respondents indicate that they assess tone at the top currently, and 80 percent state that they plan to assess management s tone in the future. Half of all respondents indicated that they assess tone annually, while an additional 20 percent perform assessments at

6 A6 TABLE 2 Current Practices in Assessing Management s Tone at the Top Question 1: How often does the IAF assess management tone at the top and how often do they plan to assess tone at the top in the future? Plan to Assess Assess Now in Future Frequency Percent Frequency Percent Annually Never Other; please explain Quarterly Semi-annually Mean Tone Assessment if Frequency is listed as Never 3.60 Mean Tone Assessment if Frequency is listed as other than Never 4.28 Question 2: For respondents that assess tone, what positions are evaluated? Has Position in Company? Given Position Exists, Position Evaluated? Chief Executive Officer Chief Financial Officer Chief Operations Officer Chief Information Officer Chief Technical Officer Chief Marketing Officer Chief Security Officer President Vice President Controller Question 3: For respondents that assess tone at the top, who assists in performing assessments and what is the highest level involved in the assessment? Who Assists? Highest Level Involved? Chief Audit Executive Internal Audit Director Internal Audit Manager Frequency Percent Frequency Percent Mean Tone Assessment (continued on next page)

7 A7 TABLE 2 continued Internal Audit Senior/Staff Who Assists? Highest Level Involved? Frequency Percent Frequency Percent Mean Tone Assessment Question 4: For respondents that assess tone, to whom are findings reported? Frequency Percent Report to Audit Committee, Board of Directors, and Management Report to Audit Committee and Board of Directors Report to Audit Committee and Management Report to Board of Directors and Management Report only to Audit Committee Report only to Board of Directors various other frequencies i.e., quarterly, semi-annually, or other. We also asked respondents to provide their current assessment of tone at the top further discussed below. Responses were coded from 1 to 5 with 1 being Very Poor and 5 being Very Good. We find that respondents who work in organizations that assess tone at the top report higher tone at the top assessments than those respondents who do not work in organizations that assess tone at the top 4.28 assessment compared to While these results are subject to limitations discussed in detail at the end of the paper, they provide some evidence that internal auditors impact tone at the top by performing tone assessments. Of those companies that do assess tone at the top i.e., 70 percent of all respondents, the most frequently evaluated positions are the chief executive officer CEO position and the chief financial officer CFO position, which are both assessed by 86 percent of responding organizations that have those positions. If other chief officer positions are present in organizations, they are usually not evaluated when assessing tone. 4 This represents a potential area of improvement for internal auditors; while the CEO and CFO are likely the most visible leaders of an organization, other individuals can play an important part in building the culture of the organization. To the 3 These differences are statistically significant t = 5.34, p Results are significant at the same level using either a test that controls for unequal variances or non-parametric tests. 4 We should note here that self-reported survey data are subject to the possibility of misreporting due to carelessness, fatigue, or knowledge of the person completing the survey. While we made every effort to make the questions clear and understandable, one should interpret the results of the study with this limitation in mind. In relation to this question in particular, we find it odd that given the relatively large nature of the companies surveyed, many responses indicated the absence of positions we believed would be present in large organizations. We are unable to provide evidence as to the quality of responses on this question.

8 A8 degree that these other individuals are not setting the appropriate tone at the top, it could have significant negative effects on the overall culture of the organization regardless of the tone the CEO and CFO attempt to establish. Concerning who performs the tone at the top assessments, respondents reveal that all levels of internal auditors play a role in assessing tone. Approximately 55 percent of respondents indicate chief audit executive involvement in assessing tone; 41 percent indicate internal audit director involvement; 35 percent indicate internal audit manager involvement; and 22 percent indicate internal audit senior/staff involvement. Perhaps more interesting, while 83 percent of companies have high-ranking internal auditors performing tone assessments, the other 17 percent of companies indicate that the highest position involved in assessing tone is the internal audit manager in 14 percent of the cases and internal audit seniors/staff in the remaining 3 percent of the cases. Given how management s tone at the top can have significant effects on all parts of the organization, IAFs may want to examine whether having an internal audit manager or senior/ staff as the highest level involved in assessing tone is appropriate. Having lower-level internal audit staff work on tone evaluations and make recommendations may be highly effective if these evaluations are properly supervised and their work submitted to a well-structured review process. For example, lower-level internal audit staff may be more effective at soliciting truthful responses from employees than high-level internal audit staff. However, given the far-reaching effects tone can have in an organization, not having a review process in place could be highly problematic. 5 Many different groups in the organization may receive reports concerning the internal auditors assessment of tone. Of the responding individuals who assess tone at the top, 81 percent indicate that they report findings of the tone assessments to the audit committee, 22 percent report findings to the Board of Directors, and 56 percent of respondents report findings to management. This latter result reporting tone at the top findings to management may be problematic. The International Standards for the Professional Practice of Internal Auditing recommend that the head of internal audit report significant risk exposures and control issues, corporate governance issues, and other matters needed or requested to the board of directors/audit committee and/or to management IIA 2008a. The standard does not say all things have to be reported to both parties, and given the sensitive nature of internal audit s evaluation of management tone at the top, it may not be appropriate to report findings directly to management. Reporting assessments of management s tone to management may cause internal auditors to be less candid and forthright in their assessments of management s tone. 6 A further breakdown of recipients of tone assessments reveals that only management receives the tone assessments in 6 percent of the responses; whereas only the audit committee receives tone assessments in 32 percent of the responses. In 51 percent of the responses, both the audit committee and management receive the assessments. Given the potential impact on the internal auditors assessments, organizations may wish to consider whether reporting the assessment to management is appropriate. Management needs to be aware of the tone they are setting, but it may be more appropriate for the audit committee to discuss the findings of the IAF s evaluation of management s tone rather than the IAF directly discussing this issue with management. 5 We are unable to tell from our survey whether respondents interpreted this question to mean who makes the initial assessment or who is ultimately responsibility for the assessment process. If the former, this may not be problematic if, as suggested above, there is a high-quality review process in place. If the latter, however, IAFs may want to evaluate whether lower-level staff have enough experience and expertise to make this important assessment. 6 Previous academic research provides evidence supporting this conjecture. Lerner and Tetlock 1999 review psychological research on accountability and find that when audience views are known prior to forming one s own opinion, conformity becomes the likely coping strategy. External auditors also appear to believe internal auditors work is more objective when they report to the audit committee rather than a member of management, as they are more willing to rely on the work the IAF performs when they report to the audit committee e.g., Abdel-Khalik et al. 1983; Tiessen and Colson 1990.

9 A9 Current Assessments of Management s Tone In Questions 5 7 we asked participants how their assessments of management s tone has changed in the previous three years and how the amount of internal audit test work has changed as a result of their assessments. We asked participants to summarize their current evaluation of tone at the top as Very Good, Good, Adequate, Poor, or Very Poor. Table 3 presents participants responses to Questions 5 7 regarding their current assessments of management s tone at the top. Internal auditors provide generally positive assessments of management s tone: 94 percent of respondents indicate that the tone is adequate or better, and 47 percent indicate that the tone set by management is Very Good. In addition, few internal auditors reveal that the tone has worsened in the last three years only 3 percent indicate that the tone has decreased or significantly decreased. Management tone at the top may impact several aspects of an organization s compliance with company policies and procedures, internal control quality and effectiveness, and operations. Question 7 relates to the relationship between tone at the top and the extent of testing performed TABLE 3 Current Assessments of Management s Tone at the Top Question 5: For respondents that assess tone, what is their assessment of tone at the top? Frequency Percent Very Good Good Adequate Poor Very Poor Question 6: For respondents that assess tone, how has assessment of tone at the top changed in previous 3 years? Frequency Percent Significantly Increased Increased No Change Decreased Significantly Decreased Question 7: For respondents that assess tone, how has test work changed because of assessment? Frequency Percent Significantly Increased Increased No Change Decreased Significantly Decreased 2 0.5

10 A10 by the internal auditor. The discussion of Question 7 below is based on the assumption that internal auditors use a risk-based approach in determining the extent of testing they need to perform, and that part of the risk they consider relates to the impact of management tone at the top on the various aspects of compliance, operations, and control throughout the organization. If this is the case, we would expect internal auditors to be able to reduce testing in some areas for companies where the management has a high tone at the top as these companies would be less risky. If the IAF can reduce testing because of a high tone at the top, they may be able to focus additional resources on providing consulting or other value-adding services. Although the respondents indicated the tone seemed to be relatively good at their organization, 22 percent of respondents said they had to increase or significantly increase the amount of testing they did because of management s tone. 7,8 Furthermore, only 8 percent of respondents indicate they decreased testing because of tone. Given that 39 percent of respondents indicate that tone has increased or significantly increased over the previous three years, one might expect internal auditors to be able to reduce their testing in some areas because if the IAFs were using a risk-based audit approach, higher tone assessments suggest lower risk and lower risk can reduce the amount of testing the IAF performs. To the extent that management tone at the top impacts the amount of work performed, internal auditors may wish to consider if they can realize efficiency gains by reducing their testing if management s tone is assessed to be sufficiently high. Potential Future Practices to Improve Management s Tone Table 4 presents responses to two questions Questions 8 9 about possible directions internal auditors could pursue to improve the tone within their organization. The first question examines whether internal auditors believe making assessments of tone at the top and reporting to the audit committee would improve management s tone. Of the respondents, 46 percent either agree or strongly agree that making assessments would improve tone, while 23 percent disagree or strongly disagree that making assessments would improve tone. The relatively large percent of respondents who disagree with this statement may believe that making assessments would make tone worse or that it would have no effect. Alternatively, respondents may believe that management tone at the top would improve, but not substantially since tone assessments were already considered to be high unfortunately, we cannot distinguish between these possibilities with the data. However, we do note, as previously explained, that respondents indicated the tone at the top was higher in the organizations that were currently assessing tone at the top than in the organizations that did not assess tone at the top, suggesting that assessing tone at the top does improve tone. Often focus is placed solely on management s tone, but there are other important members of the organization who can influence the tone. The Board of Directors represents shareholders in monitoring management and the organization as a whole. As such, the tone provided by the Board could substantially affect the tone of the organization and especially the tone adopted by management. Internal auditors may be able to add value to the organization by evaluating the tone set by the Board of Directors. Of the organizations that assess management s tone, 37 7 Respondents were specifically asked regardless of whether you currently assess management s tone at the top, has your internal audit activity decreased or increased the amount of testing it has performed because of management s tone at the top please consider only changes due to management s tone at the top and do not consider changes due to other factors such as increased regulation, SOX compliance, etc.? 8 The mean tone assessment for the 22 percent of firms that increased or significantly increased testing due to management tone is significantly lower than the mean tone assessment of the 78 percent of firms that did not increase testing 3.85 assessment compared to 4.23; t = 2.93, p = This provides preliminary evidence that the IAF adjusts testing based on increased risk from lower tone assessments.

11 A11 TABLE 4 Potential Future Practices for Assessing Management s Tone at the Top Question 8: Evaluate the following statement: If the IAF were to assess and opine on tone at the top to the audit committee, then management tone at the top would improve substantially regardless of whether the respondent does or does not assess tone currently. Responses for Organizations that Currently Assess Management s Tone Responses for Organizations that Currently Do Not Assess Management s Tone Frequency Percent Frequency Percent Strongly Agree Agree Neither Disagree nor Agree Disagree Strongly Disagree Question 9: Does the IAF evaluate the tone set by the Board of Directors? Responses for Organizations Responses for Organizations that Currently Assess that Currently Do Not Assess Management s Tone Management s Tone Frequency Percent Frequency Percent Yes No percent also assess the Board of Directors tone. The relatively low number of participants who assess the tone of the Board suggests that internal auditors may be able to add value by assessing and reporting on the tone the Board sets within the organization. Alternatively, it may be that IAFs have already considered this possibility and do not believe it adds value. To the extent they have not, they may want to consider whether an assessment of the tone set by the Board may also provide information to internal auditors regarding risks that could be used in the planning of their audit tests. CONCLUSIONS Internal auditors are in a unique position to help improve the tone at the top of an organization. The findings presented in this paper suggest that internal auditors are aware of their ability to influence the tone of the organization and appear to be working to improve the tone at the top. Nevertheless, we identify six potential ways the IAF may increase its ability to improve the tone at the top. These areas include: 1 2 assessing and reporting on tone at the top a significant number of the respondents indicate that their IAF does not assess tone at the top ; expanding the assessment of tone to include more of the upper-management than just the CEO and CFO;

12 A ensuring that internal auditors with sufficient experience and interaction with uppermanagement are performing tone at the top assessments; examining who receives results of tone assessments; examining whether efficiency gains can be achieved by reducing testing in areas where a high tone at the top reduces the risk of problems; and considering whether tone would improve if the internal auditors evaluated and opined on the tone set by the Board of Directors. Which of these factors an organization decides to implement will be based on their individual needs. We note, however, that the responses to our survey from a large sample of IAFs across the United States suggest that organizations consider these points when designing their IAF. We believe that as the IAF works to improve tone at the top, internal auditors may help to improve the financial reporting process, improve operating performance, and reduce external audit fees. Before decision makers make changes based on these recommendations, we discuss several important limitations that may impact how this data is used. First, our sample was not randomly selected. It is possible that the results of this study do not generalize to IAFs that did not respond to the survey. Second, the responses to several of the questions we asked are open to alternative explanations. Decision makers should consider the alternative possible meanings of the responses to the questions before making decisions. Third, our measurement of tone at the top does not define what is good/bad tone at the top but instead leaves the respondent to provide a subjective estimate of tone at their organization. Since we solicited the opinion of individual internal auditors, the actual tone may be higher or lower than that reported in this paper as the reported tone in this paper is likely significantly influenced by the experiences of the individual respondent. This paper examines an area that has received relatively little past research attention. Hopefully, this article will encourage researchers to continue examining questions related to tone at the top, the IAF, and the intersection of the two. Specific questions that we believe would be interesting to examine include the following: Why do 20 percent of respondents have no plans to assess tone in the future? Do internal auditors understand the value that assessing tone can bring? Why do so few internal auditors assess the tone of the Board of Directors does it not add value or are internal auditors unaware of the value it could add? Since internal audit does not assess tone in many instances, are there alternative ways organizations are examining tone? How does internal audit interact with these alternative corporate governance mechanisms? These are just a few of the questions that practitioners and academics would benefit from answering by continued investigation. REFERENCES Abdel-Khalik, A. R., D. Snowball, and J. H. Wragge The effect of certain internal audit variables on the planning of external audit programs. The Accounting Review 58 2 : Asare, S. K., R. A. Davidson, and A. A. Gramling Internal auditors evaluation of fraud factors in planning an audit: The importance of audit committee quality and management incentives. International Journal of Auditing 12 3 : Booth, P., and A. K. D. Schulz The impact of an ethical environment on managers project evaluation judgments under agency problem conditions. Accounting, Organizations and Society : D Aquila, J. M Is the control environment related to financial reporting decisions? Managerial Auditing Journal 13 8 : , and D. F. Bean Does a tone at the top that fosters ethical decisions impact financial reporting decisions: An experimental analysis. International Business & Economics Research Journal 2 8 :

13 A13 Dickins, D. E., J. L. Higgs, and T. R. Skantz Estimating audit fees post-sox. Current Issues in Auditing 2 1 : A9 A18. Gramling, A. A., M. J. Maletta, A. Schneider, and B. K. Church The role of the internal audit function in corporate governance: A synthesis of the extant internal auditing literature and directions for future research. Journal of Accounting Literature 23 1 : Hosmer, L. T Strategic planning as if ethics mattered. Strategic Management Journal 15: Institute of Internal Auditors IIA. 2008a. International Standards for the Professional Practice of Internal Auditing. Available at: b. Performance Standard No. 2130: Governance. Altamonte Springs, FL: IIA. Lerner, J. S., and P. E. Tetlock Accounting for the effects of accountability. Psychological Bulletin : Margheim, L., and W. Label External auditor reliance on internal auditors when audit risk is high: Some empirical findings. Advances in Accounting 8: National Commission on Fraudulent Financial Reporting NCFFR Report of the National Commission on Fraudulent Financial Reporting. New York, NY: NCFFR. Prawitt, D. F., N. Y. Sharp. and D. A. Wood. 2009a. Internal audit outsourcing and the risk of misleading or fraudulent financial reporting: Did Sarbanes-Oxley get it wrong? Working paper, Brigham Young University, Texas A&M University, and Brigham Young University.,, and. 2009b. Does internal audit quality affect the external audit fee? Working paper, Brigham Young University, Texas A&M University, and Brigham Young University., J. L. Smith, and D. A. Wood Internal audit quality and earnings management. The Accounting Review. Reding, K. F., P. J. Sobel, U. L. Anderson, M. J. Head, S. Ramamoorti, M. Salamasick, and C. Riddle Internal Auditing: Assurance and Consulting Services. Altamonte Springs, FL: The IIA Research Foundation. Tiessen, P., and R. H. Colson External auditor reliance on internal audit. Internal Auditing 5 3 : Verschoor, C. C A study of the link between a corporation s financial performance and its commitment to ethics. Journal of Business Ethics :