internal auditing hotline procedures and · pdf filearamco businesses and operations n...

51
Waheed Alkahtani, CFE, CISA, and ISO Lead Auditor Saudi Aramco Internal Auditing March 2012 © Copyright 2012, Saudi Aramco. All rights reserved.

Upload: phungmien

Post on 26-Mar-2018

212 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Waheed Alkahtani,

CFE, CISA, and ISO Lead Auditor

Saudi Aramco Internal Auditing

March 2012

© Copyright 2012, Saudi Aramco. All rights reserved.

Page 2: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

A Wealth of Data

employees who witnessed misconduct at work

46% reported the bad behavior

65%

Page 3: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

But it comes with its Risk

• Compliance

• We love tips

R&R

• email,

• websites, telephone

Volume • misheard

• mistreated

Risk

Mining for Hotline Gold, Robert Tie, Fraud Magazine, November/December 2011

Page 4: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Presentation Outline Overview: Understand

your requirements

Belling the cat: The implementation phase

Hotline management and best practices

Page 5: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Section I

Page 6: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Saudi Aramco • We employ almost 55,000 workers and are headquartered in Dhahran in

the Eastern Province. HR

• The Company manages proven oil reserves of 260.1 billion barrels, and the fourth largest gas reserves in the world, 279 trillion cubic feet. Reserves

• Our operations span the Kingdom, with production and product distribution facilities linking all market areas. Operations

• With operations in exploration, production, refining, petrochemicals, marketing and international shipping. Integrated

• Hold significant interests in refining and marketing companies in China, Japan, India, the Netherlands, the Republic of Korea, Singapore, the United Arab Emirates, the United Kingdom and the United States.

International

Page 7: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Challenges with Saudi Aramco Global Presence

Diverse Environment

Wide Range of Services

Business Solution Oriented

Page 8: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

The Main Goal The main goal is to establish a mechanism for

reporting noncompliance issues and other unethical behavior.

Page 9: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Best Practices

Oil and Gas

Service Providers

GCC

Page 10: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Gulf Cooperation Council

Page 11: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Oil and Gas Companies Contact us

Contact info

Phone and email info

In-house

Static web page

Simple feedback page

Outsource

Service providers

Multilingual

International office

Page 12: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Service Provider Anonymous reporting mechanisms

24/7

Case Management

Management Reports

Training and Awareness

Page 13: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Available Options

Outsource

In-house

Don’t touch it

Page 14: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Don’t Touch It

If it is not Broken

It is not our problem

Compliance

Management pressure

“The Tone at the Top”

Page 15: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

In-House

Cheap, Customized, and One-Stop Shop

Modest , Biased

Page 16: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Outsource IT

Easy, Independent

Costly, Compatibility Culture

Page 17: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Services providers are

More efficient and proficient

Provide flexibility

Allow you to focus

Save time, effort, and costs

Share your business risks

Page 18: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

But it may require

Service Level Agreement (SLA)

Legal and confidentiality agreements

It may create potential redundancies

Longer complicated approval process

More agreements to manage

Page 19: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Double-Edged Sword

• Save

• Extra

Cost

• Save

• Extra

Time • Share

• Hidden

Risk

• lack of trust

• Independent

Trust

Page 20: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

There is no “One size fits all” Start small and grow over

time.

Fulfill your needs and take the interests of your shareholders into consideration.

Outsourcing is a long-term partnership and you want to partner with the right service provider.

Page 21: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Factors to a Successful Hotline

Communicating

Reacting

Planning Polices and Procedures

Announcements Awareness and Marketing

Campaigns

Page 22: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Section II

Page 23: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

The Reporting Mechanisms

Report

Web

Telephone

IVR Fax

Email

Page 24: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

IVR Selections

Page 25: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

The Website General Goals R

epo

rtin

g

Provides an avenue for individuals to report non-compliance issues and irregularities within the Saudi Aramco Businesses and Operations

Co

mm

un

icat

ion

Provides an effective two-way communication, engaging all employees with the GA regarding case status and feedback M

ark

etin

g

Proactively promotes an ethical workplace, identifies conflicts of interest, and provides policies and procedures on business ethics

Page 26: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

The GA eHotline

Simple Independent

Private Secure

Page 27: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

The IA Hotline Process

Register

Report

Follow-up

Page 28: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

What to Report

Violations of any law or regulation applicable to the Company’s operations

Falsification of records or reports

Violation of the Company’s policies

Other irregularities, including fraud, theft and matters relating to conflicts of interest

Page 29: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Deployment Plan

Intranet

• Home

• Employees

Extranet

• Vendors

• Suppliers

Internet

• Full access

• Everyone

Page 30: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

What We Have Done

Web Application

Development

Secure Application

Server

Pilot Phase Final Design Announcement

Page 31: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

What’s Next

Awareness

• Meetings

• Announcements

• Posters

Enhancements

• Links

• Extranet

Tracking

• Number of hits

• Reports and logs

Page 32: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Section III

Ask not what the hotline can do for you, ask what you will do with the hotline results

Page 33: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Fire hose Water hose

Page 34: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Ask the following questions What is your scope of work?

Who will manage the hotline and who will administer it?

How will you handle a call or a tip?

Who will report it?

Page 35: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Call Handling

• The Hotline IVR system answers the hotline and forwards the calls to SAD auditors who interview the callers about their allegations

Income

• Calls will be directed to Arabic and English speakers according to the caller selection

Redirect

• “Saudi Aramco General Auditor Hotline.

• This is “YOUR NAME”, how can I help you?”

Greeting

• The call coordinator should log the call manually to IA e-hotline/log system while or after completing the call

Logging

Page 36: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Call Handling

• Questions should be constructed around when, where and how

Gathering

• Logs the information, fills the e-hotline form, and generates a reference number

Document

• Reference number

Closing

• A Complaint Report is emailed to the GA

After the call

Page 37: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Overview

• Emails

• Fax

• e-Hotline

• Phone

Combine

• Communicate items with the GA

Analysis • Special Audit

• Normal Audit

• HR or other

Dispatch

• Call categories

• Sources and allegation types

Report

Page 38: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Useful Measures Type

Allegation

Inquiries

Identity

Anonymous

Named

Source

Group

Location

Business lines

Level of employees

Management

Professionals

Education

Reporting methods

Online

Phone

Fax

Email

Walk in

Page 39: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Other Useful Measures

Life cycle

Actions

Substation rates

Geographic distribution

Trends against prior years

Page 40: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Questions

Appreciation

Wrong Number

Statistics on the Hotline

•30%

•Grievances

•Performance Management

•Discrimination

•20/12/2010

•380 calls

• 1-2 calls/day

•26% Phone Call

•24% Email

•3% Fax

•35% e-Hotline

• 12% Others

Inbox Figures

Other HR

Page 41: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Hotline Main Categories

Fin

ance

Accounting, Auditing and Financial Statement

Bu

sin

ess

Eth

ics Fraud, Conflicts

of interest, and Bribes

Mis

use

Vehicle Use, Employee Theft and Time-Clock Abuse

Hu

man

Res

ou

rces

Discrimination, Harassment and Compensation O

ther

Environmental, Health and Safety

Page 42: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Call Volumes Company risk areas

Organization culture and work climate

Workforce break down and staffing

Advertisements and marketing mechanism

Alternatives and other channels

Page 43: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

What May Cause Changes

News and Media

Regulatory Changes

Awareness and Training

A Real Problem

Page 44: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Hotline Trends

Page 45: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

• 7:00 to 4:00 versus 24/7 Working Hours

• Hotline with multiple reporting mechanisms, requires well-defined logging procedure and consolidation efforts.

Consolidation

• Many occasions require coordinating acts between various entities in the organization. Follow-up

• Companies with global presence and multinational employees have to consider multiple interfaces and translation issues.

Languages

Challenges

Page 46: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Other Challenges

Cal

l A

nal

ysis

So much data, but not always clear

Ben

chm

ark

ing

The need to demonstrate the hotline’s effectiveness

Rep

ort

ing

The need to report meaningful and actionable data to management

Page 47: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Hotline Kills Discouraging callers with questions or requests for advice

Long investigation cycle

Failure to publish sanitized outcomes for employees

Neglecting trends and benchmarks

Page 48: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Final Thought

Why don’t

people report?

The fear of retaliation

Who cares? Nothing

will happen

Page 49: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Conclusion N

ow

Reaction

Complex

Collective

65% L

AT

ER

Prevision

Simple

Awareness

75%

Page 50: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

Thank you [email protected]

Page 51: Internal Auditing Hotline Procedures and · PDF fileAramco Businesses and Operations n Provides an effective two-way communication, engaging all employees with the GA regarding case

“Association of Certified Fraud Examiners,”

“Certified Fraud Examiner,” “CFE,” “ACFE,”

and the ACFE Logo are trademarks owned by

the Association of Certified Fraud Examiners,

Inc. The contents of this paper may not be

transmitted, re-published, modified,

reproduced, distributed, copied, or sold without

the prior consent of the author.