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“AUDITING IN THE PUBLIC INTEREST”
NEWSLETTER, AUTUMN 2004
Winds of change
Since our last newsletter, we have released Chief Finance Officer: Roles and responsibilities (Good practice guide, 2004:1). This publication supports the Financial Management Compliance Framework developed by the Department of Treasury and Finance. This should assist CFOs, CEOs and audit committees, and will help organisations maintain an effective CFO function.
Our Autumn 2004 newsletter provides an update on the adoption of international standards and specifically addresses Disclosing the Impact of Adopting AASB Equivalents to IASB Standards (ED 129) and Pending Accounting Standard AASB 1: First-time Adoption of Australian International Financial Reporting Pronouncements. We will continue to provide updates on this important activity in future newsletters.
An article on “Guiding principles of corporate governance in the public sector” is also included. Good governance has been the subject of much consideration and public debate in recent times - and for good reason. The community is entitled to be assured that practices in the public and private sectors are as they should be in order to maintain confidence. Where confidence is eroded, governments must act to re-establish confidence in our institutions – hence the Sarbanes/Oxley legislation in the USA, and CLERP 9 here in Australia.
The public sector – as we are all too aware – is not immune from these winds of change and must collectively and individually re-examine its own practice to ensure that community trust is maintained.
Don’t forget that all of our publications, including parliamentary reports and this newsletter, are available on our website at <www.audit.vic.gov.au>. We recently enhanced our website with links to other websites that have better practice material. If you have feedback on these, or other aspects of our website, please contact us.
Wayne Cameron
Auditor-General
PURPOSE OF OUR NEWSLETTER
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Auditing in the Public Interest is published to provide information to public sector agencies on recent activities of the Victorian Auditor-General’s Office, and current developments in financial disclosure and reporting. Information on audits currently underway and scheduled for completion in the Autumn 2004 session of Parliament is also provided.
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Contents
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Auditor-General’s reports
Reports to be tabled in the Autumn 2004 session
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International Standards update
• Financial Reporting Council confirms 2005 deadline
• Disclosing the impact of adopting AASB equivalents to IASB standards (ED 129)
• Pending Accounting Standard AASB 1: First-time Adoption of Australian
International Financial Reporting Pronouncements
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Office news
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Guiding principles of corporate governance in the public sector
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2004 Public Sector International Financial Reporting Standards Conference
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Auditor-General’s reports
Reports to be tabled in the Autumn 2004 session
The following reports are to be scheduled to be tabled in the Autumn 2004 session of Parliament:
• Budget development and management within departments
• Development of policy advice
• Occasional paper - Sustainability: From silos to systems
• Beating the bugs: Protecting Victoria’s economic crops from pests and diseases
• Report on public sector agencies: Results of special reviews
• Delivery of home and community care service by local government
• Managing emergency demand in public hospitals
• Report on public sector agencies: Results of financial statement audits for agencies with balance dates other than 30 June 2003
• Control and compliance audits: Accounts payable
• Maintaining public housing stock.
Information about these reports are available on our website at <www.audit.vic.gov.au> <Audits in progress>.
International Standards update
Financial Reporting Council confirms 2005 deadline
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The FRC has reached a unanimous in-principle agreement to proceed with the current Australian timetable for the adoption of international accounting standards from 1 January 2005. However, support for this position is subject to an assurance from the AASB that a complete set of standards will be available on the AASB website by 30 June 2004. The most contentious standard, namely IAS 39 relating to financial instruments, will be adopted in its current form, even though further amendments by the IASB are imminent. The decision for the timing of the issue of the Australian version of IASB standards will be determined by the AASB. It is now expected that all pending standards will be issued as final standards during June 2004.
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For reporting periods beginning on or after 1 January 2005, all reporting entities are required to prepare financial reports in accordance with Australian equivalents of the International Financial Reporting Standards. As the Australian Accounting Standards Board (AASB) has committed to issuing sector-neutral standards, these will apply to both private and public sector entities.
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As at mid-March 2004, there are 21 pending standards that the AASB has approved. These can be accessed at the AASB’s website at <www.aasb.com.au>. Their status as pending standards reflects the AASB’s decision to prevent early adoption of these standards on either a full or piecemeal basis. The AASB is, therefore, progressively approving and releasing internationally harmonised Australian standards as pending standards prior to publishing them all on the same date.
Disclosing the Impact of Adopting AASB Equivalents to IASB Standards (ED 129)
ED 129: Disclosing the Impact of Adopting AASB Equivalents to IASB Standards is of importance as, when finally issued as a standard, it will mandate disclosure requirements for both 30 June 2004 and 30 June 2005 reporting. The AASB believes that it is vital that users of an entity's financial statements are informed about the changes that adoption of internationally harmonised standards will bring about in the financial statements. Forewarned is forearmed.
Although not yet finalised, at its meeting on 3-4 March 2004, the AASB decided that ED 129 would require disclosure of:
• for 30 June 2004: narrative explanation on the way in which the entity is managing the transition to the internationally-harmonised standards and changes in accounting policies expected to have material impacts
• for 30 June 2005: estimable quantitative information concerning how the application of the internationally-harmonised standards would have affected the financial statements for that period.
Entities now need to start thinking about the standards that might have a material impact on their financial statements. For public sector entities that are not-for-profit and do not have significant amounts of complex financial instruments, the number of standards that will have this level of impact may be limited.
Pending Accounting Standard AASB 1: First-time Adoption of Australian International Financial Reporting Pronouncements
One of the first major challenges facing any entity when introducing the new accounting standards applicable to the first reporting period commencing on or after 1 January 2005 will be to fully address all the implications that flow from Pending Accounting Standard AASB 1: First-time Adoption of Australian International Financial Reporting Pronouncements. Once it has been confirmed that the new standard is applicable to the entity in question then a detailed analysis of the requirements should be undertaken and the likely impacts identified.
One of the most significant impacts of AASB 1 is the need to retrospectively apply many of the new standards to be adopted, but with certain limited mandatory and optional exceptions. These exemptions need to be identified early, because while the mandatory exemptions will save time and effort, the optional exemptions will require a cost-benefit analysis of data collection, systems implications and identifying the ongoing implications of each exemption chosen. AASB 1 also contains a number of significant disclosure implications, which will require careful planning if the entity is to smoothly progress to the new reporting regime.
Furthermore, the analysis of AASB 1 cannot be done in isolation. There is a compelling need to identify the impact of each and every pending standard as it is issued, not only to determine the transitional requirements relating to AASB 1 but also to establish the ongoing administrative and resourcing requirements of these new standards.
The most significant areas of early impact include the recognition and measurement of financial instruments, which will involve recognition of assets and liabilities not previously disclosed on the face of the statement of financial position. The more restrictive rules of impairment will apply, instead of the existing recoverable amount test. Where internally-generated intangible assets have been recognised, they will either have to be remeasured using prices from existing active markets or be removed from the statement of financial position.
For a not insignificant number of public sector entities, implementing the new “balance sheet” approach to accounting for income taxes, will prove to be a challenging exercise. The concepts of “timing” and “permanent” differences are replaced by a “temporary” difference which arises when the amount calculated in the tax balance sheet differs from the amount in the accounting balance sheet! While not conceptually difficult, the fact remains that few accountants, even in the private sector, have ever constructed a tax-based balance sheet along the lines set down in AASB 1020: Income Taxes.
Future challenges and directions
Entities should realise that the new standards can have significant implications across the whole entity and that it is important that all staff, not only financial reporting and audit staff, are appropriately briefed and trained to address the needs of the new reporting regime.
The Victorian Auditor-General is working closely with members of the Department of Treasury and Finance (DTF) to ensure a coordinated approach to the new reporting standards. DTF has produced a comprehensive summary of current status of standard setting in Australia in its latest Financial Reporting Update, Edition 5, January 2004.
Future articles in Auditing in the Public Interest will address significant issues for the public sector that arise from Pending Standards to be issued over the next few months. If members of the public sector have particular concerns with the new standards regime, please contact Jim Dixon, Assistant Auditor-General, Accounting and Auditing Policy, on <jim.dixon@audit.vic.gov.au>.
What kinds of support will we offer?
The Office has devised a strategy and program to support audit clients, audit service providers and other stakeholders to understand and successfully implement the requirements of AIFRPs. While the program will give particular emphasis to the needs of departments, local government and statutory authorities, the needs of corporate entities will also be addressed.
There are several means by which the Office intends to deliver its strategy:
• Auditor-General support letter: the Auditor-General will write to all audit clients and audit service providers reminding them of the implications of Australia’s decision to adopt IFRS for reporting periods commencing on or after 1 January 2005
• internet: the Office will shortly establish and maintain an internet site that will contain key information (e.g. differences between pending/proposed standards and existing generally accepted accounting principles – GAAP, public sector implications, Office policy)
• support on request: the Office will respond to particular queries concerning the impact of the new standards on the public sector
• articles in Auditing in the Public Interest: to enable the reader to be kept up-to-date with the broad developments of international harmonisation
• audit staff: will continue to deal with specific queries. Audit clients need to discuss the changes resulting from the transition to international standards with Office audit staff as early as possible. For most clients, this should be made a regular item for discussion at audit committee meetings
• participate with DTF in its strategy of client training: demonstrating our combined commitment to ensuring the state public sector’s successful transition to AIFRPs.
Questions?
If you have any questions concerning how we will support you as we move towards adoption of international standards, please contact the Office Financial Audit Director responsible for your audit/s.
Office news
The Auditor-General, Wayne Cameron, has been appointed to the International Federation of Accountants, Public Sector Committee, representing Australia.
Guiding principles of corporate governance in the public sector
The following article is based on a presentation by Wayne Cameron to the IPAA – Spotlight on Spring Street series in June 2003.
What is corporate governance?
“Governance is concerned with structures and processes for decision making, accountability, control and behaviour at the top of an entity”. (IFAC)
“It influences how the objectives of an organisation are set and achieved, how risk is monitored and assessed and how performance is optimised”. (ASX)
It is generally understood to encompass authority, stewardship, leadership, behaviour, direction and control.
Good governance will result from behaviour rather than process
Good governance will not guarantee good practice, but it does provide a discipline around which to frame quality processes and relationships.
“If nobody makes the rules then it turns into a game without rules – and nobody wins that kind of game”. (John Macdonald)
Counsel assisting the HIH Royal Commission was recently reported as saying that corporate Australia should aspire to improved moral and ethical standards rather than tick-in-a-box corporate governance. Processes are important as the means to the end - not the end in itself!
Governance framework
This diagram is a modification of my Office’s 2003-04 Annual Plan. It demonstrates how the elements of an effective governance structure are inter-related.
Each of the 4 pillars is discussed below.
Leadership, stewardship, management control and risk management are included at the centre to ensure that they are not overlooked by those holding governance responsibility.
Proposed Minister of Finance Directions require that: “A public sector agency … have a financial code of practice setting out a cohesive statement of the agency’s internal processes to ensure probity in the agency’s management”. The guide goes on to set out what the agency’s code of practice must include:
• tendering, conflict of interest, confidentiality, unlawful or unethical behaviour
• it also requires that each agency maintain appropriate structures and responsibilities to ensure compliance with the code.
Much of the public debate has centred on the corporates and on issues unique to the corporate sector – issues such as incentivised remuneration arrangements, related party abuse, conflict of interest issues.
But we should not dismiss the debate as irrelevant. The public sector has its share of governance issues to be concerned about as well. We should take this opportunity to make sure that we all learn from the debate and ensure that we in the Victorian public sector apply best governance practice at all times.
Strategy and direction
Those with governance responsibilities must establish the entity’s strategy and direction.
Goals should be explicit about performance objectives and relate those objectives, supported by plans covering finance/costs, assets, technology and personnel requirements.
Both long and short-term goals and objectives need to be supported by specific strategies for their achievement.
It is important that strategy, policies and other directions be clearly specified, communicated and understood by those parties responsible for their implementation. Responsibilities and accountabilities must be clear.
Departments – Strategies and directions will be developed by the respective secretaries/ministers in the context of the government’s goals and desired outcomes.
Local government – Strategies and directions will be developed by the council in consultation with the local community (through best value) within the constraints of enabling statute.
Statutory boards – Strategies and directions will be developed in the context of enabling statute having regard for the government’s goals and desired outcomes.
An example - Statutory bodies
Parliament has established boards to oversee the management of the entity.
The board is responsible for setting corporate objectives, developing policies governing day-to-day operations and overseeing the implementation of those policies through the CEO.
The Crown has retained certain rights, usually espoused in legislation, which are exercised through the responsible minister, namely:
• to exercise control over the entity and determine its direction, as expressed in legislation
• to appoint and dismiss members of the board
• to approve the size, shape and scope of the entity’s operations
• exercise other rights contained in legislation.
The board is immediately accountable to the responsible minister for the performance of the entity. The minister is responsible for ensuring the entity is managed in the Crown’s interests, and so plays a key part in the governance framework for the entity.
Structures and relationships
Effective governance requires explicit role definition of key participants in the governance process and the control, reporting and accountability structures established to facilitate communication, action and monitoring.
Governing body members need a proper induction process to ensure that they are clear about their role and about that of management, and the nature of the relationship with the government (usually the responsible minister) and the department.
Determinations should be made about powers and delegations (this must be done in the context of the governing legislation).
The nature, timing and method of information flows need to be defined.
Clear views are needed about what must be referred to owners (minister) for consideration or information:
• business plan (including financial plans) – define nature, scope and location of business
• strategy, policy and performance monitoring information
• regular assessment of relevant risks and proposals with potential to impact on the risk profile of the organisation
• investment/divestment considerations
• information about the public profile.
Business structures
A clear view is required of:
• purpose of business structure
• expectations of stakeholders
• determination of powers/delegations
• information flows
• explicit definition of relationship between parent and subsidiary (e.g. entity and committee).
Boards
“Governing board members are accountable for their conduct and the strategic direction and performance of the agency as well as the agency’s compliance with other requirements.” (WA Public Service Guide). Boards must have a full understanding of the organisation, the environment in which it operates and the issues it faces. (Refer to AICD Checklist for guidance on what prospective directors ought to do before accepting appointment to a board body.)
Subsidiary company model
Changes rights and responsibilities – from parent to the subsidiary company.
Any transfer of the legal ownership makes it essential that the parent keeps close control over its subsidiary – can be achieved through direct representation by the parent on the board of the holding company, and oversight of the business direction taken by the companies in the group.
Changing delivery arrangements
There is no doubt that the development of alternative service delivery models in the public sector will continue out into the future just as it has in the recent past. At times of such change, clear and explicit consideration, decision and communication must be given to the impacts of these changes on maintaining effective governance arrangements.
Whenever services are performed by other providers – whether they be on contract, through franchising arrangements or partnerships or joint ventures – the governance arrangements must be accorded priority.
Boards
Appointment and membership
• Requisite skills, tidy and transparent appointment process, induction and review.
• Mixed board membership confuses accountability and roles, and distorts information flows.
• Should CEO be on the board?
Common expectations
• Explicit record of the relationship between the board, and responsible minister about shared understanding between the 2 about what the board is there to do.
• Clear lines of accountability and authority between the board, CEO and responsible Minister.
• Board members to understand public sector legislation, procedures and practices, and have an awareness of the importance of following acceptable standards of conduct and behaviour.
Obligations of being a public body
• Board member to understand public sector conventions and practices.
• Standard of behaviour.
• Identification and management of conflicting interests.
• Understand relationship with government.
Staff skills
• Recent survey of sample Fortune 500 US companies revealed that 20 per cent of CFOs were qualified accounting professionals.
• CPA survey in May 2003 reported that 81 per cent of organisations preferred a CPA as CFO; and 74 per cent wanted a CPA as audit committee chair.
Committees
Advisory committees to:
• minister – ensure objective advice: perception of independence
• CEO and board/councils.
Any advisory committee structure (e.g. economic development, audit etc.) needs to be mandated explicitly with a clearly set out charter, powers, functions and duties.
Management committee – what are they but a form of internal communication and method of achieving consensus? They must not undermine primary accountabilities.
Audit committee
• Established feature of corporate governance is having an effective audit and risk committee with an independent chair to oversee compliance and risk management.
• Members must have a knowledge of the business.
Ministry of Finance Directions
• At least 2 members must be independent and appear as such in the annual report.
• Must have a charter.
• Must be fully accountable to the responsible body.
• Accountable officer and CFO not to be members.
• Chair to be independent and cannot be the chair of a governing body, unless exempted.
• Sets out requisite skills.
• Sets out functions, powers and responsibilities.
• Oversight of risk management framework.
Minister/board/management relationships
Minister/board/management relationships are areas which require careful management.
Role of the responsible minister
Each minister is free to determine how best to undertake their responsibilities, but core features should include:
Role of advisors – needs explicit understanding by all the parties about the role of advisors – best dealt with formally in writing.
Ministerial directives – such directives should be transparent. These need to be explicit as they affect accountabilities.
Board/management relationships
The relationship between the board and management is critical to an organisation’s long-term success. However, problems do arise when the different interests of the board and management are not defined. Some common problems include:
• interference by board members in operational matters
• managers become hesitant to make decisions
• managers delegate difficult decisions upward which leads to a risk-averse or conservative culture
• boards spend too much time on minor matters, and thus overlook the major ones.
Governing board relationships with responsible minister – see WA Better Practice Guide.
Codes of conduct
Minimum standards of corporate behaviour
Cue is taken from the top – shared vision, collaboration/openness, ethical values and respect for different views. Examples:
• compliance with law
• treatment of employees – fair and reasonable
• unbiased tendering and purchasing
• control over sensitive expenditures, e.g. travel, hospitality, sponsorship
• management of potential or actual conflicts of interest
• use of transparent/open processes to distribute funds
• provision of public access to information about the organisation and its operations.
Conflict of interest
Conflict of interest takes many forms and is worthy of a separate discussion on its own merits
Examples of conflict of interest, e.g. ENRON, HIH Insurance
“ENRON board’s worst failure, governance experts say, was to overlook the dual role of the Company’s CFO who reaped $30m by simultaneously running limited partnerships that did business with ENRON. – Should have been a red flag to the board. Having your CFO on both sides of a transaction reflected badly on the judgment of management.”
A person can’t serve 2 masters!
There should be explicit guidelines about what constitutes a conflict of interest and what to do about it whenever the possibility occurs, or might occur. A register of conflicts of interest should be maintained for all board members.
I don’t deny the difficulty. I recently attended a forum on the changing arrangements for auditing standards, and the subject of independence was traversed – in the context of the HIH Royal Commission findings. I was intrigued to hear the speaker refer to the difficulty people have in grasping the notion of conflict of interest. That too, is my experience. People may understand the notion as it applies to others (especially competitors), but just don’t see it when they are involved!
Regarding public servants on the board – this may indicate a conflict of roles; observer status may be a better compromise.
The common practice in the public sector of having a senior departmental official on the board of a statutory agency is one such issue, as is the practice of one’s CEO also being on the board. These practices can work well, but when they don’t, the tension that exists when the person seeks to fulfil the dual or multiple roles rapidly comes to the surface. There is still a way to go in the Victorian public sector to simplify these lines of responsibility and accountability.
Nominee directors
• Nominee directors face conflict between their responsibilities to the entity and the board/council to which they were primarily appointed. Elected representatives are responsible for promoting community interests, which may conflict with the commercial objectives of the commercial entity.
• Nominee directors should not be a substitute for formal monitoring arrangements between subsidiaries and the council.
• CEOs should not be put in a position of conflict between their roles as advisors to council and their obligations as company directors.
Performance monitoring
Determine what should come to the board - content and frequency - governing bodies should be monitoring the big things.
Tracking against agreed goals, money, tasks and risk management activities
The monitoring and reporting systems need to be timely for senior management and the governing body when things begin to divert from planned outcomes.
This means coherent data collection and reporting systems that need to be coordinated, integrated and accurate. There is some evidence that some entities continue to struggle in this area post-amalgamation.
The lack of discipline about information requirements ranks as the single most common reason why difficulties develop and may frequently become terminal in organisations. The lack of complete information denies timely intervention to turn adverse circumstances around.
This may be an area for future audit attention
Monitoring of risks needs to be targeted
There are different types of risk in the public sector, i.e. more than merely financial risk, also political risk – community confidence, social risk, environmental risk, and public safety risk.
Monitoring arrangements for an entity needs to reflect an assessment of the risks and opportunities facing the business, with a view to protecting and promoting the owners’ interests.
Our recent report on Managing business risk in the Victorian public sector identified some progress, but there is still some way to go – especially in internal awareness about what constitutes risk, and in reporting procedures.
When do you need to alert the minister about matters, which may materially affect the Crown’s interests?
Compliance and accountability
It is important to monitor compliance. There is a need for proper reporting processes for surfacing non-compliance.
The Public Sector Management and Employment Act 1998 sets out obligations of an agency head – supported by a Code of Conduct published by the Commissioner for Public Employment:
Section 13. Department heads are responsible to agency minister or ministers for the general conduct and the effective, efficient and economical management of the functions and activities of the department.
The Financial Management Act 1994, s. 42 requires that there be an accountable officer for each department and public body. An accountable officer has certain obligations/responsibilities mainly related to financial management and maintenance of proper systems, compliance with directions issued by the Minister of Finance, and which includes reporting performance and preparing financial statements and a report on operations each year.
I continue to be amazed at the number of those with governance responsibilities not familiarising themselves with the primary legislation of their organisation.
Importance of recognising trade-offs between performance and compliance
The public sector is under the public gaze; all the more reason to invest in explicit processes so that our talented people can seek innovative solutions.
Disclosure of corporate governance practices: In ex-ante documents and ex-post reports.
APRA winners of Good Governance disclosures – Melbourne Health, CSR Ltd.
Research shows that in the corporate world, openness and transparency in reporting is rewarded (market capitalisation). Yet corporates continue to fight it.
Key prerequisites
• Clear roles and responsibilities.
• Constructive relationships and accountabilities.
• Effective governing body.
• Effective monitoring.
• Effective communication.
• Good external reporting.
• Sound risk management practices.
In bringing this article to a close, in my view, the prerequisites for effective governance are:
• establishing clear roles for each of the parties, and ensuring that all parties understand their own roles, and those of the other parties
• constructive relationships and accountabilities based on those roles
• an effective governing body
• effective monitoring arrangements which reflect a balance between the interests of Parliament, Executive oversight and the autonomy of the governing body and/or management
• effective communications
• good external reporting
• sound risk management practices.
Organisations frequently fail when there is:
• lack of sound goals
• inadequate internal control and non-disclosure
• dominance of individuals
• deficiency of values and, ethics
• absence of arms-length approach to some transactions
• lack of action by other directors to scrutinise/challenge the financial information
• poor risk management and poor reporting to the board. “Not to know is bad; not to wish to know is worse”. (West African proverb)
Good corporate governance
The purpose of this article has been to provide my perspective on what constitutes good governance.
Good governance has been the subject of much consideration and public debate in recent times. And for good reason.
The community is entitled to be assured that practices in the public and private sectors are as they should be, in order to maintain confidence.
Where confidence is eroded, governments must act to re-establish confidence in our institutions – hence the Sarbanes/Oxley legislation in the USA, and CLERP 9 here in Australia.
The public sector – as we are all too aware – is not immune from these winds of change and must collectively and individually re-examine its own practice to ensure that community trust is maintained.
Much more guidance is around now:
• PAEC Report on Examination of Corporate Governance Issues in Victoria – Checklist
• WA and Queensland public service guidance
• ANAO better practice guide
• new MOF Directions, effective 1 July 2003
• John Uhrig’s review of corporate governance of Commonwealth statutory authorities and office holders (available soon).
Much of the governance debate has been about the rules – principles … BUT … It’s not just about applying corporate governance principles, it’s also about the PRINCIPLED application of those principles.
2004 Public Sector International Financial Reporting Standards Conference
Towards an Internationally Recognised and Nationally Consistent Public Sector Financial Reporting Framework
A conference on IFRS harmonisation and GFS/GAAP convergence for public sector entities will be held in Canberra over 1 to 3 June 2004. The conference will address IFRS issues relevant to the public sector and will provide information on the new accounting framework.
The conference aims to equip public sector entities with direction and the tools to achieve successful adoption of AAS and IAS standards, the progress of GFS/GAAP convergence, efficient management of reporting systems, operations and staff training programs, and future implications.
Conference topics include:
• IFRS for the public sector – Implementation, implications and issues management
• Technical framework and standards affecting the public sector
• Financial reporting and stakeholder confidence
• Transitioning the change – systems and personnel
• The road ahead – an outlook on IFRS in the public sector.
For further information on this conference, please contact IIR Australia on (02) 9923 5090, fax (02) 9959 4684, email to <info@iir.com.au> or visit <www.iir.com.au/government>.
Further information
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Office Directors and Audit Managers are usually your first point of contact for technical matters. The Accounting and Auditing Policy Group provides technical and policy advice to financial and performance auditors.
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This newsletter is prepared by the Victorian Auditor-General’s Office. Every effort is taken to ensure that the information is accurate. Neither the Office, nor any of its employees, shall be liable on any grounds whatsoever to any party in respect of decisions or actions they may take as a result of using the information contained in this newsletter.
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The information in this newsletter is of a general nature only and is not intended to be relied upon as, or as a substitute for, specific professional advice.
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Further information about any of the issues contained in this newsletter, or about the Victorian Auditor-General’s Office, may be obtained from:
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John Olesky - Manager, Reports and Communications
Victorian Auditor-General’s Office
Level 34, 140 William St
Melbourne Vic. 3000
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Fax: (03) 8601 7010
Email: <john.olesky@audit.vic.gov.au>
Office website: <www.audit.vic.gov.au>
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