We note that the primary purpose of the FRC’s current consultation is to gain a good understanding of how the Turnbull guidance has been implemented in practice and where improvements can be made.
One aim of the original guidance was to make Boards of Directors more aware of the risks facing their businesses so that they could not only be identified, but more importantly be managed with the appropriate controls. There was an objective that the concepts of risks and internal controls would become inbuilt into the normal management processes.
To an extent therefore the evidence gathering phase of the Turnbull Review Group will be dependent on specific and possibly confidential inputs directly from companies that have applied the guidance. As a professional association we can comment from an external perspective and based on inputs received from our members, but with the caveat that in some respects we may be at one stage removed from the direct process.
In compiling this response input has been received from individuals with company specific experience and from the ACT’s Technical Committee comprised of members operating in non financial corporates, financial institutions and in advisory services.
