Course Notes Flashcards
What does any assurance engagement need? (7)
A responsible party
A practitioner
A user of the report
A subject matter
Criteria
Sufficient appropriate evidence to support the conclusion
A written report containing a conclusion
What is an assurance engagement governed by?
The terms of engagement found in the engagement letter.
What are the two types of assurance?
Reasonable assurance engagement
Limited assurance engagement
What type of opinion is a reasonable assurance engagement?
Positive or negative
Positive opinion
The financial statements show a true and fair view in all material respects.
What type of opinion is a limited assurance engagement?
Positive or negative
Negative opinion
Nothing has come to our attention
What type of evidence is sought for a reasonable assurance?
Sufficient and appropriate
What type of evidence is sought for a limited assurance?
Sufficient and appropriate (less intrusive)
Can absolute assurance be provided to any assurance engagement?
No, it cannot be provided due to audit limitations and the nature of the evidence available.
Name the 6 users of an assurance engagement
Shareholders
Directors
Customers/Suppliers
Lenders/Banks
Employees
Society
What benefits would a shareholder get from an assurance engagement?
(3)
[] Enhances the credibility of the information being reported on
Reliable information to hold management to account
Draws the attention of the user to any deficiencies in the information being reported on
What benefits would a director get from an assurance engagement?
(4)
Reduces the risk of management bias and error in the information being reported on
Deter fraud
Enhanced reliability of information for business decisions
The management letter will provide constructive advice regarding internal controls and risk management leading to improvements in organisational efficiency
What benefits would a customer/supplier get from an assurance engagement?
The financial statements could impact decision to trade with the company. An audit may provide them with the confidence to transact with the company
What benefits would a lender/bank get from an assurance engagement?
(2)
They value having the business scrutinised by another set of professional eyes
The added confidence lenders have may mean it is easier for the company to raise finance assisting in negotiations and allowing the bank to appreciate risk better
What benefits would a employees get from an assurance engagement?
(2)
May provide greater confidence over job security
May provide greater confidence over bonuses payable if linked to profits
What benefits would society get from an assurance engagement?
(2)
They ensure that high-quality, reliable information circulates in the market improving the reputation of the company
It provides additional assurance to third parties such as taxation authorities concerning the reliability of the financial statements
What are the overall objectives of the auditor in conducting an audit of financial statements?
To obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error
To express an opinion on whether the financial statements are prepared, in all material respects, in accordance with an applicable financial reporting framework
What are the criteria to need an audit and how many do you need?
More than 50 employees
Turnover over £10.2 mil
Gross assets over £5.1 mil
Two or more to need an audit
Irrespective of size, how can subsidiaries be exempt from audit?
If the parent company guarantees the liabilities of the subsidiary.
What can cause a company to need an audit even if they do not meet two of the criteria?
The articles of association require one
Shareholders who own 10% or more ask for one
Public companies
The company is involved in insurance or banking
What types of work are performed on an audit engagement?
(8)
Analytical procedures
Enquiry
Inspection
Observation
Recalculation
Re-performance
External confirmation
Written representations
What assurance level is given in an audit?
Reasonable assurance
What assurance level is given in other assurance engagements?
Limited assurance
What does PFI stand for?
Prospective Financial Information
What work would be completed on a PFI assurance engagement?
Assessment of assumptions
Re-computation
Written representations
What work would be completed on an assurance engagement that is not an audit but reviewing past data?
Enquiry
Analytical procedures
Written representations
is it managements responsibility to manage the company? Does the auditor play any part?
Yes it is management’s responsibility.
No the auditor should not do anything to manage the company but should understand the the risks facing the business and understand how this affects their approach to the audit.
Under the Companies Act 2006, what are the responsibilities of the Directors?
(4)
Safeguard the assets
Maintain books and records
Prepare the financial statements
Give the FS to shareholders at AGM
File the financial statements at Companies House
In the Directors’ responsibilities under the
Companies Act 2006, what are the two parts to safeguarding the assets?
– Prevent and detect fraud and error
– Ensure compliance with laws and regulations
In the Directors’ responsibilities under the
Companies Act 2006, what are the four parts to preparing the financial statements?
– Correct basis
– Adequate accounting policies
– Appropriate judgements
– Comply with accounting standards
The responsibility of the external provider of assurance services is determined by:
The requirements of any legislation or regulation under which the engagement is conducted,
The terms of engagement for the assignment, which will specify the services to be provided
Ethical standards
Quality management standards
In the case of an audit of annual accounts under the Companies Act 2006, it is the external auditor’s
responsibility to:
Form an independent opinion on the truth and fairness of the annual accounts
Confirm that the annual accounts have been properly prepared in accordance with the Companies Act 2006
State in their auditor’s report whether in the opinion the information given in the directors’ report is consistent with the annual accounts.
To achieve the objective of an audit the auditor must:
(3)
The audit is planned properly
Sufficient and appropriate audit evidence is gathered
The evidence is properly reviewed and valid conclusions drawn
In accordance with the law and ethical standards the auditor must maintain…
Independence from the client
Does the appointment as an auditor make the auditor responsible for
The design and operation of the accounting systems
No
Does the appointment as an auditor make the auditor responsible for
The maintenance of the accounting records.
No
Does the appointment as an auditor make the auditor responsible for
The preparation of the financial statements.
No the responsibility stays with management
Does the appointment as an auditor make the auditor responsible for
The identification of every error and deficiency in the accounts and the accounting records
No
Does the appointment as an auditor make the auditor responsible for the prevention of fraud in a company
No
Does the appointment as an auditor make the auditor responsible for the detection of immaterial fraud in the company
No but should spot material fraud if the accounts are materially correct.
Does the appointment as an auditor make the auditor responsible for ensuring that the company has complied with relevant laws and regulations
No but if they haven’t the audit should be adjusted accordingly.
CA 2006 grants auditors certain rights to enable them to fulfil their responsibilities.
Name three
[] The right of access at all times to the company’s books and accounts
The right to obtain any information necessary for the audit from any employee of the company
The right to attend any general meeting of the company
Define error
An unintentional misstatement in financial statements, including the omission of an amount or a disclosure.
Define fraud
The intentional act to deceive or obtain an unjust or illegal advantage.
According to ISA 240 (UK) what are the two types of misstatement which can arise from fraud?
Misstatements arising from fraudulent financial reporting
Misstatements arising from misappropriation of assets
Who has the primary responsibility regarding fraud?
Management
What are the auditors responsibilities in relation to fraud?
(3)
The auditor’s responsibility is to:
Obtain reasonable assurance (not complete assurance) that the financial statements are free from material misstatement, whether caused by fraud or error.
Assess the risk of material misstatement
Where fraud or error is discovered - report to the appropriate party
Auditors should also carry out a discussion of the susceptibility of the entity’s financial statements to fraud. This will usually include a consideration of:
The unique position of management to commit fraud
The circumstances that could indicate earnings management
The known internal and external factors that could be an incentive to fraud being carried out
Any unusual or unexplained changes in behaviour/lifestyle of management or employees
Any allegations of fraud that have been made
If the auditors identify misstatements which might indicate that fraud has taken place, they should
consider the implications of this for other aspects of the audit, particularly management representations which may not be trustworthy if fraud is indicated.
Identify characteristics of journals that heighten the risk of fraud (see ISA 240 A43)
Relate to seldom used accounts or suspense accounts
Processed by individuals that do not usually do journals
Unusual in timing
Contain no description or vague references
Are made outside of office hours
Lack commercial rationale
Involve related parties
ISA 240 requires that the auditors to make the appropriate reports if fraud is found or suspected, who must they dislcose to? (3)
Those charged with governance - report to the appropriate level ie audit committee
Shareholders - Where fraud or error causes the financial statements do not give a true and fair view the auditors’ report should be modified
Third parties - The auditor determines the responsibility to report suspicion outside the entity
What are the two categories of laws and regulations that auditors are interested in?
Those with a direct impact on the financial statements, for example, the Companies Act
Those which provide a legal framework within which the company operates
What are the three areas of law that affect all businesses?
Employment law
Social security law
Health and safety law
Who has primary responsibility to ensure compliance
with laws and regulations?
Management
What is the auditor’s responsibility regarding compliance with laws and regulations? (4)
Auditor should:
Make inquiries of management
Inspect correspondence with relevant licensing or regulatory bodies
Obtain written representations that management has disclosed all known instances of actual or possible non-compliance with laws and regulations.
Report issues of non-compliance
Do the auditors have to report non-compliance with laws and regs to those charged with governance?
Any non-compliance with laws and regulations should be reported to the appropriate level ie the Audit Committee
Do the auditors have to report non-compliance with laws and regulations with shareholders?
Only if non-compliance causes the financial statements to not give a true and fair view
Do the auditors have to report non-compliance with laws and regulations with third parties?
The auditor shall determine whether the auditor has a responsibility to report the identified or suspected noncompliance to parties outside the entity.
The Act regards a payment as bribery if
it leads to ‘improper performance’ by another person
What is the legal test of what is and is not a proper payment?
what a reasonable person in the UK would expect of a person performing the relevant function or activity’.
Can Commercial organisations be penalised for
failing to prevent bribery by persons associated
with that organisation, including employees,
agents and subsidiaries?
Yes
The Bribery Act 2010 introduces severe
penalties for individuals and organisations that
engage in bribery. The offences relating to
individuals are:
Offering a bribe
Accepting a bribe
Bribing a foreign public official
What do auditors need to do in relation to bribery as part of an audit?
Auditors will need to analyse the risk to a client of non-compliance and will need to ensure that adequate procedures are in place. Auditors may also have a duty to report suspicions of bribery to the National Crime Agency (NCA) under the Proceeds of Crime Act 2002 (POCA).
As commercial organisations in their own right, audit firms will themselves need to have bribery prevention policies in place. The government suggests that the bribery prevention policies should focus on six principles:
[] Proportionate procedures designed to mitigate risks and prevent unethical conduct
Top-level commitment that creates a culture in which bribery is unacceptable
Risk assessment that is periodic, informed and documented
Due diligence procedures that take a proportionate and risk based approach
Communication (including training) to ensure that bribery prevention is embedded and understood throughout the organisation
Monitoring and review, and making improvements to procedures where necessary
What is the risk with related party transactions?
They may not be the same as in an arm’s length transaction with an independent third party
What is the approach adopted in the financial reporting standards in relation to related parties?
To disclose the relevant amounts and relationships so that the readers of the financial statements can decide for themselves whether such transactions have led to a manipulation of the financial statements.
ISA 550 (UK) Related Parties details the audit work required in respect of related party transactions.
The work can be split into the three main stages of the audit:
The planning stage
The detailed testing stage
The review stage
What does the auditor need to consider with related party transactions at the planning stage?
The auditor needs to consider the risk of there being undisclosed material related party transactions. However materiality here is based on what is material to the transacting parties which may be smaller than the materiality of the company being audited.
ISA 550 sets out specific procedures that should be carried out at the detailed testing stage of an audit in relation to related party transactions. What 4 things are they?
Enquire to the directors of the existence of related parties
Reviewing minutes of board meetings
Reviewing records for large or unusual transactions or balances
Reviewing investments in other companies
What should be done at the reviewing stage of an audit in relation to related party transactions?
Written representations should always be requested from directors, who are in the best position to know the identities of related parties. The auditor then reviews the accounts, together with the audit evidence available, in order to reach a conclusion on the appropriate audit opinion.
What is money laundering?
Money laundering is the using, acquiring, retaining, controlling, concealing, disguising, converting and transferring the proceeds of crime and criminal property.
The purpose of money laundering is to:
Disguise the origins of funds derived from illicit sources, and
Enable illicit funds to be used by those who control them
Criminal property includes
any gain from non-compliance with laws and regulations such as tax evasion, selling illegal substances and even the saved cost of non-compliance with laws and regulations eg health and safety!
What are the firms 4 responsibilities in relation to money laundering?
Appoint a Money Laundering Nominated Officer - responsible for evaluating interal reports and reporting them to the NCA by a SAR.
Client Due Diligence - for new and existing clients
Training - staff on how to recognise and what to do
Record keeping - records kept for 5 years after the engagement has ended
What are the auditors 3 responsibilities in relation to money laundering?
Comply with the Proceeds of Crime Act
Failure to report is an offence, if an accountant has grounds for suspicion (no de-minimis) that money laundering is taking place at a client, that accountant must report it to the MLNO. This overrides the duty of confidentiality.
Avoid tipping off – this is also an offence.
The penalties for non-compliance by accountants are potentially quite severe – for some offences a
jail term of how many years is possible?
14 years
What is the expectations gap?
This so-called ‘gap’ is between the expectations of users of assurance reports, particularly of auditor’s
reports, and the firm’s legal responsibilities.
Various steps have been taken to try to reduce the expectations gap. What are they?
Expanding the auditors report
Adapting the engagement letter to state directors responsibilities
How has the auditors report been expanded to narrow the expectations gap?
Set out responsibilities of auditors and directors
Explain how an audit is conducted:
– On a test basis (which implies sampling)
– By assessing significant estimates and judgements
– So as to give reasonable assurance on the financial statements
– So as to detect material misstatements – in relation to fraud, error or any other irregularity
What is the need for professional standards?
The reliability of the financial statements does not vary from company to company so easy comparisons can be made.
IFAC was set up by the professional bodies representing accountants from…
Around the world
Members of the IFAC from the UK are:
ACCA (Certified accountants)
CIMA (Management accountants)
CIPFA (Public sector accountants)
ICAEW
ICAI (Ireland)
ICAS (Scotland)
ISAs do not override the local regulations governing the audit of financial or other information in a particular country.
True or false
True
In exceptional circumstances, an auditor may judge it necessary to depart from an ISA. Why would they do this?
in order to more effectively achieve the
objective of an audit. When such a situation arises, the auditor
should be prepared to justify the departure.
The FRC was established to promote
good financial reporting in the UK through the setting of accounting standards and review of published financial statements.
In the FRC, the codes and standards committee are responsible for?
actuarial policy,
audit and assurance,
corporate governance, and accounting and reporting policy
In the FRC, the conduct committee are responsible for?
audit quality review,
corporate reporting review,
professional discipline,
professional oversight, and
supervisory inquiries
How does the FRC promote improvements in audit quality?
Issuing audit standards (ISAs) which describe auditor responsibilities and approaches
Issuing ethical standards, which help ensure objectivity
Issuing practice notes such as on professional scepticism
The FRC monitors compliance with ISAs and ES via its Audit Quality Review Team who visits audit firms
The FRC oversees matters of misconduct and has the power to take disciplinary action against auditors and firms
The FRC also oversees the UK Code of Corporate Governance part of which outlines responsibilities of the Audit Committee to oversee the external audit function
Define Professional scepticism
‘An attitude that includes a questioning mind, being alert to conditions which may indicate possible misstatement due to error or fraud, and a critical assessment of audit evidence.’
ISA 200 requires auditors to plan and perform audits with professional scepticism because: (4)
Management may deliberately conceal fraud
Management may be biased in the creation of the financial statements
Evidence may not be reliable
Financial statements contain complex judgemental issues
Professional scepticism ensures: (4)
Sufficient enquiry and challenge to management
The scrutiny of documents and responses for reliability
Contradictory evidence or conditions indicative of fraud followed up
Changes in accounting policies scrutinised
What is big data?
Big data is a broad term for data sets that are large or complex.
What other technological developments may have implications for accounting and auditing:
Robotic Process Automation
AI & Cognitive Computing
Blockchain
What was the kingsman review?
The Kingman review resulted in the wake of some high profile corporate collapses of Carillion and BHS – where some stated that the audit was a colossal waste of time and money
providing only false assurance. The Kingman review was published in December 2018 and recommended the abolition of the FRC replacing it with a new Audit, Reporting and Governance Authority (ARGA)
It is anticipated that the new
ARGA will:
Directly regulate the biggest audit firms
Impose greater sanctions in cases of corporate failure
Require rapid explanations from companies
Publish reports about company’s conduct and management
What was the Competitions and Market
Authority’s review (CMA)
The CMA made some recommendations having reviewed the state of the audit market. The key recommendations were:
Greater oversight of audit committees and the role they play to ensure audit quality
A split between the Big Four’s audit and non-audit businesses to ensure focus on quality
A five-year review of the state of the industry
Mandatory joint audits to increase the ability of smaller firms to compete with the Big-Four
What was the brydon report for?
This report called for urgent reform to rebuild public trust in the audit.
Key recommendations:
Separation of the audit profession from the accounting profession
A redefinition of audit and its purpose
Introduction of the word suspicion into qualities of audit
To increase audit responsibilities beyond the financial statements
[] Greater engagement with shareholders
Change the language of the opinion given
Greater clarity around the role of the audit committee
Improved auditor transparency
Which companies are required to make disclosures related to climate-related issues
The largest ones
What are the 5 ethical principles?
Integrity
Objectivity
Professional competence and due care
Confidentiality
Professional behaviour
Define integrity
A professional accountant should be straight forward and honest.
Define objectivity
A professional accountant should not allow bias, conflict of interest or undue influence of others to provide professional or business judgements
Define professional competence and due care
A professional accountant has a continuing duty to maintain professional knowledge and skill at the level required to ensure that a client or employer receives competent professional service based on current developments in practice, legislation, and techniques. A professional accountant should act diligently and in accordance with applicable technical and professional standards when providing professional services
Define confidentiality
A professional accountant should respect the confidentiality of information acquired as a result of professional and business relationships and should not disclose any such information to third parties without proper and specific authority unless there is a legal or professional right or duty to disclose.
Define professional behaviour
A professional accountant should comply with relevant laws and regulations and should avoid any action that discredits the profession
What are the 6 ethical threats?
Self interest
Self review
Management
Advocacy
Familiarity
Intimidation
What are the general safeguards to threats?
Training
ICAEW offers support
Quality management systems in place
3 examples of quality management systems
Planning, supervision and review procedures
Hot and cold file reviews
Regulatory inspections
What are the overarching principles and supporting ethical provisions?
Integrity
Objectivity
Independence
What is the control environment?
The whole culture and working practices of the firm which should lead to ethical behaviour
Firms should:
Create ethical policies
Monitor compliance
Have reporting systems to ensure breaches are communicated to the engagement partner
Evaluate the implications of identified possible or potential breaches
What does the engagement team do?
It sets out requirements for partners and staff to report:
Family and other personal relationships
Financial interests in an entity audited by the firm
Decisions to join an audited entity
As these might be perceived as casting doubts about the firm’s independence.
What is the role of the ethics partner?
Section 1 requires all firms except the very smallest to appoint an ethics partner, who will be a senior partner with a good deal of authority within the firm, and who will be available for consultation on ethical matters
What is the engagement partners’ role?
Responsible for documenting and reaching a conclusion on the firm’s ethical compliance on a particular audit and communicating on a timely basis any issue that impacts the firms’ objectivity to those charged with governance.
What is the independent partners role?
For listed clients, the firm’s compliance with ethical standards should be reviewed by an independent partner.
What is the other auditors role?
Where other auditors are involved with the engagement, the firm has to be satisfied that they too comply with the ethics rules.
Who cannot have financial interests in a client?
The parties listed below are not allowed to own a direct financial interest or an indirect material financial interest in an audited entity:
The audit firm
Any partner in the audit firm
Any person in a position to influence the conduct and outcome of the engagement (eg, a member of the engagement team)
A person closely associated with any of the above
An audit firm or member of the engagement team (inc immediate family) should not enter into any loan or guarantee arrangement with an audited entity that is not a bank or similar institution.
Describe/explain close business relationships
For audited entities, there should be no close business relationships other than that of the audit engagement except for the purchase of goods on:
In ordinary course of business
On an arms-length basis
Not material to either party
Inconsequential in the view of an objective, reasonable and informed third party
Describe/explain employment with assurance firm from client
Individuals who have been a director or officer of the client, or an employee in a position to exert direct and significant influence over the subject matter information of the assurance engagement in the period under review or the previous two years, should not be assigned to a position in which he or she is able to influence the conduct and outcome of the audit for two years following the date of leaving the audited entity.
Describe/explain employment with assurance client
When a partner leaves the firm and is appointed as a director or to a key management position with an audited entity, having acted as audit engagement or engagement quality reviewer/key partner in relation to that audit at any time in the previous two years:
The firm shall resign as auditors
The auditors shall not reaccept appointment until two years have elapsed since that partner’s involvement in the audit or the former partner leaves the audit client, if earlier.
When any other former member of an engagement team joins an audit client as director/key management within two years of being involved with the audit, the firm shall consider whether the composition of the audit team is appropriate.
The audit firm, a partner or employee of an audit firm shall not perform a role as an officer or member of the board of an audited entity
Describe/explain family and personal relationships
When an immediate family member of a member of the audit team is a director, an officer or an employee of the audited entity in a position to exert direct and significant influence over the subject matter information of the audit engagement, the individual should be removed from the audit team.
Describe long association for listed entities
The following partner rotation rules exist:
Five years – engagement partner for listed clients, can’t be a partner for a further 5 years
Can be extended by 2 years if necessary to safeguard audit quality ie in times of significant change (must be disclosed to shareholders)
Seven years – engagement quality reviewers, key partners involved in the audit and senior
staff for listed clients can’t be a quality reviewer for a further 5 years
An audit tender should be carried out every 10 years and there should be a mandatory rotation of audit firm every 20 years
Describe long association for non-listed entities
Regular rotation is not mandatory, but after ten years the firm must consider if ‘a reasonable and informed 3rd party would question the partners objectivity’ – if so safeguards should be implemented such as involving additional partners and quality reviews.
Can an audit be undertaken on a contingent fee basis?
No
What are the rules around high percentage of fees?
Where total fees for both audit and non-audit services will regularly exceed 15% (10% for a listed entity) the firm must not act as auditor.
Where total fees (audit and non-audit services) from an audited entity are expected to regularly exceed 10% of the annual fee income of the audit firm (5% in the case of a listed company) the audit engagement partners should disclose that fact to the ethics partner and those charged with governance of the audited entity and consider whether appropriate safeguards should be applied to reduce the threat to independence.
Where non audit services are permitted, they are limited to no more than 70% of the audit fee, calculated on a rolling three-year basis.
What is lowballing?
What must still be ensured?
Where the fee quoted is significantly lower than would have been charged by the predecessor firm the engagement partner must be satisfied that:
The appropriate staff and time are spent on the engagement irrespective of the fee
All applicable assurance standards, guidelines and quality management procedures have been complied with
Fee has not been influenced by the provision of non-audit services
What is considered gifts and hospitality?
Unless the value of a gift or hospitality is clearly insignificant, a firm or a member of an engagement team should not accept them. (Reasonable and informed 3rd party test)
Describe evaluation policies within the firm?
There should be a firm’s policy on the extent to which gifts, hospitality etc may be accepted from audited entities.
Audit staff should not be assessed, or have their performance appraisal or their pay related to their ability to cross sell the firm’s products.
For listed clients an external independent quality review (hot review) MUST be undertaken.
The firm should resign as auditor where there is actual or potential litigation between the firm and the audited entity.
What is a PIE?
Public interest entity
Examples of PIE
An issuer whose transferable securities are admitted to trading on a UK regulated market (ie a listed company)
A credit institution (eg a bank)
A person who would be an insurance undertaking
Can you complete audit related services for a PIE?
Yes, other assurance engagements are permitted as they too require the auditor to be objective. The auditor may still need to be mindful of total fees earned and their reliance on the client.
Can internal audit be completed as an additional service for a PIE?
Provision of internal audit is prohibited.
Can valuation and actuarial valuation be completed as an additional service for a PIE?
No - Valuation services are prohibited where they require significant judgement and are material to the financial statements.
Can IT services be provided to a PIE audit client?
The firm should not undertake work on IT systems which would be important to any significant part of the accounting system and production of the financial statements.
Can tax services be provided to a PIE audit client?
No - The firm must not prepare, calculate or provide tax advice including deferred tax.
Can transaction related services be provided to a PIE audit client?
No - Transaction related services are ‘one-off’ engagements such as due diligence work. Such work often involves undertaking a management role and is prohibited for listed companies
Can restructuring services be provided to a PIE audit client?
Limitations on advice relating to an entity in distress.
Can recruitment and renumeration advice services be provided to a PIE audit client?
The firm is prohibited from providing recruitment services of any director or employee where this would mean taking on responsibility for the appointment. The firm shall not provide advice on measurement criteria in relation to any director or employee’s remuneration package
Can accounting and payroll services be provided to a PIE audit client?
Not it is prohibited
Can audit related services be provided to a non-PIE?
Similar considerations apply as PIEs – this decision must be taken in context of the circumstances of the client and the audit firm in the same way.
Can internal audit services be provided to non-PIE audit clients?
Provision of internal audit is prohibited.
Can valuation and actuarial valuation be provided to a non-PIE audit client?
Valuation services are prohibited where they require significant judgement and are material to the financial statements
Can IT services be provided to non-PIE audit clients?
The firm should not undertake work on IT systems which would be important to any significant part of the accounting system and production of the financial statements.