Order On Auditing Financial Enterprises And Financial Groups

Original Language Title: Bekendtgørelse om revisionens gennemførelse i finansielle virksomheder m.v. samt finansielle koncerner

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Read the untranslated law here: https://www.retsinformation.dk/Forms/R0710.aspx?id=122447

Overview (table of contents)
Chapter 1 Scope
Chapter 2 The external audit
Chapter 3 The internal audit
Chapter 4 The audit report
Chapter 5 Common Provisions
Chapter 6 Special provisions for banks
Chapter 7 Special provisions for mortgage
Chapter 8 Special provisions for insurance
Chapter 9 Special provisions for investment companies and investment management companies
Chapter 10 Special provisions for investment funds and special funds and restricted associations and hedge funds
Chapter 11 Special provisions for securities dealers
Chapter 12 Penalties and entry into force
Appendix 1
Appendix 2
Appendix 3
The full text
Order on auditing financial enterprises and financial groups 1)
Pursuant to § 199 paragraph. 11, § 373, paragraph. 4 of the Act on Financial Business Act. Act no. 897 of 4 September 2008, § 71 paragraph. 10, § 113, § 114 f and § 132 paragraph. 3 of the Act on investment funds and special funds and other collective investment schemes, etc., see. Legislative Decree no. 929 of 18 September 2008, § 5, paragraph. 2 and § 14 paragraph. 2 of the Act on a Ship Finance Institute, see. Act no. 1376 of 10 December 2007, shall:
Chapter 1
scope
§ 1. This Order shall apply to financial companies, see. § 5, paragraph. 1 pt. 1 of the Financial Business Act, and investment funds, special funds, restricted associations and hedge funds, see. § 4, paragraph. 1, § 5, paragraph. 1, § 111 and § 114 a paragraph. 1 and paragraph. 2 of the Act on investment funds and special funds and other collective investment schemes, etc. and Danish Ship Finance A / S.
PCS. 2. The notice shall also apply to both groups as a whole,. § 5, paragraph. 1, no. 9, in the Financial Business Act as the individual companies within the groups where the parent company is a financial undertaking or a financial holding company, see. § 5, paragraph. 1 pt. 10 of the Financial Business Act.
General conditions
§ 2. Statements and information under this Order shall, if they submitted without qualifications, reproduced verbatim. See Appendix 1. statements and information that can not be delivered verbatim, be discussed and listed separately.
PCS. 2. Confirmations under this Order shall be reproduced verbatim. See Appendix 1. If the confirmations can not be reproduced verbatim, they discussed and listed separately.
PCS. 3. Statements, information and confirmations delivered with additional information to be discussed and listed separately.
Chapter 2
The external audit
§ 3. The external auditors shall audit the annual report including the consolidated financial statements in accordance with generally accepted auditing standards and check if these are presented in accordance with legislation and any other provisions accounting requirements.
The external auditors' audit
§ 4. For the purpose of the board of companies based in Denmark, the external auditors keep an audit. There must Minutes accounted for in the year audit, which can form the basis for auditing partial conclusions. The protocol must be presented at each board meeting, and all entries must be signed by the Board of Directors and the Chief Auditor.
PCS. 2. In the minutes of the annual report must account for the audit and the conclusion of this. In a separate section of the audit regarding the annual report, the external auditors summarize all the comments, the audit has given rise to advance to the board. The summary should contain a status of the observations put forward on that financial year, and a status of the observations appearing as pending in the minutes of the previous annual report provided. Annex 2.
PCS. 3. The external audit shall be in a separate section of the audit regarding the annual report disclose the performance of any assistance- or advisory assignments.

PCS. 4. The external audit shall be linked to information on any assistance- or provide advice, at least in the minutes of the annual report, confirm that the prohibition of self-audit in § 24 paragraph. 4, 1st clause. Act on Approved Auditors and Audit Firms have been observed, including the auditor or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about or involved in preparing the annual report or any other document relating. The confirmation must be submitted even if there have been performed assistance- or advisory assignments.
PCS. 5. The external audit shall be in a separate section of the audit regarding the annual report disclose the uncorrected errors. The information must be provided per. errors including the amount and effect of accounting items. Uncorrected errors below the minimum limit can be omitted from information about the used triviality and the net effect of the total uncorrected error de minimis. If all errors are corrected, or that no error is found, this shall be mentioned.
information
§ 5. It should be in the minutes of its Annual Report on



1) the financial undertaking's guidelines according to § 77 paragraph. 4, in the Financial Business Act or the association's guidelines according to § 34 paragraph. 4 of the Act on investment funds and special funds and other collective investment schemes, etc. are adequate and have functioned appropriately referred. § 77 paragraph. 5, of the Financial Business Act and § 34 paragraph. 5 of the Act on investment funds and special funds and other collective investment schemes, etc.
2) control according to § 77 paragraph. 5, of the Financial Business Act and § 34 paragraph. 5 of the Act on investment funds and special funds and other collective investment schemes, etc. have given rise to comments
3) established procedures to ensure compliance with the provision in § 182 of the Financial Business Act, and
4) having recorded material misstatements in connection with the examination of transactions between the company and the companies covered by § 2 of the Ordinance on intercompany transactions, see. § 6, no. 3, and provide a detailed description of the transactions of substantial or extraordinary.


PCS. 2. In companies that have internal audit, it must be in the audit regarding the annual report disclosed whether



1) the according revision agreement agreed tasks are performed, as well as on the internal audit function satisfactorily, including the external audit has not been aware of conditions that, individually or together compromise the internal audit function independent of the daily management, and | || 2) the external auditors agree with the contents of all the internal audit protocol inputs regarding the financial year, and if this is not the case where the disagreement lies.


PCS. 3. In the minutes of the Annual Report for the parent companies to be significant comments on the accounting and auditing matters in the individual subsidiaries mentioned.
PCS. 4. A copy of the minutes of the Annual Report The Company shall be submitted to the FSA at the same time a copy of the board of directors approved the annual report and the Board of Directors approved the consolidated financial statements. Similarly, by a copy of the minutes of subsidiaries based in Denmark.
statements
§ 6. In the minutes of the annual report shall make a declaration about the following:



1) Whether the company's administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this context, the external auditor also declare whether



a) the overall system, data and reliability and works reassuring
b) that the company checks the company's portfolio of securities and the like
c) bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and
d) the external auditors are aware of conditions that are contrary to the requirements of legislation for financial companies and associations.



2) Whether the Council-allocated exposures and collateral received from board members or directors and companies where these are executives or directors are granted under the company's ordinary business terms and on market terms, see. § 78 paragraph. 2, in the Financial Business Act.
3) Whether the financial undertaking has exposures with enterprises covered by § 80 paragraph. 1 and 2 of the Act on Financial Business Act. § 80 paragraph. 8, 2nd paragraph., In the Financial Business Act.


Other provisions
§ 7. § 4, paragraph. 4, § 5, paragraph. 1 and § 6, no. 1, point c and d, and no. 2-3, does not apply to audit reports of subsidiaries that are not financial companies, see. § 1. 1.
§ 8. If the company has an internal audit that meets the requirements of Chapter 3, the external audit agreement with the chief that statements in accordance with § 4, paragraph. 2, 2nd and 3rd clauses., § 4, paragraph. 5, § 5, paragraph. 1 pt. 3 and 4, § 6, no. 1, §§ 23-24 and 26, § 28, no. 1, §§ 30-32 and 37 solely from the internal audit protocol. This agreement should appear on the agreement, see. § 15.
Chapter 3
The internal audit
§ 9. The Board may decide to establish an internal audit according. However paragraph. 3. If there is established an internal audit, the Board of Directors at least once a year to discuss the need to create an internal audit taking into account the complexity of the company, including whether the company outsoucer and insourcer activities. The Board's decision must appear in the Board's minutes.
PCS. 2. If a board under paragraph. 1 provides for the establishment of an internal audit, the provisions concerning the internal audit application.
PCS. 3. Undertakings in the last two financial years at the balance sheet date, on average, had 125 or more employees, we must establish an internal audit.
PCS. 4. For groups paragraphs. 1 and 3, mutatis mutandis.
PCS. 5. Paragraphs. 3-4 does not apply to investment funds, special funds, restricted associations, hedge funds and Danish Ship Finance A / S.
§ 10. The Internal Audit is headed by a chief auditor. The appointment and dismissal of the chief can only be made by the Board. The appointment and dismissal of the Chief Auditor can be made for the group as a whole.
PCS. 2. The chief internal auditor must have a theoretical training equivalent to that required to be chartered or registered accountant.
PCS. 3. Revision command shall, recruitment have participated in the practical audit work for at least three years within the last 5 years.
PCS. 4. Financial Supervisory Authority may in special cases grant exemptions from the requirements of paragraphs. 2-3.
PCS. 5. The Board may appoint one or more deputy chief internal auditors.
PCS. 6. The Board may appoint a deputy chief auditor as a deputy to the chief.
PCS. 7. The provisions of paragraphs. 1-4, § 11 paragraph. 1-3 and § 12 on the chief shall apply mutatis mutandis to the Deputy audit executives, including deputies.
§ 11. When an audit manager joins, must be reported to FSA within 1 month after accession.
PCS. 2. The Board shall report to the Financial Supervisory Authority on the recruitment of the Chief Auditor, see. Paragraph. 1, declare that the Chief Auditor meets the requirements of § 10 paragraph. 2 and 3.
PCS. 3. When a chief auditor resigns or is dismissed, the board and the chief later than 1 month after the resignation each send a report to the FSA on the basis thereof.
PCS. 4. In the context of the paragraph. 2 declaration required by the Board must state whether the chief endorse the annual report pursuant to § 19
PCS. 5. The Board shall change the decision on whether the chief endorse the annual report, inform the FSA thereof.
PCS. 6. The board shall decision to disband the internal audit inform the FSA thereof.
§ 12. The chief internal auditor should have access to all information which it deems necessary for conducting the audit, including board protocol.
PCS. 2. The chief internal auditor and the employees of the Internal Audit shall not engage in other work in the undertaking or group than auditing.
PCS. 3. Internal audit should not take on tasks when there are circumstances that are apt to arouse doubts in an informed third party for the internal audit independence.

§ 13. Audit and deputy chief internal auditors may, in accordance. § 77 paragraph. 10 of the Financial Business Act, does not have financial interests in the company or group to which they are employed.
§ 14. companies and groups with an internal audit, there must be a function description approved by the Board. The job description can be prepared for the group as a whole and accepted by the individual Group companies boards. The job description should at least include provisions on



1) the internal audit ordinary powers, responsibilities and tasks
2) qualifications,
3) how and to what extent the chief and employees of the Internal Audit ensure ongoing training,
4) the appointment and dismissal of employees of the internal audit shall be completed or approved by the chief and staff training must be approved by the Chief Auditor,
5) the internal audit budget and to approval by the board, as evidenced by a Board Minutes and
6) information on agreements between the company management and the internal auditors about performing specific audit tasks. Once Tasks and work of a temporary need only to follow from the internal audit protocol.


PCS. 2. The internal audit shall only take on tasks, see. Paragraph. 1 pt. 1, as it has sufficient competence to perform.
PCS. 3. The provisions of paragraph. 1, no. 6, mentioned tasks must not cause the chief internal auditor in a situation where he agrees or provides information about facts or documents which the chief or employees of the Internal Audit has prepared the basis.
§ 15. companies and groups with an internal audit, the audit work is performed in accordance with generally accepted auditing standards and according to an audit agreement between the external auditor and audit manager. The audit agreement can be drawn up for the group as a whole. The audit agreement must contain



1) a general description of the audit tasks to be performed and which of these respective responsibilities of the external audit and internal audit,
2) guidelines for cooperation between the external auditors and the internal audit, including the work of the external auditors must perform in connection with the control of the internal audit work, and
3) a description of how and to what extent the exchange of information between the internal and external auditors on the audit performed.


PCS. 2. If the chief endorse the annual report provided. § 11 paragraph. 4 and § 19 paragraph. 2, must be referenced in the audit agreement that the Chief Auditor participate in the audit of material and risky areas. With participation means that the chief of these areas carry out part of the work in companies where the chief should not issue statements on the annual report alone would be performed by the external auditors.
§ 16. In companies that have an audit manager must also be the chief auditor of all the companies covered by § 1. 2, i.e. whether there is a financial services company or not.
PCS. 2 pcs. 1 shall not apply in cases where the company operated temporarily for liquidation of prior commitments or with a view to restructuring of businesses.
The internal audit protocol
§ 17. For the purpose of the board of companies based in Denmark, the internal auditors keep an audit. There must Minutes accounted for in the year audit, which can form the basis for auditing partial conclusions. The protocol must be presented at each board meeting, and all entries must be signed by the entire board.
PCS. 2. chief internal auditor shall submit the internal audit årsprotokollat, audit plan and budget for the internal audit of the / the relevant board meetings.

PCS. 3. The internal audit protocol regarding the annual report must account for the audit, including how the internal audit participated in the audit of material and risky areas, as well as the conclusion of this. In a separate section of the audit regarding the annual report, the internal auditors summarize all the comments, the audit has given rise to advance to the board. The summary must include a status of the observations put forward relating to the year and a status of the observations appearing as pending in the minutes of the previous annual report provided. Annex 2.
PCS. 4. The chief internal auditor must at least in the minutes of the Annual Report in a separate section confirm that the chief did not come into a situation where he agrees or provides information about facts or documents which the chief or employees of the Internal Audit has prepared the basis pursuant . § 14 paragraph. 3.
PCS. 5. In the minutes of the annual report shall indicate whether the internal auditors have received all the information requested.
PCS. 6. If there will be no protocol regarding the annual report should be submitted at least one minute per year of which paragraph. 3-5 must appear.
PCS. 7. § 5, paragraph. 3 and 4 and § 7 shall apply correspondingly to the internal audit protocol regarding the annual report.
Chapter 4
The audit report
§ 18. The external auditors' report on the annual report, including the consolidated financial statements and the annual report for subsidiaries shall be, made in accordance with the Act on Approved Auditors and Audit Firms, and the regulations issued thereunder.
PCS. 2. The requirement for endorsement of subsidiaries' annual reports applies only if the financial undertaking's external auditors conducted the audit.
§ 19. The chief internal auditor shall submit a report on the annual report, including the consolidated financial statements and annual report for subsidiaries based in Denmark, if selected according to § 11 paragraph. 4 referred to. However, § 16 paragraph. 2.
PCS. 2. Audit Manager's endorsement means that the internal audit was conducted in accordance with the audit agreement, see. § 15.
PCS. 3. The endorsement must include a brief description of the audit, including the internal audit participated in the audit of material and risky areas, as well as the conclusion of this. It should be disclosed separately, if the review includes other than the annual report. Any reservations or additional information must clearly state endorsement.
Chapter 5
Joint provisions
§ 20. A financial undertaking or a company within the same group shall not grant commitment or receive collateral from the external audit, the chief or deputy chief internal auditor. This does not apply to loans granted by a life insurance company within the repurchase of one of the life insurance company issued insurance policy.
§ 21. If the external auditors or the internal audit must assume that a financial institution does not meet or in the foreseeable future will not be able to meet the requirements for solvency set. §§ 124-126, in the Financial Business Act, or capital requirements in § 4, paragraph. 7, § 5, paragraph. 7, § 9, no. 3 and 4 and § 111 paragraph. 6 and § 114a paragraph. 6 of the Act on investment funds and special funds and other collective investment schemes, etc., that person shall immediately notify the FSA this.
§ 22. Upon issuance of the statements and information referred to. §§ 5-6, 23-24, 26, 28-32 and 35-37, it must be assessed which of these are relevant to that activity. Where specific information or a statement not be submitted in relation to an undertaking must be explained in the minutes.
Chapter 6
Special provisions for banks
§ 23. It should be in the external auditors' audit on the annual and consolidated financial statements disclose whether



1) the bank's measurement of loans and guarantees made in accordance with the regulations, and
2) the bank can calculate the individual depositors and investors covered assets.


§ 24. The external auditors must in the minutes of the annual report represent one of the bank prepared a summary of the following, see. However paragraph. 5:



1) The bank's 10 largest exposures.
2) Other exposures exceeding 10 per cent. of the capital base calculated in accordance with § 145 of the Financial Business Act.

3) Other significant exposures if these by the bank and / or the auditor's judgment gives rise to comments to the board.


PCS. 2. The statement under subsection. 1 For each engagement include information on



1) the exposure amounts,
2) any committed framework for contracts and other transactions with derivative financial instruments
3) embedded security and their estimated value,
4) whether the individual impairment on exposure
5) whether the financial year or the previous two years have been written off or written down on the exposures,
6) the debtor's financial situation, and
7) management's assessment of the risk of exposure, taking into account all the circumstances, including the management considers the exposure for correctly measured.


PCS. 3. The external auditors must in the minutes of the Annual Report in line with management's assessment of the individual exposure



1) state auditor's overall assessment of risk on each exposure taking into account all available evidence, and
2) state whether the individual exposures covered by paragraph. 1, is measured correctly.


PCS. 4. In groups see. § 1. 2, the statement and information in accordance with paragraph. 1-2 and the auditor's report in accordance with paragraph. 3 also provided on a consolidated basis.
PCS. 5. The statement by paragraph. 1 must only contain exposures to mortgage companies as well as domestic and foreign banks, if special circumstances dictate.
Chapter 7
Special provisions for mortgage
§ 25. The internal audit must review



1) new mortgage loans without government guarantee, which according to the Board's instructions to the Executive to be granted by the Board
2) conversions of loans exceeding 10 million. kr., and
3) other lending business.


PCS. 2. Consideration of loan cases referred to. Paragraphs. 1, Nos. 1-3, will be done partly through an examination of the loan applications where the collateral value or the institution's assumptions are of particular interest in light of market conditions in that area of ​​common property of the species, partly through random, representative sampling in the paragraph. 1 mentioned groups.
PCS. 3. The internal audit should also verify that the information data is recorded, meet FSA's guidelines. See Financial Supervisory udsøgningssystem.
PCS. 4. The audit agreement must include detailed guidelines for monitoring in accordance with paragraph. 1 and for the reporting of findings to management and the board. Such reporting should include include a discussion of sample selection and the conclusion of the loan file review and a separate report on the lending business, the audit found that the collateral value should have been less. The reporting is given in the minutes of the annual report or sent to the FSA in the copy.
PCS. 5. mortgage companies without internal audit incumbent tasks by paragraph. 1-4 the external audit.
§ 26. In the external auditors' audit on the annual and consolidated financial statements disclose whether



1) the MCI measurement of loans, including the adjustment of the value that takes place as a result of credit risk is carried out in accordance with the regulations,
2) the mortgage bank grants mortgage loans on the basis of anything other than the issuance of mortgage bonds, mortgage bonds, mortgage bonds and other securities referred to. § 1. 1 of the Act on Credit Bonds etc.
3) mortgage bank uses funds obtained through issue of securities lending and whether it invests excess funds from block issue in accordance with § 20 of the Act on Credit Bonds etc.
4) mortgage bank keeps the series reserve fund separate from the other funds in the Foundation in accordance. § 26 paragraph. 1 Credit Loans and Mortgage and
5) mortgage bank can calculate the individual depositors and investors covered assets.


Chapter 8
Special provisions for insurance
§ 27. When subsequently used the concepts of insurance or life insurance, these options include pension funds.

§ 28. In the external auditors' audit on the annual and consolidated financial statements disclose whether



1) there is reason to believe that the technical provisions are calculated so that the taking into account what can reasonably be foreseen, is sufficient to cover all its insurance liabilities at the balance sheet date but are no larger than necessary and
2) the insurer meets the requirements of the statutory investment rules, including state any comments by the Order on registration of assets in insurance companies etc.


§ 29. The external auditors must in the minutes of the annual report to declare whether the FSA submitted inventories of capital and risks per. December 31 is calculated in accordance with the applicable guidelines referred to. Instructions for reporting forms for disclosure of capital and risks in life, non-life and reinsurance companies, pension funds and industrial companies.
Chapter 9
Special provisions for investment companies and investment management companies
§ 30. The external auditors must in the minutes of the Annual Report of Investment Companies say whether



1) investment company if it has a minimum capital of 0.3 million. euro, see. § 125, paragraph. 2, no. 4, of the Financial Business Act and provides services with derivative hedging derivative contracts with other securities transactions
2) The investment company's business is in line with the company's license to carry out investment activities, see. Annex 4 to the Financial Business Act as well as any. holding of own shares is in accordance with § 26 paragraph. 1 of the Financial Business Act, and
3) the investment company can calculate the individual depositors and investors covered assets.


PCS. 2 pcs. 1 shall apply mutatis mutandis to investment management companies authorized according to § 10 paragraph. 2 referred to. § 9 paragraph. 1, of the Financial Business Act.
Chapter 10
Special provisions for investment funds and special funds and restricted associations and hedge funds
§ 31. It is in the external auditors' audit regarding the annual report for investment funds and special funds and restricted associations indicated whether



1) calculation of the issue and redemption shall be made in accordance with it pursuant to § 48 paragraph. 5 and § 113 of the Investment Associations and Special Purpose Associations and other Collective Investment Schemes etc. Act,
2) regulations, see. Chapter 13-14 for investment funds, see. Chapter 15 for special funds and § 113 for restricted associations of the Act on investment funds and special funds and other collective investment schemes, etc., are observed and
3) association or a division have been or are below the statutory minimum requirement for capital as laid. § 4, paragraph. 7, § 5, paragraph. 7 and § 111 paragraph. 6 of the Act on investment funds and special funds and other collective investment schemes, etc.


§ 32. It is in the external auditors' audit regarding the annual report for hedge funds, which are subject to § 114 a paragraph. 1 or paragraph. 2 of the Act on investment funds and special funds and other collective investment funds, etc. disclose whether



1) calculation of the issue and redemption shall be made in accordance with in accordance with § 48 paragraph. 5 and § 114 fi Danish Investment Associations and Special Purpose Associations and other Collective Investment Schemes etc. Act, and
2) association or a division have been or are below the statutory minimum requirement for capital as laid. § 114a paragraph. 6 of the Act on investment funds and special funds and other collective investment funds, etc.


§ 33. In the minutes of the annual report for investment funds and special funds and restricted associations and hedge funds should not be given in § 6, no. 2 and 3, those statements.
Chapter 11
Special provisions for securities dealers

§ 34. Securities dealers are banks, mortgage banks, investment companies and investment management companies authorized as a securities dealer in accordance with § 9 paragraph. 1, of the Financial Business Act, as well as branches in Denmark of credit institutions, investment firms and management companies authorized to provide investment services in a country outside the European Union, the Community has not concluded an agreement for the financial area, and performing such activity in this country, hereinafter referred to as securities dealers.
§ 35. The internal audit shall establish and implement an audit plan to examine and evaluate the securities dealer's systems, internal control mechanisms and arrangements are appropriate and effective.
PCS. 2. The internal audit, as part of the work provided for in paragraph. 1 said working operations through reporting to the board of the compliance function and risk management function referred to. § 6 of the Ordinance on organizational requirements and operating conditions for business as a securities dealer. The internal audit shall as a minimum in the audit on the annual report on the comments on audit matters that the review raises, indicating whether there are appropriate measures in the event of any deficiencies. If the review does not give rise to comments, this must also be apparent from the minutes.
§ 36. If there is established an internal audit, the external auditors to review the reporting to the board of the compliance function and risk management function referred to. § 6 of the Ordinance on organizational requirements and operating conditions for business as a securities dealer. The external audit shall as a minimum in the audit on the annual report on the comments on audit matters that the review raises, indicating whether there are appropriate measures in the event of any deficiencies. If the review does not give rise to comments, this must also be apparent from the minutes.
§ 37. It is in the external auditors' audit on the annual and consolidated financial statements disclose whether the securities dealer with the provisions of § 72 paragraph. 1-3 of the Financial Business Act including the external audit has not been aware of any facts that are contrary to the requirements of the Ordinance on organizational requirements and operating conditions for business as a securities dealer.
Chapter 12
Penalties and entry into force
§ 38. Violation of §§ 2-6, § 8, 2nd paragraph., § 9 paragraph. 1, 2-3. section. and paragraphs. 2-3, § 10 paragraph. 1, 1st and 2nd clauses., And paragraphs. 2-3 and 7, §§ 11-15, § 16 paragraph. 1, § 17, § 18 paragraph. 1, § 19 paragraph. 1 and 3, §§ 20-26, §§ 28-32 and §§ 35-37 fined.
PCS. 2. There can be imposed on companies etc. (legal persons) under the rules of the Penal Code Chapter 5.
§ 39. This Order shall enter into force on 1 January 2009 and apply to audit reports relating to the financial year commencing 1 January 2008 or later. At the same time, Executive Order no. 1224 of 22 October 2007 on auditing financial enterprises and financial groups.
PCS. 2. The provisions of § 10 paragraph. 2 and 3 shall apply to persons who take up a position as chief auditor, deputizing for the chief or deputy chief auditor after 1 January 1999.
FSA, December 16, 2008
Peter Sylvest Larsen
/ Lars Østergaard
Annex 1
Statements and information in the audit on the annual
According to the audit Order § 2, confirmations, statements and information reproduced with the wording shown in the following tables if they submitted without qualifications.
Statements and information that can not be delivered as specified in this Annex should be discussed and listed separately. The shell of these separate statements and information clearly displayed why they have not been given the wording of this Annex.
Please note that by submitting the following statements and information must be assessed which of these that are relevant to the business. Where specific information or a statement not be submitted in relation to an undertaking must be justified in the protocol referred to. Audit Order § 22
For each of the listed elements of audit executive order listed:


- "(E)" for the information / statements to be provided by the external auditors,

- "(I)" for the information / statements to be provided by internal audit
- »(E / I)" for the information / statements, depending on the audit agreement can be performed by either external or internal auditors in accordance. Audit Order § 8



1. Banks






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about, and





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating.





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have come into a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis.





Of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


the financial undertaking's guidelines on monitoring compliance with the ban on speculation according to § 77 paragraph. 4, in the Financial Business Act are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)


checking compliance with the ban on speculation according to § 77 paragraph. 5, of the Financial Business Act has not given rise to comments



§ 5 pieces. 1 pt. 3 (E / I)


established procedures to ensure compliance with the provision of intra-group exposures in § 182 of the Financial Business Act



§ 5 pieces. 1 pt. 4 (E / I)


who has not been identified material errors or omissions in connection with the examination of transactions between the company and the companies covered by § 2 of the Ordinance on intercompany transactions



§ 5 pieces. 1 pt. 4 (E / I)


there is a detailed description of intercompany transactions of material or extraordinary on page ... 1)




§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)



we have received all the information requested





According to the audit Order § 23, we must state that:



§ 23, no. 1 (E / I)


the bank's measurement of loans and guarantees made in accordance with the regulations



§ 23, no. 2 (E / I)


the bank can calculate the individual depositors and investors covered assets





Statement The wording





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the company's administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system, data and reliability and works reassuring





- That the company checks the company's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of legislation on financial companies



§ 6, no. 2 (E)


by the Board granted exposures and collateral received from board members or directors and companies where these are executives or directors are granted under the company's ordinary business terms and on market terms, see. § 78 paragraph. 2 of the Act on Financial Business



§ 6, no. 3 (E)


the financial undertaking has exposures with enterprises that are owned or operated by other executive employees or in which directors or senior executives otherwise participate in the management or operation, see. § 80 paragraph. 1, 2, and 8, 2nd paragraph., In the Financial Business Act





According to the audit Order § 24, we must declare that:



§ 24 paragraph. 3, no. 2 (E / I) 2)



above commitment is measured korrekt3)







2. Mortgage banks






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about, and





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)



we have come into a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis.





Of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


the financial undertaking's guidelines on monitoring compliance with the ban on speculation according to § 77 paragraph. 4, in the Financial Business Act are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)


checking compliance with the ban on speculation according to § 77 paragraph. 5, of the Financial Business Act has not given rise to comments



§ 5 pieces. 1 pt. 3 (E / I)


established procedures to ensure compliance with the provision of intra-group exposures in § 182 of the Financial Business Act



§ 5 pieces. 1 pt. 4 (E / I)


who has not been identified material errors or omissions in connection with the examination of transactions between the company and the companies covered by § 2 of the Ordinance on intercompany transactions



§ 5 pieces. 1 pt. 4 (E / I)


there is a detailed description of intercompany transactions of material or extraordinary on page ... 4)




§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





According to the audit Order § 26, we must state that:



§ 26, no. 1 (E / I)


the MCI measurement of loans, including the adjustment of the measurement to take place as a result of credit risk is carried out in accordance with the regulations



§ 26, no. 2 (E / I)


mortgage banks do not offer mortgages on the basis of anything other than the issuance of mortgage bonds, mortgage bonds, mortgage bonds and other securities referred to. § 1. 1 of the Act on Credit Bonds etc.



§ 26, no. 3 (E / I)


mortgage bank does not use funds obtained through issue of securities other than lending



§ 26, no. 3 (E / I)


mortgage bank invests excess funds from block issue in accordance with § 20 of the Act on Credit Bonds etc.



§ 26, no. 4 (E / I)


mortgage bank keeps the series reserve fund separate from the other funds in the Foundation in accordance. § 26 paragraph. 1 of the Act on Credit Bonds etc.




§ 26, no. 5 (E / I)


mortgage bank can calculate the individual depositors and investors covered assets





Statement The wording





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the company's administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system, data and reliability and works reassuring





- That the company checks the company's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of legislation on financial companies



§ 6, no. 2 (E)


by the Board granted exposures and collateral received from board members or directors and companies where these are executives or directors are granted under the company's ordinary business terms and on market terms, see. § 78 paragraph. 2 of the Act on Financial Business



§ 6, no. 3 (E)


the financial undertaking has exposures with enterprises that are owned or operated by other executive employees or in which directors or senior executives otherwise participate in the management or operation, see. § 80 paragraph. 1, 2, and 8, 2nd paragraph., In the Financial Business Act






3. Insurance companies






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about,





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have come into a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis





Of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


the financial undertaking's guidelines on monitoring compliance with the ban on speculation according to § 77 paragraph. 4, in the Financial Business Act are adequate and have functioned appropriately




§ 5 pieces. 1 pt. 2 (E)


checking compliance with the ban on speculation according to § 77 paragraph. 5, of the Financial Business Act has not given rise to comments



§ 5 pieces. 1 pt. 3 (E / I)


established procedures to ensure compliance with the provision of intra-group exposures in § 182 of the Financial Business Act



§ 5 pieces. 1 pt. 4 (E / I)


who has not been identified material errors or omissions in connection with the examination of transactions between the company and the companies covered by § 2 of the Ordinance on intercompany transactions



§ 5 pieces. 1 pt. 4 (E / I)


there is a detailed description of intercompany transactions of material or extraordinary on page ... 5)




§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





According to the audit Order § 28, we must state that:



§ 28, no. 1 (E / I)


there are reasons to believe that the technical provisions are calculated so that the taking into account what can reasonably be foreseen, is sufficient to cover all its insurance liabilities at the balance sheet date but are no larger than necessary



§ 28, no. 2 (E)


the insurance company meets the requirements of the statutory investment rules. There are given the necessary remarks after the Executive Order on registration of assets in insurance companies etc. on the side ... 6)






Statement The wording





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the company's administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system, data and reliability and works reassuring





- That the company checks the company's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of legislation on financial companies



§ 6, no. 2 (E)



by the Board granted exposures and collateral received from board members or directors and companies where these are executives or directors are granted under the company's ordinary business terms and on market terms, see. § 78 paragraph. 2 of the Act on Financial Business



§ 6, no. 3 (E)


the financial undertaking has exposures with enterprises that are owned or operated by other executive employees or in which directors or senior executives otherwise participate in the management or operation, see. § 80 paragraph. 1, 2, and 8, the second section. in the Financial Business Act





According to the audit Order § 29, we must declare that:



§ 29 (E)


the FSA reported statement of capital and risks per. December 31 is calculated in accordance with the applicable guidelines referred to. Instructions for reporting forms for disclosure of capital and risks in life, non-life and reinsurance companies, pension funds and industrial companies.






4. Investment companies






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about,





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have come into a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis





Accessibility of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


the financial undertaking's guidelines on monitoring compliance with the ban on speculation according to § 77 paragraph. 4, in the Financial Business Act are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)


checking compliance with the ban on speculation according to § 77 paragraph. 5, of the Financial Business Act has not given rise to comments



§ 5 pieces. 1 pt. 3 (E / I)


established procedures to ensure compliance with the provision of intra-group exposures in § 182 of the Financial Business Act



§ 5 pieces. 1 pt. 4 (E / I)


who has not been identified material errors or omissions in connection with the examination of transactions between the company and the companies covered by § 2 of the Ordinance on intercompany transactions



§ 5 pieces. 1 pt. 4 (E / I)



there is a detailed description of intercompany transactions of material or extraordinary on page ... 7)




§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





According to the audit Order § 30 paragraph. 1, we must state that:



§ 30 paragraph. 1 pt. 1 (E / I)


investment company if it has a minimum capital of 0.3 million. euro, see. § 125, paragraph. 2, no. 4, of the Financial Business Act and provides services with derivative hedging derivative contracts with other securities transactions



§ 30 paragraph. 1 pt. 2 (E / I)


investment company's business is in line with the company's license to carry out investment activities, see. Annex 4 to the Financial Business Act as well as any. holding of own shares is in accordance with § 26 paragraph. 1 of the Financial Business Act



§ 30 paragraph. 1 pt. 3 (E / I)


the investment company can calculate the individual depositors and investors covered assets





Statement The wording





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the company's administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system, data and reliability and works reassuring





- That the company checks the company's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of legislation on financial companies



§ 6, no. 2 (E)


by the Board granted exposures and collateral received from board members or directors and companies where these are executives or directors are granted under the company's ordinary business terms and on market terms, see. § 78 paragraph. 2 of the Act on Financial Business



§ 6, no. 3 (E)


the financial undertaking has exposures with enterprises that are owned or operated by other executive employees or in which directors or senior executives otherwise participate in the management or operation, see. § 80 paragraph. 1, 2, and 8, 2nd paragraph., In the Financial Business Act







5. Investment management companies that only have a license under § 10 paragraph. 2 of the Act on Financial Business






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about, and





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have not come to a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis





Of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


the financial undertaking's guidelines on monitoring compliance with the ban on speculation according to § 77 paragraph. 4, in the Financial Business Act are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)


checking compliance with the ban on speculation according to § 77 paragraph. 5, of the Financial Business Act has not given rise to comments



§ 5 pieces. 1 pt. 3 (E / I)


established procedures to ensure compliance with the provision of intra-group exposures in § 182 of the Financial Business Act



§ 5 pieces. 1 pt. 4 (E / I)


who has not been identified material errors or omissions in connection with the examination of transactions between the company and the companies covered by § 2 of the Ordinance on intercompany transactions



§ 5 pieces. 1 pt. 4 (E / I)


there is a detailed description of intercompany transactions of material or extraordinary on page ... 8)




§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





Statement The wording






According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the company's administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system, data and reliability and works reassuring





- That the company checks the company's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of legislation on financial companies



§ 6, no. 2 (E)


by the Board granted exposures and collateral received from board members or directors and companies where these are executives or directors are granted under the company's ordinary business terms and on market terms, see. § 78 paragraph. 2 of the Act on Financial Business



§ 6, no. 3 (E)


the financial undertaking has exposures with enterprises that are owned or operated by other executive employees or in which directors or senior executives otherwise participate in the management or operation, see. § 80 paragraph. 1, 2, and 8, 2nd paragraph., In the Financial Business Act






6. Investment management companies authorized according to § 10 paragraph. 2 referred to. § 9 paragraph. 1 of the Act on Financial Business






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about, and





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have come into a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis





Of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


the financial undertaking's guidelines on monitoring compliance with the ban on speculation according to § 77 paragraph. 4, in the Financial Business Act are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)



checking compliance with the ban on speculation according to § 77 paragraph. 5, of the Financial Business Act has not given rise to comments



§ 5 pieces. 1 pt. 3 (E / I))


established procedures to ensure compliance with the provision of intra-group exposures in § 182 of the Financial Business Act



§ 5 pieces. 1 pt. 4 (E / I)


who has not been identified material errors or omissions in connection with the examination of transactions between the company and the companies covered by § 2 of the Ordinance on intercompany transactions



§ 5 pieces. 1 pt. 4 (E / I)


there is a detailed description of intercompany transactions of material or extraordinary on page ... 9)




§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





According to the audit Order § 30 paragraph. 2, we state that:



§ 30 paragraph. 1 pt. 1 (E / I)


investment management company if it has a minimum capital of 0.3 million. euro, see. § 125, paragraph. 2, no. 4, of the Financial Business Act and provides services with derivative hedging derivative contracts with other securities transactions



§ 30 paragraph. 1 pt. 2 (E / I)


investment management company's business is in line with the company's license to conduct investment management business



§ 30 paragraph. 1 pt. 3 (E / I)


investment management company can calculate the individual depositors and investors covered assets





Statement The wording





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the company's administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system, data and reliability and works reassuring





- That the company checks the company's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of legislation on financial companies



§ 6, no. 2 (E)



by the Board granted exposures and collateral received from board members or directors and companies where these are executives or directors are granted under the company's ordinary business terms and on market terms, see. § 78 paragraph. 2 of the Act on Financial Business



§ 6, no. 3 (E)


the financial undertaking has exposures with enterprises that are owned or operated by other executive employees or in which directors or senior executives otherwise participate in the management or operation, see. § 80 paragraph. 1, 2, and 8, 2nd paragraph., In the Financial Business Act






7. Trusts






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about, and





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have come into a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis





Of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


Association guidelines according to § 34 paragraph. 4 of the Act on investment funds and special funds and other collective investment schemes, etc. are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)


checking compliance with the ban on speculation according to § 34 paragraph. 5 of the Act on investment funds and special funds and other collective investment schemes, etc. has not given rise to comments



§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





According to the audit Order § 31, we inform that:



§ 31, no. 1 (E / I)



the calculations of the issue and redemption shall be made in accordance with it pursuant to § 48 paragraph. 5 of the Act on investment funds and special funds as well as other Collective Investment Schemes etc. Act



§ 31, no. 2 (E / I)


placement rules, see. Chapter 13-14 of the Act on investment funds and special funds and other collective investment schemes, etc., are met



§ 31, no. 3 (E / I)


association or a fund has not been or is below the statutory minimum requirement for capital as laid. § 4, paragraph. 7 of the Act on investment funds and special funds and other collective investment schemes, etc.





Statement The wording





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system security, data and reliability and works reassuring





- In association checks on the association's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of legislation on investment funds






8. Special Associations






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about, and





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have come into a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis





Of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


Association guidelines according to § 34 paragraph. 4 of the Act on investment funds and special funds and other collective investment schemes, etc. are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)



checking compliance with the ban on speculation according to § 34 paragraph. 5 of the Act on investment funds and special funds and other collective investment schemes, etc. has not given rise to comments



§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





According to the audit Order § 31, we inform that:



§ 31, no. 1 (E / I)


the calculations of the issue and redemption shall be made in accordance with it pursuant to § 48 paragraph. 5 of the Act on investment funds and special funds as well as other Collective Investment Schemes etc. Act



§ 31, no. 2 (E / I)


placement rules, see. Chapter 15 of the Act on investment funds and special funds and other collective investment schemes, etc., are met



§ 31, no. 3 (E / I)


association or a fund has not been or is below the statutory minimum requirement for capital as laid. § 5, paragraph. 7 of the Act on investment funds and special funds and other collective investment schemes, etc.





Statement The wording





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system security, data and reliability and works reassuring





- In association checks on the association's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to requirements of legislation for special funds






9. Limited-membership associations






Determination of audit Order


Wording of confirmations





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including






- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about, and





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have not come to a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis





Of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


Association guidelines according to § 34 paragraph. 4 of the Act on investment funds and special funds and other collective investment schemes, etc. are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)


checking compliance with the ban on speculation according to § 34 paragraph. 5 of the Act on investment funds and special funds and other collective investment schemes, etc. has not given rise to comments



§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





According to the audit Order § 31, we inform that:



§ 31, no. 1 (E / I)


the calculations of the issue and redemption shall be made in accordance with it pursuant to § 48 paragraph. 5 and § 113 of the Investment Associations and Special Purpose Associations and other Collective Investment Schemes etc. Act



§ 31, no. 2 (E / I)


placement rules, see. Chapter 13-15 and § 113 of the Act on investment funds and special funds and other collective investment schemes, etc., are met



§ 31, no. 3 (E / I)


association or a fund has not been or is below the statutory minimum requirement for capital as laid. § 111 paragraph. 6 of the Act on investment funds and special funds and other collective investment schemes, etc.





Statement The wording





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that






- The overall system security, data and reliability and works reassuring





- In association checks on the association's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of the legislation on restricted associations






10. Hedge funds






Determination of audit Order


Bekræftelsers text





According to the audit Order § 4, paragraph. 4, we must confirm that:



§ 4 pcs. 4 (E)


we have complied with the ban on providing assistance and consultancy assignments, see. § 24 paragraph. 4, first paragraph. Of the Act on Approved Auditors and Audit Firms, including





- We or other persons in the audit firm has not participated in the accounts or similar documents that form the basis for the annual report or other conditions that make a declaration about, and





- We or other persons in the audit firm not involved in preparing the annual report or any other document relating





According to the audit Order § 17 paragraph. 4, we must confirm that:



§ 17 paragraph. 4 (I)


we have not come to a situation where we declare ourselves and communicate facts or documents we or employees of the Internal Audit has prepared the basis





Accessibility of information text





According to the audit Order § 5, we must state that:



§ 5 pieces. 1 pt. 1 (E)


Association guidelines according to § 34 paragraph. 4 of the Act on investment funds and special funds and other collective investment schemes, etc. are adequate and have functioned appropriately



§ 5 pieces. 1 pt. 2 (E)


checking compliance with the ban on speculation according to § 34 paragraph. 5 of the Act on investment funds and special funds and other collective investment schemes, etc. has not given rise to comments



§ 5 pieces. 2, no. 1 (E)


the according revision agreement agreed tasks to be performed by internal audit is performed, and that the internal audit function satisfactorily including that the external auditors have not become aware of conditions that, individually or together compromise the internal audit function independent of the management



§ 5 pieces. 2, no. 2 (E)


we agree with the content of all the internal audit protocol inputs for the financial year





According to the audit Order § 17 paragraph. 5, we state that:



§ 17 paragraph. 5 (I)


we have received all the information requested





According to the audit Order § 32, we must state that:



§ 32, no. 1 (E / I)



the calculations of the issue and redemption shall be made in accordance with it pursuant to § 48 paragraph. 5 and § 114 fi Danish Investment Associations and Special Purpose Associations and other Collective Investment Schemes etc. Act



§ 32, no. 2 (E / I)


association or a fund has not been or is below the statutory minimum requirement for capital as laid. § 114a paragraph. 6 of the Act on investment funds and special funds and other collective investment schemes, etc.





Declarations reads





According to the audit Order § 6, we must declare that:



§ 6, no. 1 (E / I)


the administrative and accounting practices in key areas, including business and internal control procedures are designed and operating with integrity. In this connection we must also declare that





- The overall system security, data and reliability and works reassuring





- In association checks on the association's portfolio of securities and the like





- Bookkeeping is organized in such a way that it can form the basis for reports to be made to the FSA, and





- We are not aware of conditions that are contrary to the requirements of the legislation on hedge funds






11. Securities dealers








According to the audit Order § 37, we inform that:



§ 37 (E / I)


The securities dealer with the provisions of § 72 paragraph. 1-3 of the Financial Business Act including





- That we are not aware of conditions that are contrary to the requirements of the Ordinance on organizational requirements and operating conditions for business as a securities dealer



1) 2) 3) 4) 5) 6) 7) 8) 9) 10) 11) Annex 2
Summary of comments in the audit on the annual
1. The provision
The following are the details concerning the contents of the provision, including an interpretation of the key words in that paragraph.
1.1 The wording
The requirement for a summary of all observations of the audit Order § 4, paragraph. 2, 2nd and 3rd clauses., And § 17 paragraph. 3, 2nd and 3rd sentences .:
In a separate section of the minutes of the annual report shall auditors (external audit internal audit) summarize all the comments, the audit has given rise to advance to the board. The summary must include a status of the observations put forward relating to the year and a status of the observations appearing as pending in the minutes of the previous annual report.
1.2 The requirement for a separate section
The requirement for a separate section for comments is mandatory. This means that the separate section on remarks should always be included, whether there are any comments or not. This applies both to the external auditor and the internal audit report.
If the external auditors agree with the contents of the internal auditors' audit, 12), it is sufficient that any comments are only apparent from the internal audit report. If need be it of the separate parts of the external auditors' audit indicated that the comments appear in the internal audit report. Certain conditions is of such a nature that they must be addressed in both the external auditor as the internal auditors' audit, for example. conditions which cause reservations and / or additional information in the audit report.

The separate parts should be placed in a place where it is easy to find, and assigned a headline that makes it clear how the comments summarized. If compiled a table of contents for the audit report to the annual report, the episode's location indicated thereof.
1.3 The requirement for summing
The idea of ​​the provision is to provide an overview. A summary (in a few lines) of each of the raised arguments are therefore better than a repetition of the entire description. The problem must be stated in the summary. More comments regarding the same should also be consolidated where appropriate. Eg. it may be appropriate to merge several comments on the circulation of lending to one point.
The summary of comments must be made at the corporate level. For corporations must also be included comments from subsidiaries that are relevant assessed at group level, see. Audit Executive Order § 5, paragraph. 3.
1.4 The requirement for all comments
All - all without exception - those in the audit report raised arguments should be summarized in the separate section of the audit regarding the annual report.
There can not be built materiality assessment in determining whether a point should be summarized.
A relationship that once the audit report has raised the remark included in future in the annual summary of the comments in the audit of the annual report. It is not sufficient that an audit report during the year have seen, that observation is clarified. It should also be mentioned in the first annual summary. Only then deleted the remark of future annual summaries.
1.5 Notes contra comments
A note must be understood as the auditor's observation that a relationship is not in accordance with relevant regulations, orders, agreements 13) or standards (including "good practice") that may be applicable to that area. A note may also include a relationship that auditor during the use of his professional experience did not consider it appropriate and without the relationship, however, is contrary to specific regulations, orders, agreements or standards.
A comment must be understood as auditor supporting information for a given relationship.
Comments are therefore not the same as comments. An cautions function is to draw the Board's attention to matters which are not in accordance with the rules, etc., or which are not appropriate. A comment's function is, however, only to clarify a relationship that did not give rise to any comments.
Another difference between a note and a comment is a comment concerns a relationship that is as reparable.
The following conditions will typically give rise to observations relevant to the Board:


- Exceeding the solvency limits, exposure limits, lending limits, breach of speculation provisions, exceeding the placement limits, failure to comply with the statutory minimum capital size / capital requirement, etc.,
- Failure to comply with the Board's obligations under. Companies Act, the Financial Business Act and sector laws, Accountancy Act, the Annual Accounts Act,
- Violation of the reporting requirements of the FSA,
- Other offenses, 14)
- Order made by the FSA, which has not yet complied,
- The Financial Supervisory required statements in the audit by the auditor comments,
- Conditions which cause reservations and / or additional information in the audit report,
- Procedures where there is a clear need to strengthen the internal controls (without affecting the information that business procedures are adequate)
- Exceeding the determined by the board lines / guidelines, and
- Systems, internal control arrangements or is not appropriate and / or effective, see. Audit Executive Order § 35 paragraph. 1.

It should be emphasized that the above list is not exhaustive but merely some examples of relevant types of comments.
1.6 The requirement to provide a status
The legislation requires that there be given a status of


- The observations put forward on that financial year, and
- The observations appearing as pending in the minutes of the previous annual report.


Comments that are raised in the current period includes comments in Minutes during the year and årsprotokollatet. What matters is whether the note is put forward as part of the review relating to the year.
Status must contain a reference to the pages where comments have been featured in the årsprotokollat, as well as references to the protocol relating to the previous annual reports, if this is not the first time the remark referred.
Notes can have two types of status - either clarified or open-ended.
Resolved comments
Comments may be clarified in one of two ways:


- The relationship is no longer relevant, or
- Has been remedied.

Notes that have lost their relevance, for example. remarks on problems with the calculation of value adjustments on securities in a fund system where the fund system was subsequently replaced by a new fund system that can calculate value adjustments correctly. Additional include comments regarding a specific violation of speculation rules that do not reflect poor internal controls. Cases of fraud are also examples of comments made once and then lose their relevance.
Comments that are resolved, for example. remarks on lack of business description, which subsequently developed.
For each of the clarified comments should state how the relationship is clarified.
Open comments below
Notes that are not corrected, are inherently open-ended. For each of the open-ended comments must specify at what point the management expects that the condition has been remedied. If the circumstance is partially remedied, this must also be reflected. Furthermore, it must appear the status if the expected remedial time changes along the way.
Since the audit, among other things carried out taking into account the company's internal control environment, it is relevant that the auditor verifies whether previously raised arguments are resolved. The audit carried out an assessment of materiality and risk and therefore, among other things, made of a rotation basis, so that the longer the review of areas that are less important and risky than areas that are important and risky. The auditor will later have to deal with previously raised arguments when the review next time comprises the area in which the comment relates.
For information about how individual comments are clarified or expected clarified, is not part of the review, and this information can be based on information received by management (organization).
If the auditor's professional skepticism means that the auditor has reason to doubt the information provided, the auditor should verify the validity of enlightenment.
Being auditor during the audit noted that by Management (organization) information given on clarification of the comments are misleading or erroneous, the auditor should make the Board aware of this in the audit report.
If the auditor also becomes aware of facts that should be remedied, but has not yet become the auditor should investigate that area the following year. Concerns remark central aspects of financial reporting, the auditor should reassess the audit plan and, if necessary perform compensatory audit work for the current year.
2. Examples
The following shows two examples that illustrate how the auditor may summarize his observations so that they meet the requirements of the audit order. The first model may be used in the case where the external audit whereas the internal audit notes. The second model shows how the separate section for comments can be designed.
Example 1
X. Summary of comments
'In accordance with Executive Order on Auditing in a separate section of the audit of the annual report and the consolidated financial statements summarize all the comments, the audit has given rise to advance to the board. The summary must include a status of the observations put forward relating to the year and a status of the observations appearing as pending in the audit related to the previous financial year.
It agreed with the Internal Audit that summing up according to auditing the Order solely from Internal Audit audit report, to which we refer.

We have no further comments. "
Example 2
X. Summary of comments
'In accordance with Executive Order on Auditing in a separate section of the audit of the annual report and the consolidated financial statements summarize all the comments, the audit has given rise to advance to the board. The summary must include a status of the observations put forward relating to the year and a status of the observations appearing as pending in the audit related to the previous financial year.
Comments that are resolved in the year 200x, marked with A, and remarks that are left open, marked with Å. The specified page references refer to the pages in the audit report, which comments have been discussed. In cases where it is not the first time the remark referred to, the reference is also made to Minutes on previous annual reports in addition to the reference to the minutes of that period.
Unless otherwise stated, we have not verified information on whether comments are resolved / under remediation.
Speculation Rules (A - page xxx)
The prohibition .... has been violated in two cases. Reportedly ........
Lending rates (Å - page xxx, page xxx)
There is a general need to update descriptions of business to correspond to the actual - and also reassuring - business processes. Reportedly, the business procedure descriptions will be updated over the xxxxx - while implementing the new xxx system.
Securities Area (Å - page xxx, A - page xxx and Å - page xxx)
We have found that the Funds have been problems related to the reconciliation of the foreign securities. Initiatives have been taken to strengthen internal controls in connection with the vote of foreign securities, and according to information expected work thereon conducted during the fall 200x.
We have found that the Board's instructions now contains a description of the products front-office must act, and requirements for the management of market risks.
Absence of an updated register of shareholders in accordance with the Companies Act § 25. We have been informed that an updated register of shareholders will be presented at the Board meeting on x. March 200x.
IT application (Å - page xxx)
There is a need to establish a plan for the servers that operation running Internet Bank. Management has prepared an action plan for improving disaster preparedness that are expected implemented in Q1 200x.
Intercompany transactions (A - page xxx, A - page xxx and Å - page xxx)
The in the year 200x acquired companies were not covered by the guidelines for the implementation of intra-group transactions, but we have now ensured that these companies are subject to the Council-approved guidelines.
The agreement with xxxxx, which was put into effect, without the formal approval. We have found that the agreement has now been approved by the Executive Board.
Settlement of the commission is based on the agreement with yyyyy not updated. We subsequently found that updating the agreements on commissions is ongoing and expected to be completed in the second quarter 200X. "
Appendix 3
Internal audit functions and behavior
There are revisionsbekendgørelsen fixed framework within which, the internal auditors must perform tasks. The aim is to ensure the internal audit independent of the activities being audited.
The sections below 1 outlined the conditions under which internal audit must be aware before a task assumed. Next, section 2 provided a number of examples of tasks that internal audit can, respectively can not perform.
1. The provisions of revision Order
1.1 Only audit
According to the audit Order § 12 paragraph. 2


- Must audit manager and employees of the internal audit did not participate in other work in the undertaking or group than auditing.

1.2 Independence
According to the audit Order § 12 paragraph. 3,


- Do internal audit does not take on tasks when there are circumstances that are apt to arouse doubts in an informed third party for the internal audit independence.

According to the audit Order § 14 paragraph. 3 that



- Audit tasks must not cause the chief internal auditor in a situation where he agrees or provides information about facts or documents which the chief or employees of the Internal Audit has prepared the basis.

The provisions to ensure the internal audit's independence. The controller is to perform assurance engagements in accordance with the audit notice and endorse also the annual report, if selected by the Board. The internal audit should always safeguard its independence as external audit must safeguard its independence. The internal audit has, however, a slightly different basis for its independence, due to its special role in the financial business.
The internal audit should be to safeguard its independence, always be aware that the chief and employees of the internal audit:


- Has a duty to identify and evaluate circumstances and relationships that create threats to independence, and demonstrate that they have arranged for this
- Take the necessary steps to eliminate these threats or reduce them to an acceptable level through the application of security as far as is possible given that the starting point is that they are employed by the company and
- Not carry out audit tasks, which means that circumstances arise that are suitable to arouse doubts in an informed third party for the internal audit independence.

1.3 Adequate competence
In addition, the internal audit referred. Audit Order § 14 paragraph. 2


- Alone can take on the tasks that it has sufficient competence to perform.

Below is the definition of what tasks under the provisions carried out by the chief and employees of the internal audit elaborated.
2. Examples of work for the internal audit
2.1 Financial audit and review
Financial audit and review includes audit and review of historical financial information, including annual reports, interim reports, etc. The work includes a review and assessment of the procedures and the manual or system-based controls related to the creation of the historical financial information.
Internal auditors' duties include - depending on the level of competence and whether it is selected that internal auditors endorse the annual report or not - for example:


- Auditing and submission of audit opinion on annual reports
- Review of interim reports
- Submission of declarations, data and information according to the Financial Business Act and revision notice
- Submission of statements to public authorities
- Assistance to external auditors in connection with the issuance of subordinated debt and the offering of shares
- Assessment of whether procedures and internal controls meet the Financial Business Act § 71 with associated manuals and internal guidelines and
- Assistance with due-diligence on the purchase / sale of business.

In most cases, the central task of internal audit be participation in the financial audit. It appears, however, more and more often to the internal audit focus to a greater extent paid to the operational audit, see. The discussion below, ie that internal audit involvement in the financial audit of the annual report deselected or reduced.
If the chief endorse the annual report, the Chief Auditor participate in the audit of material and risky areas, see. Audit Order § 15 paragraph. 2. The assessment of the areas that are critical audit will follow the guidelines of Auditing Standard 315, and will depend on each company type and complexity.
In credit institutions, for example. lending, fees for trading, real estate, unlisted equity investments and derivative financial instruments and liabilities such. pension obligations and guarantees basically be substantial and risky, including due to complex rules, the use of models, compliance with investment rules and solvency calculations.
For insurance companies, for example. premium income, claims expenses / insurance services and investment return is considered significant and risky. Also the associated investment assets and provisions for insurance and investment contracts as well as reinsurance and financial derivatives is usually significant and risky areas.

Annual report content, including management report, financial / group, 5-year view and notes, as well as the accounting policies are considered in all cases as significant and risky. The above examples of individual business types is merely meant as an inspiration, since in all cases be made a specific and documented individual assessment of the material and risky areas associated with each company's activity.
The internal audit may not, as part of the review taking on tasks when there are circumstances that are apt to arouse doubts in an informed third party for the internal audit independence. In carrying out the financial audit should the internal audit not, for example:


- Helping to make decisions or take responsibility for this,
- Carrying out inspection tasks - be a part of the internal control
- Development or establishment of the annual report or other statements of historical financial information
- Post or in some other register,
- Participate in the recruitment of employees to the company, except for the recruitment of staff for the internal audit
- Manage wages, property, alterations or similar or
- Authorize payments or be prokurahaver for the financial activities in areas other than those relating to costs related to the internal audit.

This applies whether the chief endorse the annual report or not.
These tasks are not auditors in accordance. Audit Order § 12 paragraph. 2, like internal audit will come into conflict with the prohibition of self-audit by performing these tasks, see. Audit Order § 14 paragraph. 3.
Before the internal audit undertake tasks that are not mentioned in the function description, or how to use a greater number of hours, the audit shall obtain the Board or any revisionskomites acceptance before the task is undertaken.
2.2 Operational audit
Operational audit involves and assessment of business processes, with the aim to test and report on their compliance with the management objectives.
Operational audit involves on the enterprise activity and size, including a process review with a focus on efficiency, an assessment of the reliability of financial and operational reporting, compliance with laws and regulations and ensuring the company's values. Exploration of fraud may be included.
The internal auditor may not, for example:


- Helping to make decisions or take responsibility for this,
- Carrying out inspection tasks - be a part of the internal control
- Be responsible for the implementation of new operating routines, including rationalization and efficiency measures,
- Be responsible for preparation of the daily monitoring and reporting of target achievement,
- Participate in the development of the operational objectives,
- Decide or stand for execution of sanctions by uncovered fraud or
- Determine or be responsible for preparation of operational strategies and processes.

The scope of the operational audit agreed with the Board in the function description, provided that the agreed tasks are kept within the framework of the audit order.
2.3 Review of risk management
Financial companies are exposed to various types of risk. The main types of risk are credit risk, market risk, liquidity risk, operational risk and business risk. The audit includes the established risk management within the individual types of risk, including the limits set and the established reporting structure.
Internal auditors should evaluate whether the established policies held under the Danish Financial Business Act and related executive orders and instructions. Internal audit can not assume monitoring tasks, so that the internal audit is part of the internal control device.
For example, the development of risk management strategies to Board approval and the level of risk typical management tasks that can not be done by the internal audit.
Internal audit can not assume development and control tasks related to individual risk types, the internal audit will be able to get into a situation where it must declare that the tasks which it has assisted in the preparation of.

Basically, there is nothing to prevent the internal audit acts as the independent entity in relation to paragraph 75 of the Guidance on adequate capital base and individual solvency requirement if the internal audit is independent and it does not conflict with other laws and regulations .
2.4 Review of the compliance function
Compliance function is responsible for assisting management in effectively manage corporate compliance risks. If an independent compliance function is not established, the daily management responsibility to handle any compliance risks and appoint another entity that is responsible for carrying out the necessary checks.
Internal audit must, of materiality and risk, review and assess whether the company established processes for managing compliance function's activities are reassuring. Internal auditors can not perform the compliance function or parts of it, since this is incompatible with the audit task (self-auditing).
2.5 Audit Tasks that are not directly related to the annual report
Tasks that are not part of the audit work leading to the endorsement of the annual report but which are perceived as an audit engagement, must appear explicitly in the function description.
This does not audit work on the submission of declarations and information under audit executive order that do not relate to the words of the annual report.
3. Conduct
Audit Managers, deputy chief internal auditors and employees of the internal audit must comply with the following ethical principles in such a way that both the individual auditor as the department is not adversely affected.
integrity
The auditor shall be fair and honest in all professional and business relationships.
objectivity
The auditor must not be biased, having conflict of interest or be under the undue influence of others so that the professional and business judgment suppressed.
Professional competence and due care
The auditor is obliged to continually maintain their professional knowledge and skills at a level that is necessary to ensure that supplied a qualified professional performance based on an updated knowledge of the latest developments in good practice, legislation and practices. The auditor shall at delivery of professional services act diligently and in accordance with relevant technical and professional standards.
Privacy
The auditor must maintain the confidentiality of information obtained as part of his employment, and shall not disclose such information to third parties without proper and specific authorization, unless there is a legal or professional right or duty to do so. Confidential information obtained as part of his employment should not be used to obtain personal benefit of accountant or third parties.
Professional Conduct
The auditor shall comply with relevant legislation and other regulations and avoid any behavior that could discredit the internal and external audit.
Further inspiration can be found in IFAC`s Code of Ethics' Code of Ethics for Professional Accountants ", located on IFAC`s website (www.ifac.org) or IIA`s code of ethics, located on IIA`s website (www. theiia.org). The Code is published by the CSF in a version adapted to Danish conditions.

Official notes 1) This Executive Order contains provisions that implement Commission Directive no. 2006/73 / EC of 10 August 2006 on the implementation of the European Parliament and Council Directive 2004/39 / EC as regards organizational requirements and operating conditions for investment firms and defined terms for the purposes of that Directive.
1) Please refer to the relevant pages in the audit.
2) Please refer to audit Order § 24 paragraph. 3-5 for additional requirements in connection with this declaration.
3) Refer to the audit Order § 24 paragraph. 3, for additional requirements in connection with this.
4) Please refer to the relevant pages in the audit.
5) Please refer to the relevant pages in the audit.
6) Please refer to the relevant pages in the audit.
7) Please refer to the relevant pages in the audit.
8) Please refer to the relevant pages in the audit.
9) Please refer to the relevant pages in the audit.
10) Please refer to the relevant pages in the audit.
11) Please refer to the relevant pages in the audit.

12) There is a requirement that the external audit of its protocol to the annual report should indicate whether the external auditors agree with the contents of the internal audit protocol, see. Audit Order § 5, paragraph. 2, no. 2.
13) Including special requirements from for example. Board of Directors or shareholders.
14) When the auditor's work is done in order to deliver an auditors' report on the annual report, the auditor will rarely encounter violations of law other than corporate laws, tax laws and sectoral laws. The auditor should be in the audit disclose violations of any law insofar auditor becomes aware of them.