Notice On The Implementation Of Financial Services Companies And Financial Groups, Etc.

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

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Overview (table of contents)



Chapter 1



The scope of the





Chapter 2



The external audit





Chapter 3



The internal audit





Chapter 4



The audit report





Chapter 5



Common provisions





Chapter 6



Special provisions for financial institutions





Chapter 7



Special provisions for mortgage companies





Chapter 8



Specific rules for insurance companies





Chapter 9



Special rules for stockbroking firms and investment management companies





Chapter 10



Special provisions for investment funds and specialist associations as well as fåmandsforeninger and hedge funds





Chapter 11



Special provisions for securities traders





Chapter 12



Penal provisions and entry into force





Annex 1



Conclusions and information in the audit of the hearing relating to the annual report





Annex 2



Description of the auditor's work actions





Annex 3



Summary of comments in the audit of the hearing relating to the annual accounts





Annex 4



Internal audit tasks and behaviors



The full text of the ordonnance on audits in financial firms, etc., as well as financial koncerner1)

Under section 199, paragraph 11, and § 373, paragraph 4, of the financial business Act, see. lovbekendtgørelse nr. 948 of 2. July 2013, article 79, paragraph 10, and section 221, paragraph 3, of the Act on investment associations, etc., see. lovbekendtgørelse nr. 333 of 20. March 2013 and § 5 (2) and section 14, paragraph 2, of the law on a ship's financial regulation. lovbekendtgørelse nr. 886 of 8. August 2011, fixed: Chapter 1 scope § 1. This Ordinance shall apply to financial companies, see. § 5 (1) (8). 1, in the financial business Act, and mutual funds, special funds, and hedge funds, see fåmandsforeninger. section 4, paragraph 1, article 6, paragraph 1, article 7, paragraph 1, and section 161 of the Act on investment associations, etc., as well as Danish ship credit a/s.

(2). The notice also applies to both groups as a whole, see. § 5 (1) (8). 9, in the financial business act as on individual companies in groups, where the parent undertaking is a financial holding company or a financial company, see. § 5 (1) (8). 10 of the law on financial business.

General conditions



§ 2. Conclusions and information after this notice must be either without reservation or with reservations, afkræftende. If the auditor is unable to express a conclusion on the subject, this must be specified.

(2). The auditor must know the submission of conclusions and information after this notice take reservations, if the information is taken into account for the work done, is vitiated by substantial errors, or missing, or if the auditor is unable to obtain sufficient and appropriate evidence to conclude that the subject is without significant errors. Auditor's reservations must clearly stated in conclusion with the use of the word "reservations", and the opt-out must be clearly described and justified.

(3). The auditor must know the submission of conclusions and information after this notice provide supplementary information on any matters to which the statutory auditor points without taking reservations. Additional information must not substitute one reservation. For additional information, the term "supplementary data" should be used.

(4). Conclusions and information under this Ordinance shall, if they are made without qualification, be reproduced verbatim, without prejudice. Annex 1.

§ 3. The extent and nature of the work actions that should be taken in order to give the individual conclusions and information after this notice shall be governed by the statutory auditor, taking into account good auditor usage. There is in annex 2 set out a description of actions, etc., are expected to be included in order for the auditor to give the individual conclusions and information in this notice.

Chapter 2 The external review section 4. The external audit shall review the financial statements and the consolidated financial statements in accordance with good practice and including the auditor verify whether these are carried out in accordance with legislation and other provisions, if any, requirements for financial reporting.

The external audit Protocol



§ 5. For use by the Board of Directors of undertakings established in Denmark, the external audit conduct an audit Protocol. To be in the Protocol sets out the audit carried out during the year, which can form the basis of audit partial conclusions. The Protocol must be presented at any Board meeting, and any protocol injection must be signed by the entire Board of Directors and audit manager.

(2). In the minutes relating to the annual accounts must set out the nature and extent of the audit work performed and the conclusion of this. In addition, the Division of labour between internal audit and external audit are discussed.

(3). In the minutes concerning the annual accounts of the parent companies need significant comments on the accounting and auditing conditions in the individual subsidiaries referred to.

(4). A copy of the minutes concerning the annual accounts of the company shall be submitted to the Danish financial supervisory authority together with a copy of the annual report approved by the Board of Directors and the Board of Directors approved the consolidated financial statements. Corresponding submitted a copy of the minutes concerning the annual accounts of non-financial subsidiaries with registered office in Denmark. Minutes of meetings, which are submitted to the Danish financial supervisory authority, must be written in Danish or English.

§ 6. Statements in accordance with § § 7-14 and § § 33-47 may be set out in a separate minutes of Audit Protocol referred to as "Minute with FSA specific reporting requirements to the review of the financial statements". This order shall, where appropriate, provisions for the hearing relating to the annual accounts apply mutatis mutandis to this Protocol. The separate minutes must be signed by the same external auditors and audit head, and is issued at the same date as the hearing shall be given in accordance with section 5.

Summaries



§ 7. In a separate section in the minutes relating to the annual accounts to the external review summarize all comments, as the review has given rise to carry over to the Board of Directors. The summary must contain a balance sheet relating to the comments that have been raised relating to the financial year in question, as well as the status relating to the comments that emerged in the hearing concerning the sweet open as previous financial statements, see. Annex 3. If the audit did not give rise to observations, should be disclosed.

(2). In a separate section in the minutes relating to the annual accounts, the external audit of the company represent a compiled list of all orders, which the FSA has issued during the financial year, injunction, which the FSA has issued in the previous fiscal year, but that has not yet been complied with at the end time, and notices, which are complied with in the fiscal year. If no one has cast injunctive relief in the fiscal year, and all orders are complied with at the end of the previous fiscal year, this must also be provided. The external audit shall review the of the company drew up the list and inform about comments, including the auditor's position on compliance with the injunction.

(3). In a separate section in the minutes relating to the annual accounts, the external audit of the company represent a compiled list of all critical and risk information, which the FSA has issued during the financial year. The external auditor shall review the of the company drew up the list and inform about any comments.

General conclusions and information



§ 8. In companies that have internal audit, the audit of the hearing concerning the financial statements be concluded about 1) according to the audit Agreement agreed tasks are completed, as well as whether the effective functioning of internal audit, including whether the external audit has been aware of the facts which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management, and 2) the external audit is in agreement with the contents of all the internal audit Protocol inputs relating to the financial year and if this is not the case, in which disagreement remain.

§ 9. The external audit shall be in a separate section in the minutes relating to the financial statements provide information on the execution of any assistance or advisory role.

(2). The external audit shall in connection with information on any assistance or advisory tasks at a minimum in the minutes concerning the financial statements indicate that the ban on self-review in article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms have been complied with, including the auditor should not carry out tasks pursuant to section 1, paragraph 2, which relates to a company incorporated under the section 21, paragraph 3, in the case of self-review or self-interest. If that hasn't been done assistance or advisory tasks, must be disclosed.
§ 10. The external audit shall be in a separate section in the minutes concerning the financial statements disclose not corrected error. The information must be given per error stating amount and effect on accounting entries. There shall in addition be informed about the cumulative effect of not corrected the error on the result, assets, liabilities and equity. Not corrected error that is clearly insignificant, irrespective of whether they are considered individually or collectively and be assessed by any criterion with regard to the size, nature or circumstance can be omitted from information about the used limit. If all bugs are fixed, or that no errors have been detected during the audit, must be disclosed.

§ 11. The external audit in the hearing concerning the annual accounts give a conclusion about whether the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this connection, the external auditor also conclude whether 1) company's total system, data, and operational safety are and work with integrity, and 2) external audit has been aware of facts which run counter to the requirements of legislation on financial firms and associations, including the section 71 of the financial business Act and the Executive order issued thereunder on the leadership and management of the Foundation and section 35 of the Act on investment associations, etc. and the notice of the direction issued in implementation thereof and management.

§ 12. The external audit in the hearing concerning the financial statements disclose the following related to speculative provisions 1) on the financial corporate guidelines under section 77, paragraph 4, of the financial business act or the Association's guidelines pursuant to section 41, paragraph 4, of the Act on investment associations, etc. are deemed to be reassuring and have functioned appropriately without prejudice. section 77, paragraph 5, of the financial business Act and section 41, paragraph 5, of the Act on investment associations, etc., and 2) concerning the review under section 77, paragraph 5, of the financial business Act and section 41, paragraph 5, of the law on investment funds, etc. have given rise to comments.

§ 13. The external audit in the hearing concerning the annual accounts provide the following regarding intra-group transactions and exposures: 1) conclusion as to whether there are established business practices in order to comply with the provision in section 182 of the financial business Act.

2) Information as to whether there have been found significant errors or omissions in connection with the review of transactions between the company and the companies included in the scope of section 2 of the Ordinance on intragroup transactions, see. § 14, nr. 2, and give a detailed description of the transactions, which are essential or unusual nature.

§ 14. The external audit in the hearing concerning annual accounts give conclusion on the following regarding exposures to related parties: 1) whether the Board of Directors of allocated exposures to and received guarantees from Board members or directors, as well as companies in which these are direct or indirect owners of a qualifying share, directors or members of the Board of Directors, has been granted in accordance with the company's usual business conditions and on market-based terms, see. section 78 (2) of the financial business Act.

2) whether or not the financial entity has involvement with business corporations, where employees of the Board or other employees in the financial business involved in the management or operation of these, see. section 80 (1), (2), and (8) 2. point, in the financial business Act.

Other provisions



§ 15. § 9, paragraph 2, section 11, no. 2, section 12 and section 14 shall not apply to audit minutes for subsidiaries that are not financial institutions, see. section 1, paragraph 1.

§ 16. If the company has an internal audit, which comply with the provisions of Chapter 3, the external audit agreement with the Audit Manager, to the statements in accordance with sections 33 and 34, § 36, § 38, no. 1, §§ 40-42 and section 47 only emerges from the internal audit Protocol. The agreement to that effect should be included in the audit agreement without prejudice. § 24.

Chapter 3 the internal audit section 17. The Board may provide for the establishment of an internal audit, see. However, paragraph 3. If no one has created 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 outsources and insourcer activities. The Board's decision must be made by the Board of Directors ' minute book.

(2). If a Board of Directors in accordance with paragraph 1 provides for the establishment of an internal audit, the provisions concerning the internal audit application.

(3). In companies that in the last two financial years at the balance sheet date in the average has had 125 or more full-time employees, the establishment of an internal audit.

(4). For corporations, paragraphs 1 and 3 apply mutatis mutandis.

(5). The provisions of paragraphs 3 and 4 shall not apply to investment funds, specialist associations, fåmandsforeninger, hedge funds and Danish ship credit a/s.

§ 18. The internal audit function is headed by a head of audit. The recruitment and dismissal of Auditors Chief can only be carried out by the Board of Directors. Appointment and dismissal of the head of the audit may be carried out for the group as a whole.

(2). Audit Manager should have a theoretical training equivalent to what is required to become a chartered or certified accountant.

(3). Audit Manager should know recruitment have attended practical audit work for at least three years within the last 5 years.

(4). The Danish financial supervisory authority may, in exceptional cases, grant derogations from the requirements set out in paragraphs 2 and 3.

§ 19. The Board of Directors may appoint one or more Deputy Auditors managers.

(2). The Board of Directors may appoint a Deputy head, who is deputising for auditors audit the boss.

(3). The provisions of article 18, paragraphs 1 to 4, article 20, paragraphs 1-3, and section 21 concerning audit manager shall apply mutatis mutandis to the Deputy Heads of audit, including delegates.

§ 20. When an audit Chief joins, this must be reported to the FSA within 1 month after accession.

(2). The Board shall, when reporting to the FSA about the recruitment of Audit Manager, see. paragraph 1, submit a declaration to the effect that the audit manager meets the requirements under section 18 (2) and (3).

(3). When an audit Chief resigns, the Board of Directors and Auditors the Chief not later than 1 month after the termination of employment to send every report to the FSA about his background.

(4). In connection with the statement required in paragraph 2 shall notify the Board of Directors, audit manager shall endorse the financial statements in accordance with section 29.

(5). The Board of Directors shall be by amending the decision on whether or not the audit manager shall endorse the financial statements disclose the Danish financial supervisory authority on the subject.

(6). The Board shall by decision to shut down the internal audit function to inform the Danish financial supervisory authority on the subject.

§ 21. Audit Manager should have access to all information, as this consider necessary for audits, including Board Protocol.

(2). Audit Manager and staff in the internal audit shall not engage in other work within the company or group other than auditing, see. Annex 4.

(3). Internal audit must not assume tasks when there are circumstances which are apt to arouse doubts with an informed third party about the internal audit independence.

§ 22. Audit and deputy heads must, see audit. section 77, paragraph 10, of the financial business Act, does not have financial interests in the company or group of companies, as they are employed in.

§ 23. In firms respectively groups which have an internal audit, must be the subject of a functional description, approved by the Board of Directors. Functional description can be drawn up for the group as a whole and be accepted by the individual group companies ' boards. Function description must at least provide for 1) the internal audit General powers, responsibilities and duties, 2) qualifications, 3) how and the extent to which audit manager and the employees of the internal audit is ensured ongoing continuing education, 4) to the recruitment and dismissal of employees of the internal audit shall be made or approved by the head of audit, and that employees ' training must be approved by the Audit Manager, 5) the internal audit budget and that this is approved by the Board of Directors, which shall be set out in a Board minutes, and 6) information about agreements between the company management and the internal audit function to perform specific audit tasks. One-time tasks and duties of a temporary nature only need to be set out in the internal audit Protocol.

(2). The internal audit function should only take on work tasks, see. (1). 1, as it has sufficient competence to perform.

(3). In paragraph 1, no. 6, mentioned tasks must not be used to audit the boss gets into a situation where he or she declares itself, concludes or informs about facts or documents, as the audit manager or the employees of the internal audit function has prepared the basis for.

§ 24. In firms respectively groups which have an internal audit, the audit work carried out in accordance with good accountant practices and in accordance with an agreement between the external auditors review and audit manager. Auditors agreement can be drawn up for the group as a whole. The audit agreement shall contain
1) a general description of what the audit tasks to be performed, and which of these tasks, respectively the external audit and the internal audit, 2) guidelines for cooperation between the external audit and the internal audit function, including the work of the external audit shall 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 auditing of the performed audit.

(2). If the audit manager shall endorse the annual accounts referred to in article 6. Article 20, paragraph 4, and article 29, paragraph 2, it shall be recorded in the audit agreement, to audit the Chief participant in the review of the essential and risky areas. With participation means that the audit manager in these areas performs part of the work in companies where the Audit Manager do not transfer their endorsement on the financial statements alone would be performed by the external audit.

§ 25. In companies that have an audit manager, should this also be audit manager in all the establishments covered by article 1, paragraph 2, that is. whether a financial company or not.

(2). Paragraph 1 shall not apply in cases where the company operated temporarily with a view to the liquidation of prior underwriting exposures or with regard to participation in the restructuring of businesses.

The internal audit Protocol



section 26. For use by the Board of Directors of undertakings established in Denmark, the internal audit shall conduct an audit Protocol. To be in the Protocol sets out the audit carried out during the year, which can form the basis of audit partial conclusions. The Protocol must be presented at any Board meeting, and any protocol injection must be signed by the entire Board of Directors.

(2). In the internal audit concerning the annual accounts must be accounted for minutes on the nature and extent of the audit work performed, including how the internal audit has participated in the review of the essential and risky areas and the conclusion of this.

(3). Audit Manager should present the internal audit plan and audit the financial statements relating to the minute the budget of the internal audit function on the relevant Board meetings.

§ 27. In a separate section in the minutes relating to the annual accounts, the internal audit must summarize all comments, as the review has given rise to carry over to the Board of Directors. The summary must contain a balance sheet relating to the comments that have been raised relating to the financial year in question, as well as the status relating to the comments that emerged in the hearing concerning the sweet open as previous financial statements, see. Annex 3. If the audit did not give rise to observations, should be disclosed.

(2). Audit Manager should, as a minimum, in the minutes relating to the annual accounts in a separate section to inform, to audit the boss has not come up in a situation where he or she declares itself, concludes or informs about facts or documents, as the audit manager or the employees of the internal audit function has prepared the basis for regulation. Article 23, paragraph 3.

(3). In the minutes relating to the annual accounts must indicate whether the internal audit has received all the information that is requested.

(4). section 5, paragraphs 3 and 4, § 6 and § 15 shall apply mutatis mutandis to the internal audit relating to the annual accounts the minute.

Chapter 4 the audit report section 28. The external auditors ' report on the financial statements, the consolidated financial statements and the financial statements of subsidiaries, shall be submitted in accordance with the provisions of the law on the approved Auditors and audit firms, as well as the regulations issued thereunder.

(2). The requirement for endorsement of the subsidiaries ' financial statements only applies if the financial company external audit has been in charge of the review.

section 29. Audit Manager should give an endorsement of the annual accounts, including the consolidated financial statements and financial statements of subsidiaries with registered office in Denmark, if this is selected in accordance with article 20, paragraph 4, of the basic regulation. However, article 25, paragraph 2.

(2). Audit Manager's endorsement means that the review is carried out in accordance with audit agreement without prejudice. § 24.

(3). Such endorsement shall contain a short description of the performed auditing, including the internal audit has participated in the review of the essential and risky areas, as well as conclusion of this. It must be stated separately, if the review includes other than financial statements. Any reservations or additional information must clearly be indicated in the endorsement.

Chapter 5 common provisions section 30. A financial company or an entity within the same group may not grant commitment to or receive collateral from the external audit, the audit manager or Deputy Audit Manager. However, this does not apply to loans granted by a life assurance company in the field of genkøbsværdien of one of the life assurance company issued insurance policy.

section 31. If the external review or internal audit must assume that a financial company does not meet or in the foreseeable future will not be able to meet the requirements for solvency regulation. § § 124-126, of the law on financial business, or capital requirements in § 4, paragraph 10, section 6, paragraph 4, article 7, paragraph 4, article 12, paragraph 2, no. 3 and 4, and § 162 (1) (8). 6, of the Act on investment associations, etc., that person must immediately notify the FSA this.

section 32. By the submission of conclusions and information, see. section 5, paragraphs 3 and 4, § 8, §§ 11-14, 33 and 34, 36, 38 to 42 and 45-47, must be assessed, which of these is appropriate for that company. If a piece of information or a conclusion not to be provided in relation to an undertaking, must be justified in the hearing.

Chapter 6 special provisions for financial institutions section 33. The external audit in the hearing concerning the financial statements and consolidated financial statements: 1) conclusion as to whether the money the Foundation's measurement of loans and guarantees are carried out in accordance with the rules for doing so.

2) Represent one of the Enterprise prepared summary of number of appropriations via the Board of Directors in the financial year, as well as management's comments on the number of post credits. The list shall also contain information on the number of appropriations from the Board in all of the fiscal year.

§ 34. The external audit in the hearing concerning the annual accounts drawn up by the Bank represent a summary of the following exposures from the application of the basic regulation. However, paragraph 5:1) Money the Foundation's 10 largest exposures.

2) Other exposures that exceed 10 percent of the basic capital is calculated according to the rules in section 145 of the financial business Act.

3) Other significant exposures, provided these for money an institution's or auditor's assessment gives rise to the comments of the Board of Directors, for example, due to special risks, big write-downs or other.

(2). The statement referred to in paragraph 1 shall, for each exposure shall contain information about the 1) the exposure size, 2) any communication planned framework for forward transactions and other transactions with derivative financial instruments, 3) inlaid certainties and their estimated value, 4) whether made individual write-down on exposure, 5) whether in the financial year or the preceding two fiscal years have been amortized or depreciated on exposures, 6) the debtor's financial circumstances and 7) management's assessment of the risk of exposure, taking account of all available facts, including whether the management considers the exposure for correctly measured.

(3). The external audit in the hearing concerning the financial statements following the management's assessment of the individual commitment 1) indicate the auditor's overall assessment of the risk to each engagement, taking account of all available facts, and 2) conclude whether or not the individual exposures covered by paragraph 1, is measured correctly.

(4). In groups, see. section 1, paragraph 2, the summary and the information referred to in paragraphs 1 and 2, as well as the auditor's conclusions after paragraph 3 also is provided on a group basis.

(5). The statement referred to in paragraph 1 shall only include exposures to mortgage companies as well as domestic and foreign banks, if special circumstances so dictate.

Chapter 7 special provisions for mortgage companies to section 35. The internal audit shall review 1) new mortgage without State guarantees, in accordance with the Board's instructions to the Executive Board to be granted by the Board, 2) conversions of loans that exceed EUR 10 million. DKK, and 3) other loan cases.

(2). The review of loan cases see. (1). 1-3, must be done partly through an examination of the loan cases where mortgage lending value or the Department's pre-requisites attracting particular interest, in the light of market conditions in the area in question for the General properties of the species concerned, partly by random, representative sample in the paragraph 1 groups.

(3). The audit agreement should include modalities for inspection in accordance with paragraph 1 and for reporting of the results thereof to the Board and management. Reporting to the Board of Directors must, among other things. include an explanation of the sample selection and conclusion on lånesagsgennemgangen as well as a separate exposition of the loan cases where the audit has assessed that the mortgage lending value should have been smaller. Reporting is given in the hearing concerning the annual accounts or be sent to the FSA in copy.

(4). In mortgage credit institutions without internal audit is the responsibility of the tasks under paragraph 1-3 the external audit.
§ 36. The external audit of the financial statements and the consolidated financial statements in respect of the hearing to conclude whether 1) mortgage institution's measurement of lending, including the adjustment of value that takes place as a result of the credit risk, is carried out in accordance with the rules thereof, 2) mortgage Institute provides mortgage loans on the basis of anything other than the issuance of mortgage bonds, covered bonds, covered bonds and other securities, jf. section 1, paragraph 1, of the law on mortgages and mortgage bonds, etc., 3) mortgage Institute uses funds obtained by issuing securities to lending and whether it places excess funds from block emission in accordance with section 20 of the law on mortgages and mortgage bonds, etc., 4) mortgage Institute keeps series reservefondens ' funds separately from the other funds in the Foundation, see. § 26 paragraph 1 of the law on mortgages and mortgage bonds, etc., and 5) mortgage Department can calculate the individual contributor and investors covered assets.

Chapter 8 special provisions for insurance companies section 37. When subsequently used the concepts of insurance company or life insurance company includes these also lateral pension funds.

section 38. The external audit of the financial statements and the consolidated financial statements in respect of the hearing to conclude whether 1) there is a well-founded presumption that the technical provisions are calculated in such a way that, taking into account what is reasonably foreseeable, sufficient to cover all of the company's insurance liabilities at the balance sheet date, but at the same time is not greater than necessary, and (2)) the insurance undertaking complies with the requirements for legislation, investment rules , including information about any comments made after notice of the registration of assets in insurance companies, etc.

(2). The external audit in the hearing concerning the financial statements account for the checks carried out pursuant to section 9, paragraph 2, of the Decree on the registration of assets in direct characters end insurance companies, pension funds, company pension funds interdisciplinary and branches in Denmark by foreign direct characters end insurance companies.

§ 39. The external audit of the financial statements in respect of the hearing to conclude whether the to FSA reported inventories of capital conditions and risks at 31 December 2003. December has been calculated in accordance with the applicable guidelines, see. Guidance for reporting forms for disclosure of capital and risks in life, non-life and reinsurance companies, and occupational pension funds cross-cutting companies.

Chapter 9 special rules for stockbroking firms and investment management companies section 40. The external audit in the minutes concerning the annual accounts of stockbroking companies conclude whether 1) stockbroking company's activities are in line with the company's permission to operate the stockbroking company, see. Annex 4 of the financial business Act, and of the EVS. ownership of shares is in accordance with § 26 (1) of the financial business Act, 2) stockbroking company can calculate the individual contributor and the investor's assets, and 3) covered the stockbroking company if it does not have permission to carry on business for its own account, has placed the company's capital base in line with rule 157 of the financial business Act.

(2). Paragraph 1 shall apply mutatis mutandis to investment management companies, which are allowed under section 10, paragraph 2, of the basic regulation. § 9 (1) of the financial business Act.

Chapter 10 special provisions for investment funds and specialist associations as well as fåmandsforeninger and hedge funds § 41. The external audit in the minutes concerning the annual accounts of investment associations and special associations and fåmandsforeninger conclude whether 1) calculations of emissions-and the redemption price shall be made in accordance with the under section 54, paragraph 3, section 55, paragraph 8, § 187, (3) and § 188, paragraph 5, of the Act on investment associations, etc. issued Executive order, 2) placement rules, see. Chapter 13 and 14 for mutual funds, see. Chapter 15 for special associations and section 1 of fåmandsforeninger of the law on investment funds, etc., are complied with, and (3)) the Association or a branch has been or is under the law's minimum requirements for assets size, see. § 4, paragraph 10, section 6, paragraph 4, and section 162 (1) (8). 6, of the law on investment funds, etc.

§ 42. The external audit in the minutes relating to the annual accounts for hedge funds, which are covered by section 7, paragraph 1, of the law on trusts etc. conclude whether 1) calculations of emissions-and the redemption price shall be made in accordance with in the under section 54, paragraph 3, section 55, paragraph 8, and article 1, paragraph 4, of the Act on investment associations, etc., issued the Executive order, and 2) Association or a Department has been or is under the law's minimum requirements for assets size without prejudice to article. section 7, paragraph 4, of the Act on investment associations, etc.

section 43. In the minutes concerning the annual accounts of investment associations and special associations as well as fåmandsforeninger and hedge funds should not be provided for in section 13 and section 14 referred to conclusions.

Chapter 11-special provisions for securities traders § 44. Securities dealers are financial institutions, mortgage companies, stock brokerage firms and investment management companies which are authorized as a securities dealer under section 9 (1) of the financial business Act, hereinafter referred to as securities traders.

§ 45. The internal audit is required to prepare and implement an audit plan to investigate and evaluate whether securities handler systems, internal control mechanisms and arrangements are appropriate and effective.

(2). Internal audit must, as part of the conduct referred to in paragraph 1, the working acts, review the reporting to the Board of Directors of the compliance function and the risk management function, see. section 6 of the Executive order on the organisational requirements and the conditions for the operation of the company as a securities dealer. Internal audit must, as a minimum, in the audit of the hearing concerning the financial statements reporting on the comments on audit relationship, as the review gives rise to, indicating that adequate arrangements have been made in case of any shortcomings. If the review does not give rise to observations, this must also be reflected in the minutes.

§ 46. If no one has created an internal audit, external audit review reporting to the Board of Directors of the compliance function and the risk management function, see. section 6 of the Executive order on the organisational requirements and the conditions for the operation of the company as a securities dealer. The external audit must, as a minimum, in the audit of the hearing concerning the financial statements reporting on the comments on audit relationship, as the review gives rise to, indicating that adequate arrangements have been made in case of any shortcomings. If the review does not give rise to observations, this must also be reflected in the minutes.

§ 47. The external audit of the financial statements and the consolidated financial statements relating to the minutes conclude whether securities handler comply with the provisions of § 72, paragraphs 1 to 3, of the law on financial business, including to the external audit have not been aware of facts which run counter to the requirements of the Executive order on the organisational requirements and the conditions for the operation of the company as a securities dealer.

Chapter 12 Criminal provisions and the entry into force of section 48. Violation of §§ 2-5, sections 7-14, § 16, 2. paragraph, article 17, paragraphs 1, 2 and 3. paragraphs, and paragraphs 2 and 3, article 18, paragraph 1 1. and 2. paragraphs, and paragraphs 2 and 3, article 19, paragraph 3, §§ 20-24, § 25 (1), sections 26 and 27, article 28, paragraph 1, article 29, paragraphs 1 and 3, § § 30-36, 38-42 and § § § § 45-47 is punishable by a fine.

(2). That can be imposed on companies, etc. (legal persons) criminal liability in accordance with the provisions of the criminal code 5. Chapter.

§ 49. The notice shall enter into force on the 1. September 2013 and has effect for minutes of meetings, audit relating to fiscal years beginning on or after 1. January 2013 or later.

(2). At the same time repealed Executive Order No. 4 of 5. January 2012 on audits in financial firms, etc., as well as financial groups.

(3). The provisions of section 18 (2) and (3) shall apply to persons who join the position of Audit Manager, who is deputising for the head or Deputy Head of Auditors Auditors after the 1. January 1999.

The Danish financial supervisory authority, the 21. August 2013 Ulrik Nødgaard/Mads Mathiassen



Annex 1 Conclusions and information in the audit of the hearing concerning the annual report pursuant to section 2 (4) of the Audit Ordinance to conclusions and information is rendered with the wording, which is clear from the following lists, if they are made without reservation.





 





The shell of the conclusions and information that cannot be made as set out in this annex, clearly, why they have not been able to be made after the wording in this annex, without prejudice to article. § 2.





 





Attention to it by submitting the following conclusions and information must be assessed which of these relevant to the undertaking concerned. If a piece of information or a conclusion not to be provided in relation to an undertaking, must be justified in the agreed minute referred to in article 6. audit of the Executive order on section 32.
 





Next to each of the listed provisions of the Audit Ordinance are listed:





 



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' (E) ' for the information/conclusions, to be provided by the external audit,





 



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' (I) ' for the information/conclusions to be made by internal audit,





 



-





» (E/I) ' for the information/conclusions in the light of the review the agreement can be carried out by either external or internal audit, see. section 16 of the Executive order on Auditors.





 







1. Banks provision of the audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function, including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9, paragraph 2 of the audit notice, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and







-





We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 71 of the financial business Act and the Executive order issued thereunder on the leadership and management of financial institutions and others.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation under section 77, paragraph 4, of the law on financial business is estimated to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 77, paragraph 5, of the financial business Act did not give rise to observations





 





Pursuant to section 13 of the audit notice, we must conclude that:









§ 13, nr. 1 (E)





established business practices in order to comply with the provision of intra-group exposures in § 182 in the financial business Act





 





Pursuant to section 13 of the audit notice, we must inform you that:









§ 13, nr. 2 (E)





There have not been found significant errors or omissions in connection with the review of transactions between the company and the companies included in the scope of section 2 of the Ordinance on intragroup transactions







§ 13, nr. 2 (E)





There is given a detailed description of intragroup transactions, which are essential or unusual species on the page .... 1) pursuant to section 14 of the Audit Ordinance, we must conclude that:









§ 14, nr. 1 (E)





the Board of Directors of allocated exposures to and received guarantees from Board members or directors, as well as companies in which these are directors or members of the Board of Directors, has been granted in accordance with the company's usual business conditions and on market-based terms, see. section 78, paragraph 2, of the law on financial business







§ 14, nr. 2 (E)





the company does not have involvement with business corporations, where employees of the Board or other employees in the financial business involved in the management or operation of these, see. section 80 (1), (2), and (8) 2. paragraph, of the law on financial business





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for.







§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 33 of the audit notice, we must conclude that:









section 33, no. 1 (E/I)





the Institute's measure of lending money and guarantees are carried out in accordance with the rules





 





Pursuant to section 34 of the Audit Ordinance, we must conclude that:









section 34, paragraph 3, nr. 2 (E/I)
ovenstående engagement er målt korrekt2)





 

 







2. Mortgage companies in revision-notice Provision



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including to:





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-





We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 71 of the financial business Act and the Executive order issued thereunder on the leadership and management of financial institutions and others.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation under section 77, paragraph 4, of the law on financial business is estimated to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 77, paragraph 5, of the financial business Act did not give rise to observations





 





Pursuant to section 13 of the audit notice, we must conclude that:









§ 13, nr. 1 (E)





established business practices in order to comply with the provision of intra-group exposures in § 182 in the financial business Act





 





Pursuant to section 13 of the audit notice, we must inform you that:









§ 13, nr. 2 (E)





There have not been found significant errors or omissions in connection with the review of transactions between the company and the companies included in the scope of section 2 of the Ordinance on intragroup transactions







§ 13, nr. 2 (E)





There is given a detailed description of intragroup transactions, which are essential or unusual species on the page ... 1) pursuant to section 14 of the Audit Ordinance, we must conclude that:









§ 14, nr. 1 (E)





the Board of Directors of allocated exposures to and received guarantees from Board members or directors, as well as companies in which these are directors or members of the Board of Directors, has been granted in accordance with the company's usual business conditions and on market-based terms, see. section 78, paragraph 2, of the law on financial business







§ 14, nr. 2 (E)





the company does not have involvement with business corporations, where employees of the Board or other employees in the financial business involved in the management or operation of these, see. section 80 (1), (2), and (8) 2. paragraph, of the law on financial business





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for







§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 36 of the audit notice, we must conclude that:









section 36, nr. 1 (E/I)





mortgage credit institution's measurement of lending, including the adjustment of the measurement that takes place as a result of the credit risk, is carried out in accordance with the rules







section 36, nr. 2 (E/I)





mortgage Foundation does not offer mortgages on the basis of anything other than the issuance of mortgage bonds, covered bonds, covered bonds and other securities, jf. section 1, paragraph 1, of the law on mortgages and mortgage bonds, etc.







section 36, nr. 3 (E/I)





mortgage credit Institute will not use funds obtained from securities issuance for purposes other than lending







section 36, nr. 3 (E/I)





mortgage institution shall then allocate excess funds from block emission in accordance with section 20 of the law on mortgages and mortgage bonds, etc.







section 36, nr. 4 (E/I)
mortgage Foundation keeps series reservefondens ' funds separately from the other funds in the Foundation, see. section 26, paragraph 1, of the law on mortgages and mortgage bonds, etc.







section 36, nr. 5 (E/I)





mortgage Department can calculate the individual contributor and the investor's assets covered





 

 







3. Insurance companies provision of audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-





We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 71 of the financial business Act and the Executive order issued thereunder on the leadership and management of insurance companies and lateral pension funds





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation under section 77, paragraph 4, of the law on financial business is estimated to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 77, paragraph 5, of the financial business Act did not give rise to observations





 





Pursuant to section 13 of the audit notice, we must conclude that:









§ 13, nr. 1 (E)





established business practices in order to comply with the provision of intra-group exposures in § 182 in the financial business Act





 





Pursuant to section 13 of the audit notice, we must inform you that:









§ 13, nr. 2 (E)





There have not been found significant errors or omissions in connection with the review of transactions between the company and the companies included in the scope of section 2 of the Ordinance on intragroup transactions







§ 13, nr. 2 (E)





There is given a detailed description of intragroup transactions, which are essential or unusual species on the page .... 1) pursuant to section 14 of the Audit Ordinance, we must conclude that:









§ 14, nr. 1 (E)





the Board of Directors of allocated exposures to and received guarantees from Board members or directors, as well as companies in which these are directors or members of the Board of Directors, has been granted in accordance with the company's usual business conditions and on market-based terms, see. section 78, paragraph 2, of the law on financial business







§ 14, nr. 2 (E)





the company does not have involvement with business corporations, where employees of the Board or other employees in the financial business involved in the management or operation of these, see. section 80 (1), (2), and (8) 2. paragraph, of the law on financial business





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for







§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 38 of the audit notice, we must conclude that:









§ 38, no. 1 (E/I)





There is a good reason to believe that the technical provisions are calculated in such a way that, taking into account what is reasonably foreseeable, sufficient to cover all the company's insurance liabilities at the balance sheet date, but at the same time is not greater than necessary







§ 38, no. 2 (E)





the insurer meets the requirements according to the law of investment rules. There is given the necessary comments in accordance with the Ordinance on the registration of assets in insurance companies, etc. on the page ... 1) pursuant to section 39 of the audit notice, we must conclude that:
paragraph 39 (E)





the Danish financial supervisory authority reported inventories of capital conditions and risks at 31 December 2003. December has been calculated in accordance with the applicable guidelines, see. guidance for reporting forms for disclosure of capital and risks in life, non-life and reinsurance undertakings, lateral pension funds as well as workers ' compensation companies





 

 







4. the stockbroking companies provision of audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-





We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 71 of the financial business Act and the Executive order issued thereunder on the leadership and management of financial institutions and others.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation under section 77, paragraph 4, of the law on financial business is estimated to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 77, paragraph 5, of the financial business Act did not give rise to observations





 





Pursuant to section 13 of the audit notice, we must conclude that:









§ 13, nr. 1 (E)





established business practices in order to comply with the provision of intra-group exposures in § 182 in the financial business Act





 





Pursuant to section 13 of the audit notice, we must inform you that:









§ 13, nr. 2 (E)





There have not been found significant errors or omissions in connection with the review of transactions between the company and the companies included in the scope of section 2 of the Ordinance on intragroup transactions







§ 13, nr. 2 (E)





There is given a detailed description of intragroup transactions, which are essential or unusual species on the page ... 1) pursuant to section 14 of the Audit Ordinance, we must conclude that:









§ 14, nr. 1 (E)





the Board of Directors of allocated exposures to and received guarantees from Board members or directors, as well as companies in which these are directors or members of the Board of Directors, has been granted in accordance with the company's usual business conditions and on market-based terms, see. section 78, paragraph 2, of the law on financial business







§ 14, nr. 2 (E)





the company does not have involvement with business corporations, where employees of the Board or other employees in the financial business involved in the management or operation of these, see. section 80 (1), (2), and (8) 2. paragraph, of the law on financial business





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for.







§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 40 of the audit notice, we must conclude that:









section 40 (1). 1 (E/I)





stockbroking company's activities are in line with the company's permission to operate the stockbroking company, see. Annex 4 of the financial business Act, and possibly. ownership of shares is in accordance with section 26, paragraph 1 of the financial business Act







section 40 (1). 2 (E/I)





stockbroking company can calculate the individual contributor and the investor's assets covered







section 40 (1). 3 (E/I)





stockbroking company if it does not have permission to carry on business for its own account, has placed the company's capital base in line with rule 157 of the financial business Act





 

 
5. Investment management companies, who alone have permission under section 10, paragraph 2, of the financial business Act provision of the audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-





We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 71 of the financial business Act and the Executive order issued thereunder on the leadership and management of financial institutions and others.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation under section 77, paragraph 4, of the law on financial business is estimated to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 77, paragraph 5, of the financial business Act did not give rise to observations





 





Pursuant to section 13 of the audit notice, we must conclude that:









§ 13, nr. 1 (E)





established business practices in order to comply with the provision of intra-group exposures in § 182 in the financial business Act





 





Pursuant to section 13 of the audit notice, we must inform you that:









§ 13, nr. 2 (E)





There have not been found significant errors or omissions in connection with the review of transactions between the company and the companies included in the scope of section 2 of the Ordinance on intragroup transactions







§ 13, nr. 2 (E)





There is given a detailed description of intragroup transactions, which are essential or unusual species on the page .... 1) pursuant to section 14 of the Audit Ordinance, we must conclude that:









§ 14, nr. 1 (E)





the Board of Directors of allocated exposures to and received guarantees from Board members or directors, as well as companies in which these are directors or members of the Board of Directors, has been granted in accordance with the company's usual business conditions and on market-based terms, see. section 78, paragraph 2, of the law on financial business







§ 14, nr. 2 (E)





the company does not have involvement with business corporations, where employees of the Board or other employees in the financial business involved in the management or operation of these, see. section 80 (1), (2), and (8) 2. paragraph, of the law on financial business





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for







§ 27, paragraph 3 (I)





We have received all the information that is requested





 

 







6. Investment management companies, which are allowed under section 10, paragraph 2, of the basic regulation. § 9 (1) of the financial business Act provision of the audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)
We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-





We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and act with integrity







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 71 of the financial business Act and the Executive order issued thereunder on the leadership and management of financial institutions and others.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation under section 77, paragraph 4, of the law on financial business is estimated to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 77, paragraph 5, of the financial business Act did not give rise to observations





 





Pursuant to section 13 of the audit notice, we must conclude that:









§ 13, nr. 1 (E)





established business practices in order to comply with the provision of intra-group exposures in § 182 in the financial business Act





 





Pursuant to section 13 of the audit notice, we must inform you that:









§ 13, nr. 2 (E)





There have not been found significant errors or omissions in connection with the review of transactions between the company and the companies included in the scope of section 2 of the Ordinance on intragroup transactions







§ 13, nr. 2 (E)





There is given a detailed description of intragroup transactions, which are essential or unusual species on the page ... 1) pursuant to section 14 of the Audit Ordinance, we must conclude that:









§ 14, nr. 1 (E)





the Board of Directors of allocated exposures to and received guarantees from Board members or directors, as well as companies in which these are directors or members of the Board of Directors, has been granted in accordance with the company's usual business conditions and on market-based terms, see. section 78, paragraph 2, of the law on financial business







§ 14, nr. 2 (E)





the company does not have involvement with business corporations, where employees of the Board or other employees in the financial business involved in the management or operation of these, see. section 80 (1), (2), and (8) 2. paragraph, of the law on financial business





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for







§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 40 of the audit notice, we must conclude that:









section 40 (1). 1 (E/I)





investment management company's activities are in line with the company's permission to drive the investment management business







section 40 (1). 2 (E/I)





investment management company can calculate the individual contributor and the investor's assets covered







section 40 (1). 3





investment management company, if it does not have permission to carry on business for its own account, has placed the company's capital base in line with rule 157 of the financial business Act





 

 







7. Mutual funds provision of audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-
We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 35 of the Act on investment associations, etc. and in implementation thereof issued Executive order on leadership, management and administration of mutual funds.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation after § 41, paragraph 4, of the Act on investment associations, etc. are deemed to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 41, paragraph 5, of the law on investment funds, etc. have not given rise to comments





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for.







§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 41 in the audit notice, we must conclude that:









§ 41, nr. 1 (E/I)





calculations of emission and redemption price shall be made in accordance with the under section 54, paragraph 3, and section 55, paragraph 8, of the Act on investment associations, etc. issued Executive order







§ 41, nr. 2 (E/I)





placement rules, see. Chapter 13-14 of the Act on investment associations, etc., are complied







§ 41, nr. 3 (E/I)





Association or a Department does not have been or are under the law's minimum requirements for assets size, see. § 4, paragraph 10, of the Act on investment associations, etc.





 

 







8. Special associations Determination of audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-





We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 35 of the Act on investment associations, etc. and in implementation thereof issued Executive order on leadership, management and administration of mutual funds.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation after § 41, paragraph 4, of the Act on investment associations, etc. are deemed to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 41, paragraph 5, of the law on investment funds, etc. have not given rise to comments





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for
§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 41 in the audit notice, we must inform you that:









§ 41, nr. 1 (E/I)





calculations of emission and redemption price shall be made in accordance with the under section 54, paragraph 3, and section 55, paragraph 8, of the Act on investment associations, etc. issued Executive order







§ 41, nr. 2 (E/I)





placement rules, see. Chapter 15 of the Act on investment associations, etc., are complied







§ 41, nr. 3 (E/I)





Association or a Department does not have been or are under the law's minimum requirements for assets size, see. section 6, paragraph 4, of the Act on investment associations, etc.





 

 







9. Fåmandsforeninger provision of audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the





 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-





We or other people in the audit company has not participated in the drafting of the annual report or other document the Declaration relates.





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 35 of the Act on investment associations, etc. and in implementation thereof issued Executive order on leadership, management and administration of mutual funds.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation after § 41, paragraph 4, of the Act on investment associations, etc. are deemed to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 41, paragraph 5, of the law on investment funds, etc. have not given rise to comments





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for.







§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 41 in the audit notice, we must conclude that:









§ 41, nr. 1 (E/I)





calculations of emission and redemption price shall be made in accordance with the under section 187 (3) of section 188 and paragraph 5, of the Act on investment associations, etc. issued Executive order







§ 41, nr. 2 (E/I)





placement rules, see. Chapter 13-15 and § 161, paragraphs 1 and 2, of the Act on investment associations, etc., are complied







§ 41, nr. 3 (E/I)





Association or a Department does not have been or are under the law's minimum requirements for assets size, see. § 162 (1) (8). 6, of the law on investment funds, etc.





 

 







10. Hedge funds provision of audit notice



 



 





Pursuant to section 8 of the Audit Ordinance, we must conclude that:









§ 8, nr. 1 (E)





According to the audit Agreement agreed tasks, to be performed by internal audit is performed, as well as to the proper functioning of the internal audit function including the external audit have not been aware of the circumstances which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management







§ 8, nr. 2 (E)





We agree with the contents of all the internal audit Protocol inputs relating to the financial year





 





Pursuant to section 9 (2) of the Audit Ordinance, we must inform you that:









§ 9, paragraph 2 (E)





We have complied with the prohibition to carry out assistance and advisory tasks, see. Article 24, paragraph 4, 1. paragraph, of the law on the approved Auditors and audit firms, including the
 



-





We or other people in the Court undertaking did not take part in posting or similar registrations, which forms the basis of the annual report or other conditions made statement and





 



-





We or other people in the audit company has not participated in the drafting of the annual report or other document declaration relates





 





Under section 11 of the audit notice, we must conclude that:









section 11 (E)





the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this context, we also conclude that







§ 11, nr. 1 (E)





-





the company's total system, data, and operational safety are and work with integrity,







§ 11, nr. 2 (E)





-





We have not been aware of facts which run counter to the requirements of the legislation relating to financial services companies, including section 35 of the Act on investment associations, etc. and in implementation thereof issued Executive order on leadership, management and administration of mutual funds.





 





Pursuant to section 12 of the Audit Ordinance, we must inform you that:









§ 12, nr. 1 (E)





the financial company guidelines concerning the verification of compliance with the prohibition of speculation after § 41, paragraph 4, of the Act on investment associations, etc. are deemed to be reassuring and have functioned appropriately







§ 12, nr. 2 (E)





control of compliance with speculative prohibition pursuant to section 41, paragraph 5, of the law on investment funds, etc. have not given rise to comments





 





Pursuant to section 27 of the audit notice, we must inform you that:









§ 27, paragraph 2 (I)





We have not come up in a situation where we declare us or inform you of facts or documents we or staff of the internal audit function has prepared the basis for







§ 27, paragraph 3 (I)





We have received all the information that is requested





 





Pursuant to section 42 of the audit notice, we must conclude that:









§ 42, nr. 1 (E/I)





calculations of emission and redemption price shall be made in accordance with the under section 54, paragraph 3, section 55, paragraph 8, and article 1, paragraph 4, of the Act on investment associations, etc. issued Executive order







§ 42, nr. 2 (E/I)





Association or a Department does not have been or are under the law's minimum requirements for assets size, see. section 7, paragraph 4, of the Act on investment associations, etc.





 

 







11. Securities traders under section 47 of the audit notice, we must conclude that:









section 47 (E/I)





the company complies with the provisions of § 72, paragraphs 1 to 3, of the law on financial business including that we have not been aware of facts which run counter to the requirements of the Executive order on the organisatorske requirements and conditions for the operation of the company as a securities dealer





 



-





We have not been aware of facts which run counter to the requirements of the Executive order on the organisational requirements and the conditions for the operation of the company as a securities dealer









1) please refer to the relevant page numbers in the audit report.

2) refer to section 34 of the Executive order on Auditors, paragraphs 3-5 of the additional requirements in connection with this conclusion.



Annex 2 description of the auditor's work actions this annex provides a description of the actions, etc., are expected to be included in order for the auditor to give the individual conclusions and information in this notice, without prejudice. § 3, 2. point the extent and nature of the work actions, including any additional labour actions that should be taken in order to give the individual conclusions and information after this notice shall be governed by the statutory auditor, taking into account good auditor usage, see. § 3, 1. Pkt. This implies, inter alia, that the Auditor in assessing actions should assess materiality and risk on the territory concerned. The auditor must also assess the need to perform actions in addition to the actions described in this annex. If carried out fewer operations than indicated in this annex, the auditor could justify this on the basis of materiality and risk on the territory concerned.





 





Pursuant to paragraph 5 shall auditor for use by the Board of Directors prepare an audit Protocol. The audit report is issued only to the Board's own use. Application of the concepts in this annex, as normally used in relation to standards on auditing and assurance, as well as references to auditing standards, etc. are solely intended to describe the requirements for work where the nature and scope of the failure.





 





The degree of safety by which the auditor shall make a conclusion shall be determined on the basis of the wording of the conclusion of the order concerned. As a general rule, all conclusions positively formulated, which implies a requirement for high degree of certainty. Each, however, is negatively formulated, for example, section 11, no. 2, which only involves the requirement of limited security. Please refer also to the international auditing standards (ISA) conceptual framework for assurance engagements with security.





 





A conclusion presupposes that the auditor performs a series of actions with a view to obtaining conviction that the subject meets the relevant criteria, shall evaluate the results of the performed actions and finally concludes whether the subject meets the relevant criteria. If the Auditor in the performance of the acts required to provide the individual conclusions, is not in a position to conclude auditor must expand the work, so it is possible to conclude on the subject with the necessary degree of certainty. If the auditor is unable to obtain sufficient and appropriate evidence to conclude that the subject is without significant errors, auditor conclusion subject to formulate them.





 





A enlightenment is characterized by that auditor often may express an opinion on the subject without having carried out separate actions for the purpose of individual information. For example, the information about not corrected errors and information about assistance and other tasks performed by the statutory auditor.





 





Where, in the notice or the annex referred to materiality, this base materiality in relation to the individual area, as the conclusion or the information relates.





 
For certain information and conclusions, for example, in relation to the company's administrative and accounting practices, it may be appropriate to perform labour actions in the course of the financial year. If this is the case, the statutory auditor should consider whether there have been significant changes in the company during the period leading up to the submission of the minute relating to the financial statements.





 







Summaries











The wording of that provision-section 7





"In a separate section in the minutes relating to the annual accounts to the external review summarize all comments, as the review has given rise to carry over to the Board of Directors. The summary must contain a balance sheet relating to the comments that have been raised relating to the financial year in question, as well as the status relating to the comments that emerged in the hearing concerning the sweet open as previous financial statements, see. Annex 3. If the audit did not give rise to observations, should be disclosed.









(2). In a separate section in the minutes relating to the annual accounts, the external auditor of the company represent a compiled list of all orders, which the FSA has issued during the financial year, injunction, which the FSA has issued in the previous fiscal year, but that has not yet been complied with at the end time, and notices, which are complied with in the fiscal year. If no one has cast injunctive relief in the fiscal year, and all orders are complied with at the end of the previous fiscal year, this must also be provided. The external auditor shall review the of the company drew up the list and inform about comments, including the auditor's position on person-acquisition of injunctive relief.









(3). In a separate section in the minutes relating to the annual accounts, the external auditor of the company represent a compiled list of all critical and risk information, which the FSA has issued during the financial year. The external auditor shall review the of the company drew up the list and inform about any comments. ”





 





1.





If the auditor at the time of the hearing concerning the financial statements preparing audit is aware that there is received a report after the end of the financial year, or there is a report on the way from the Danish financial supervisory authority with orders, reprimands or risk information – for example, if there has been held a final meeting with the FSA inspection, but the report has not yet been completed and forwarded to it – should this be noted in the minutes, but/referred to these injunctions , reprimands and risk information is not covered by section 7.





 







Injunctive relief









2.





Management will present a summary of all the injunction, which the FSA has issued during the financial year, injunction, which the FSA has issued in the previous fiscal year, but that has not yet been complied with at the end time, and notices, which are complied with in the fiscal year. The summary is reproduced in the audit report. Management summary contains the indication of whether the rules are deemed to be complied with as well as the detailed reasons for this assessment. Auditor CAPTCHA comments, if the list is incomplete or does not reproduce the received orders correctly, or the specified status concerning compliance not assessed to be in accordance with the facts. Those conditions must therefore be reflected in the protokollatets list, until the after the auditor's assessment may be regarded as complied with.





 





3.





Auditor's review of the statement should include a comparison with the FSA correspondence to the Auditor (completeness).





 





4.





Auditor must review the management indicated the status of enforcement of the injunction, including after trial the evidence of whether the measure meets the individual orders. This can be done by, for example, to verify whether the contents of the policies and business procedures are in accordance with the order, or whether a modified procedure is carried out in practice. There is no detailed description of the Protocol by auditor's actions to ensure compliance.





 





5.





The auditor is not required to obtain expert assistance in the context of the review of orders and their enforcement, why the review will rely on the auditor's knowledge of law and practice.





 







Reprimands and risk information









6.





Management will present a summary of all the reprimands and risk information, which the FSA has issued during the financial year. The summary is reproduced in the audit report.





 

 





7.





Auditor must perform the same work acts concerning completeness of management's overview of reprimands and risk information by management's overview of the injunction. Auditor CAPTCHA comments, if the list is incomplete or does not reproduce the received reprimands and risk information correctly.





 







Conclusions concerning the internal audit







 







The wording of that provision-section 8











"In companies that have internal audit, the audit of the hearing concerning the financial statements, it is concluded, on







 





1)









According to the audit Agreement agreed tasks are completed, as well as whether the effective functioning of internal audit, including whether the external audit has been aware of the facts which, individually or together, has been denied that the internal audit function operates independently of the day-to-day management, and







 





2)









the external audit is in agreement with the contents of all the internal audit Protocol inputs relating to the financial year, and if this is not the case, in which disagreement remain. ”





 

 





8.





Auditor's conclusion about the internal audit shall be granted on the basis of the performed audit of annual accounts, including the auditor's review of minutes from internal audit submitted since the last status review, as well as any review of the work carried out by internal audit, in accordance with article 3. ISA 610.





 







Assistance or advisory tasks







 







The wording of that provision-section 9











"The external audit should be in a separate section in the minutes relating to the financial statements provide information on the execution of any assistance or advisory role.
(2). The external audit shall in connection with information on any assistance or advisory tasks, at least in the minutes concerning the financial statements indicate that the ban on self-review in article 24, paragraph 4, 1. section of the Act on approved Auditors and audit firms have been complied with, including the auditor should not carry out tasks pursuant to section 1, paragraph 2, which relates to a company incorporated under the section 21, paragraph 3, in the case of self-review or self-interest. If that hasn't been done assistance or advisory tasks must be disclosed. "





 







Oplysning om ikke-korrigerede fejl







 







The wording of that provision-section 10











"The external audit should be in a separate section in the minutes concerning the financial statements disclose not corrected error. The information must be given per error stating amount and effect on accounting entries. There shall in addition be informed about the cumulative effect of not corrected the error on the result, assets, liabilities and equity. Not corrected error that is clearly insignificant, irrespective of whether they are considered individually or collectively and be assessed by any criterion with regard to the size, nature or circumstance can be omitted from information about the used limit. If all bugs are fixed, or that no errors have been detected during the audit, must be disclosed. "





 





9.





The auditor must not disclose the errors that have been corrected in the financial statements.





 







The company's administrative and accounting practices







 







The wording of that provision-section 11











"The external audit in the hearing concerning the annual accounts give a conclusion about whether the company's administrative and accounting practice in essential areas, including business processes and internal control mechanisms, is organized and operates with integrity. In this connection, the external auditor also conclude whether 1)









the company's total system, data, and operational safety are and work with integrity,







 





2)









the external audit has been aware of facts which run counter to the requirements of legislation on financial firms and associations, including the section 71 of the financial business Act and the Executive order issued thereunder on the leadership and management of the Foundation and section 35 of the Act on investment associations, etc. and in implementation thereof issued Executive order on leadership and management. "





 





10.





Auditor's weighting of performance in each area as well as choice of audit actions will depend on the auditor's assessment of concrete risks of material errors in the financial statements, including the company's business model and risk regulation. ISA 315.





 

 





11.





In those institutions where there is a requirement for internal audit, the following actions will naturally be carried out by the internal audit and external audit will subject good auditor usage (including special ISA 610) could rely on this by submitting the finding in the audit report. These institutions will have a size, where it would be expected that the scope of any of the following actions will be fairly comprehensive. In departments without requirement for internal audit actions alone will have to be performed by external audit. On the other hand, these institutions have a smaller size and complexity, why the tasks reasonably could be carried out by external audit alone.





 

 





12.





Auditor to be based on the company's business model to identify which areas of the company, where the inherent risk of errors in financial statements is high, and which are considered essential for use in the planning and execution of the audit of the financial statements. The auditor must, in order to identify the essential and risky areas review the corporate risk profile. The auditor shall, in accordance with the Audit Ordinance conduct a review of policies and guidelines, including ensuring that the Board has ensured that these are reasonable in relation to the company's business model. Please refer also to the ISA 315.





 

 





13.





Auditor shall audit planning review management's statement on the company's risks, which produced for the Board of directors pursuant to § 4 paragraph 2 of executive order management for banks, mortgage companies and stockbroking companies, § 4, paragraph 1, of the Management Executive order for insurance companies and lateral pension funds and section 5, paragraph 1, in the notice of special investment funds management and assess whether the auditor finds reporting consistent with the auditor's other knowledge about the Department.





 

 





14.





Auditor must on the essential areas at random after test and assess the internal coherence of practices, business processes and internal control mechanisms, see. sections 15-18 respectively and section 25 of the Ordinance issued under section 71 of the financial business Act (Management Ordinance) for financial institutions and others., sections 15-18, and section 22 of the Ordinance for management insurance companies and lateral pension funds as well as §§ 20-24 and section 28 of the Ordinance for mutual funds management. If the auditor finds significant shortcomings or weaknesses, reported these to the Board of Directors of the Protocol.





 

 





15.





The auditor should assess whether risk management function and the compliance function has the necessary resources to perform tasks safely. The auditor must also assess whether reporting from these two functions is satisfactory, including whether the two functions are separated from each other and from the other functions in the company (if this is required by the law for that company). If the auditor becomes aware of weaknesses in the organization or operation of risk management or compliance function, this must be mentioned in the audit report, as a weakness in this area can have wide-ranging consequences for the company in the long term.





 

 







The administrative practice in the following areas must be reviewed for all company types:









16.





Auditor must review the business processes relating to securities and random verify that transferred control of the company's holdings of securities and the like, including control of valuation, ownership, presence and completeness of an organization's inventory of securities.





 

 





17.





Random auditor must review and assess whether the posting is organised in such a way that it can serve as a basis for accounting reports to be made to the FSA.





 

 





18.





If there is an outsourcing of one or more major areas of activity, the auditor review and assess the extent of outsourcing and ensure that there is follow-up and control with outsourcing.
 

 





19.





In paragraphs 21-33 below are listed the main areas where for individual enterprises, as a minimum, must be assessed and tested business processes and internal control mechanisms.





 

 





20.





The following list of areas is not exhaustive. If a company has other business activities not covered by the under-mentioned, the auditor has to assess whether it is an important area for the undertaking's financial reporting. In the annexes to the management notices there is a detailed specification of what business processes the company shall prepare within the individual areas of activity.





 







For banks, mortgage companies and stockbroking companies will normally be significant the following areas:









21.





Credit area (with the exception of stockbroking companies): the Board of Directors shall, upon a principle of caution adopt a credit policy, see. § 5 (1) (8). 1 and annex 1 of the Executive order management for financial institutions and others. Credit policy must, depending on the business type and size as well as the financial complexity of the company's risky activities contain positions for which the credit risk profile of the Board of Directors wishes that the company must have. For a detailed description of the requirements for the content of the credit policy and business corridors, etc. in this area see annex 1 in management notice for financial institutions and others.





 

 





22.





Market risk area: the Board must adopt a market risk policy, see. § 5 (1) (8). 2, and annex 2 of executive order management for financial institutions and others. By market risks shall mean interest rate, currency, equity and commodity risks, including risks associated with derivative financial instruments, URf.eks. option risks. Interest rate risks include, among other things, interest-rate risks on all on-and off-balance sheet items, including those on fixed-rate funding. Interest rate risks also include interest rate risk structure. For a detailed description of the requirements for the contents of the market risk policy and business corridors, etc. in the area please refer to annex 2 in management notice for financial institutions and others.





 

 





23.





Operational risk: the Board must adopt a policy for operational risk, see. § 5 (1) (8). 3 and annex 3 of executive order management for financial institutions and others. By operational risk means the risk of loss as a result of inappropriate or inadequate internal procedures, human errors and systemic error or as a result of external events, including legal risks. Reputation risk and strategic risk is not considered operational risks management the notice, but shall, to the extent that it is relevant, is treated according to the same guidelines as operational risk. For a detailed description of the requirements for the content of the operational risk policy and business corridors, etc. in the area please refer to annex 3 in management notice for financial institutions and others.





 

 





24.





Insurance covering risks: the Board must adopt a policy of insurance covering risks, see. § 5 (1) (8). 4, in executive order management for financial institutions and others.





 

 





25.





Liquidity: the Board must adopt a policy area for liquidity risks, see. § 5 (1) (8). 5, and annex 4 of the Executive order management for financial institutions and others. By liquidity risk means the risk that the company's costs for liquidity increases disproportionately, to the lack of funding prevents the company from maintaining its current business model, and the company ultimately cannot meet its payment obligations due to lack of funding. For a detailed description of the requirements for the content of the policy on liquidity risks and business corridors, etc. in this area see annex 4 of the Executive order management for financial institutions and others.





 

 





26.





Contingency plans: the Board must adopt contingency plans for other serious disruption, see. § 5 (1) (8). 7, in executive order management for financial institutions and others.





 

 







For insurance companies and lateral pension funds will normally be significant the following areas:









27.





The insurance sector: the Board must adopt a policy of insurance risks, see. § 5 (1) (8). 1 and annex 1 of the notice for the management of insurance companies and lateral pension funds. For a detailed description of the requirements for the content of the policy for the insurance sector and business corridors, etc. in this area see annex 1 in the notice for the management of insurance companies and lateral pension funds.





 

 





28.





Investment area: the Board must adopt a policy for investment area (market, counterparty and credit risks), see. § 5 (1) (8). 2, and annex 2 of the Management Executive order for insurance companies and lateral pension funds. The area includes the investment risks as a result of the evolution of prices, rates, etc. on interest rate, currency, equity and commodity markets (market risks) and risks in companies or groups of companies (credit and counterparty risks) as a result of the company's investments and placement of funds, see. financial business Act § 164. By market risks shall mean interest rate, currency, equity and commodity risks, including risks associated with derivative financial instruments, URf.eks. option risks. Interest rate risks include, among other things, interest-rate risks on all on-and off-balance sheet items, including those on fixed-income deposits and lending and fixed-rate funding. Interest rate risks also include interest rate risk structure. For a detailed description of the requirements for the content of the policy for the investment area and business corridors, etc. in the area please refer to annex 2 in management notice of insurance companies and lateral pension funds.





 

 





29.





Operational risk: the Board must adopt a policy for operational risk, see. § 5 (1) (8). 3 and annex 3 of executive order management for insurance companies and lateral pension funds. By operational risk means the risk of loss as a result of inappropriate or inadequate internal procedures, human errors and systemic error or as a result of external events, including legal risks. Reputation risk and strategic risk is not considered operational risks management the notice, but shall, to the extent that it is relevant, is treated according to the same guidelines as operational risk. For a detailed description of the requirements for the content of the operational risk policy and business corridors, etc. in the area please refer to annex 3 in management notice of insurance companies and lateral pension funds.





 

 





30.





Contingency plans: the Board must adopt contingency plans for other serious disruption, see. § 5 (1) (8). 5, in the notice for the management of insurance companies and lateral pension funds.





 







For mutual funds and investment management companies will normally be significant the following areas:









31.
Operational risk: the Board must adopt a policy for operational risk, see. section 6 (1). 1, and annex 2 of the Management Executive order for mutual funds. By operational risk means the risk of loss as a result of inappropriate or inadequate internal procedures, human errors and systemic error or as a result of external events, including legal risks. Reputation risk and strategic risk is not considered operational risks management the notice, but shall, to the extent that it is relevant, is treated according to the same guidelines as operational risk. For a detailed description of the requirements for the content of the operational risk policy and business corridors, etc. in the area please refer to annex 2 of the Management Executive order for mutual funds.





 

 





32.





Insurance covering risks: the Board must adopt a policy of insurance covering risks, see. section 6 (1). 2, in the notice of special investment funds management.





 

 





33.





Contingency plans: the Board must adopt contingency plans for other serious disruption, see. section 6 (1). 4, in the notice of special investment funds management.





 

 







System-, data-and reliability-section 11, no. 1









34.





The Management Board shall adopt a policy for it security, including an it contingency plan, see. § 5 (1) (8). 6, and annex 5 of executive order management for financial institutions and others., § 5 (1) (8). 4, and annex 4 of the notice for the management of insurance companies and lateral pension funds and section 6 (1). 3 and annex 3 of executive order management for mutual funds. For a detailed description of the requirements for the content of the policy for it security and business corridors, etc. in this area refer to the annexes for management notice.





 

 





35.





At the conclusion of the company's system-, data-and reliability must assess whether the Auditor General it controls in the company can be considered safe, including sample shown after try these as well as review and assess the statements from any system suppliers.





 







Familiar with conditions that are contrary to the requirements of the financial legislation, section 11, no. 2









36.





The background for the relinquishment of this conclusion are the above mentioned labour actions (point 11-35) regarding the administrative and accounting practices as well as auditor's other knowledge about the Department.





 







Speculative provisions







 







The wording of that provision-section 12











"The external audit in the minutes concerning the financial statements disclose the following related to speculative provisions:







 





1)









about the financial business guidelines under section 77, paragraph 4, of the financial business act or the Association's guidelines pursuant to section 41, paragraph 4, of the Act on investment associations, etc. are deemed to be reassuring and have functioned appropriately without prejudice. section 77, paragraph 5, of the financial business Act and section 41, paragraph 5, of the Act on investment associations, etc., and







 





2)









on the review under section 77, paragraph 5, of the financial business Act and section 41, paragraph 5, of the law on investment funds, etc. have given rise to comments. "





 

 





37.





Auditor, who shall ensure the monitoring of compliance with the ban is carried out by (the checks may be carried out by the Board itself or by an independent external party, for example a lawyer or an external auditor different from the elected). The auditor should evaluate whether the reviewer independence of the controlled is reassuring. Auditor finds that this is not the case, the auditor indicate comment to that effect in the audit report.





 

 





38.





Auditor must review the guidelines and the inspection procedures set out therein, including assess whether the guidelines covered persons are relevant and sufficient. The auditor shall make a specific assessment of controls, on the company's guidelines — including the requirement for documentation, IE. inventory listings from banks, copies of the information provided by the tax authorities, etc. – are considered to be reassuring and has been followed.





 

 





39.





The auditor must audit the minutes shall indicate whether the review of the company's guidelines have given rise to comments, and on the company's control on the reports received have given rise to comments. If the auditor is otherwise become aware of facts which run counter to the requirements of section 77 of the financial business Act, shall inform the management board thereof by a remark auditor in the audit of the hearing.





 







Intra-group transactions and intra-group exposures







 







The wording of that provision-section 13











"The external audit in the minutes relating to the annual accounts provide the following regarding intra-group transactions and exposures:







 





1)









Conclusion as to whether there are established business practices in order to comply with the provision in section 182 of the financial business Act.







 





2)









Information about whether there has been found significant errors or omissions in connection with the review of transactions between the company and the companies included in the scope of section 2 of the Ordinance on intragroup transactions, see. § 14, nr. 2, and give a detailed description of the transactions, which are essential or unusual nature. "40. Auditor must ensure that the established procedures and, if necessary, the company has obtained the permission to have intra-group exposures and indicate if the auditor has been familiar with overrun thereof.





 





41. The auditor should review and random verify business processes relating to intra-group exposures and intragroup transactions. After the test, the doctor, taking into account the Group's size organisation, complexity and circumstances, moreover, so as to achieve an appropriate relationship between a possible system-based approach and the random show verification of transactions and exposures.





 







Exposures to related parties







 
The wording of that provision-section 14











"The external audit in the agreed minute relating to annual accounts give conclusion on the following regarding exposures to related parties:







 





1)









Whether the Board appropriated exposures to and received guarantees from Board members or directors, as well as companies in which these is held (directly or indirectly) by a qualified share, directors or members of the Board of Directors, has been granted in accordance with the company's usual business conditions and on market-based terms, see. section 78 (2) of the financial business Act.







 





2)









Whether or not the financial entity has involvement with business corporations, where employees of the Board or other employees in the financial business involved in the management or operation of these, see. section 80 (1), (2), and (8) 2. point, in the financial business Act. "





 

 





42.





To be made to review of all registered exposures and collaterals with related parties (or the largest amount, combined with a representative sample of the rest, if there is a large group with many related parties) in order to assess whether they are licensed in accordance with the company's usual business conditions and on market-based terms.





 

 





43.





In evaluating the usual business conditions and market-based conditions, together with the auditor's experience this auditor from the revision of the financial business, including what other customers in the company would be able to achieve on similar terms. Members of the Board of Directors (which is not the employee elected) and the Executive Board shall not participate in staff approved schemes, see. comments to the financial business Act § 78.





 







Communication from the Commission to the FSA-going concern assumption







 







The wording of that provision-section 31











"If the external review or internal audit must assume that a financial company does not meet or in the foreseeable future will not be able to meet the requirements for solvency regulation. § § 124-126, of the law on financial business, or capital requirements in § 4, paragraph 10, section 6, paragraph 4, article 7, paragraph 4, article 12, paragraph 2, no. 3 and 4, and § 162 (1) (8). 6 of the Act on investment associations, etc., that person must immediately notify the FSA this. "





 





44.





This provision must be seen in connection with the auditor's obligation to, in connection with the submission of the audit report on the financial statements to obtain sufficient and appropriate audit evidence that use of the going concern assumption in the preparation of the financial statements is adequate, and they are working, this might deflect relating to solvency and capital requirements (ISA 570).





 







Declaration of solvency need









45.





The auditor must make an initial assessment of the company's solvency and economic situation. Shall hereafter Auditor on the basis of an assessment of materiality and risk, determine the amount and depth of the acts described in subparagraphs (a) to (d). The starting point is that the auditor must always carry out actions under (a) to (c). Unless the company has a great deal of coverage in relation to solvency requirements, the auditor also should carry out actions under subparagraph (d). The actions described as the following:





 



(a))





Review and assess whether the management set out preconditions for the inventory of the company's solvency needs are documented and justified.





 



(b))





Random verify of the solvency requirement statement is prepared in accordance with the established conditions.





 



(c))





Random verify the solvency requirement statement internal numerical context.





 



(d))





Assess whether the Declaration of solvency needs taking into account the conditions laid down in the Ordinance on capital adequacy article 5, paragraph 1, respectively, the Executive order on solvency and operating plans for the insurance companies section 4 and section 5, paragraph 1.





 







Inventory of assets (mutual funds)









46.





The auditor should review, as a minimum:





 



(a))





Take care of the assets on the balance sheet date is sufficient according to the law on investment funds, etc.





 



(b))





Assess whether the company's portfolio is exposed in such a way that there is a heightened risk that within a foreseeable future will occur substantial loss. An example would be an association/business unit that invests in European government bonds, which goes from having the main emphasis of the property lying in bonds from stable European countries to have the main focus in the more at-risk countries.





 







Banks ' measurement of lending







 







The wording of that provision-section 33











"The external audit in the minutes concerning the financial statements and the consolidated financial statements:







 





1)









Conclude whether the banks ' lending and guarantees made to measurement in accordance with the rules for doing so.







 





2)









Reproduce one of the Enterprise prepared summary of number of appropriations via the Board of Directors in the financial year, as well as management's comments on the number of post credits. The list shall also contain information on the number of appropriations from the Board in all of the fiscal year. "





 

 





47.





To be relating to section 33, no. 1, carried out a review of banking practices and internal controls in this area, just as there must be selected a sample of loans and guarantees, which shall be examined by the auditor. The work done by the auditor shall include review of the approach used by management for the measurement of exposures.





 

 





48.
The Institute's business times respectively for individual and group display impairment, see. section 13 of the Executive order on Auditors also administrative and accounting practices in the credit area, including business processes and internal control mechanisms, must be reviewed in order to assess whether these are organised and acts with integrity.





 

 





49.





For group show impairment should review, as a minimum, consist of:





 



(a))





The management on the basis of the model's estimates relate thereto and shall assess whether there should be attributed to a managerial discretion. This estimate must be documented.





 



(b))





A review of the model for group show impairment, including documentation of the model and the assumptions in the budget.





 



(c))





A random verification of the model's internal numerical context.





 



(d))





A review of backtests on the results, the model previously supplied.





 



(e))





To ensure that the inventory of the group show Downs is duly approved by management





 





50.





For individual impairment losses should review, as a minimum, consist of:





 



(a))





A random verification of the numerical context for selective impairment losses, including about securities is recorded correctly in the depreciation calculation.





 



(b))





Review of the discount model used at Setup and discounting of paylines.





 



(c))





A comparison of previous years ' impairment losses with subsequent periods.





 



(d))





To ensure that essential individual write-downs are duly approved by management.





 





51.





On the basis of the work performed shall be a final assessment of the reasonableness of the company's accounting estimates based on the understanding of the company and its environment and of whether the accounting estimates are consistent with other evidence obtained during the audit.





 





52.





Concerning the revision of the write-downs refer in addition to ISA 540.





 





53.





A version of an overview of the following appropriations (section 33, no. 2) draw the Board's attention on whether the number of after appropriations is reasonable. Management's comments on the number of after appropriations could eg. be of the number raises that management is considering to change something in the appropriations process in the future.





 







Banks ' version of exposures







 







The wording of that provision – section 34 (1)











"The external audit in the minutes relating to the annual accounts drawn up by the Bank represent a summary of the following exposures from the application of the basic regulation. However, paragraph 5:







 





1)









Money the Foundation's 10 largest exposures.







 





2)









Other exposures that exceed 10 percent of the basic capital is calculated according to the rules in section 145 of the financial business Act.







 





3)









Other significant exposures, provided these for money an institution's or auditor's assessment gives rise to the comments of the Board of Directors. For example, due to special risks, big write-downs or other. "





 





54.





Other significant exposures (section 34, paragraph 1, no. 3) is exposures in which the financial institution or the auditor assessed that there is a heightened risk of significant loss. This can for example be exposures, which in the financial year is made relatively large write-downs, or exposures to weakness, where a substantial part of the exposure is not covered by collateral or exposures associated with particularly uncertainty or which are particularly difficult to make calculations on the write-down.





 







The wording of that provision – section 34, paragraph 2











"The statement referred to in paragraph 1 shall, for each exposure shall contain information about the







 





1)









the exposure size,







 





2)









any communication planned framework for forward transactions and other transactions with derivative financial instruments,







 





3)









inlaid certainties and their estimated value,







 





4)









whether any amendment is made to an individual write-down on exposure,







 





5)









whether in the financial year or the preceding two fiscal years have been amortized or depreciated on exposures,







 





6)









the debtor's financial situation, and







 





7)
management's assessment of the risk of exposure, taking account of all available facts, including whether the management considers the exposure for correctly measured. "





 





55.





The provisions concerning the content of management's overview of the Protocol are minimum requirements. The purpose of this provision is that the description should make the Board in a position to be able to assess the individual exposures per the balance sheet date. The description should, therefore, be so complete that the Board can carry out this assessment.





 





56.





Exposures shall be calculated in accordance with the Ordinance on large exposures before deduction of special secure parts and received indemnities, warranties, etc., except that the repurchase transactions is calculated after deduction of received collateral, see. § 145 (4) of the financial business Act. This implies, inter alia, that the statement by the 10 largest exposures must be after write-downs and provisions.





 







The wording of that provision – section 34 (3)











"The external audit in the minutes concerning the financial statements following the management's assessment of the individual commitment







 





1)









indicate the auditor's overall assessment of the risk to each engagement, taking account of all available facts, and







 





2)









conclude whether or not the individual exposures covered by paragraph 1, is measured correctly. "





 





57.





In order to be able to give an overall assessment of the risk to each engagement and in order to be able to conclude whether exposures are measured correctly, Auditor, at a minimum:





 



(a))





Undertake review of documentation prepared by the management of the individual exposures indicated by overview (extract from posting, the write-down charge, information about the customer's financial circumstances, etc.).





 



(b))





Verify management's overview of exposures, as well as ensure the Institute's poll to underlying and underlying documentation for each commitment in the statement.





 



(c))





Assess the risk of individual exposures, including assessing the debtor's financial situation and future ability to pay and the value of any securities.





 



(d))





Assess whether there is an objective indication of impairment.





 







Mortgage lending '







 







The wording of that provision-section 36











"The external audit of the financial statements and the consolidated financial statements in respect of the hearing to conclude whether







 





1)









mortgage credit institution's measurement of lending, including the adjustment of value that takes place as a result of the credit risk, is carried out in accordance with the rules thereof,







 





2)









mortgage Foundation provides mortgage loans on the basis of anything other than the issuance of mortgage bonds, covered bonds, covered bonds and other securities, jf. section 1, paragraph 1, of the law on mortgages and mortgage bonds, etc.,







 





3)









mortgage credit Institute uses funds obtained by issuing securities to lending and whether it places excess funds from block emission in accordance with section 20 of the law on mortgages and mortgage bonds, etc.,







 





4)









mortgage Foundation keeps series reservefondens ' funds separately from the other funds in the Foundation, see. § 26 paragraph 1 of the law on mortgages and mortgage bonds, etc., and







 





5)









mortgage Department can calculate the individual contributor and investors covered assets. "





 





58.





Concerning paragraph 36, nr. 1 whether the mortgage Institute's measure of lending, which audits of the company's controls in the area, like to be selected a sample of exposures are reviewed.





 

 





59.





There should be a review and assessment of the management approach used for the measurement of exposures, including:





 



(a))





The statement method for fair values, including the assumptions that underlie the statements.





 



(b))





Validation of the numerical consistency of the measurements of the exposures.





 



(c))





Comparison of balances relating to write-downs made for previous periods with the actual results for these periods.





 



(d))





Assessment of the management of the used authorization procedure.





 





60.





Moreover, reference is made to ISA 540.





 





61.





Concerning paragraph 36, nr. 2 and 3, the Auditor, at a minimum, review business procedures and established checks within above mentioned areas as well as random testing, to verify and transactions are in accordance with the rules of the time.





 





62.





Concerning paragraph 36, nr. 4 and 5, random auditor review series accounts and registrations thereof, including reviewing the registration of individualization of assets and liabilities, allocation of assets as well as review the distribution of individualised not expenditure and revenue. Furthermore, it should ensure that there is consistency between series accounts and total accounts.
 







Insurance companies ' inventory of technical provisions







 







The wording of section 38-











"The external audit of the financial statements and the consolidated financial statements in respect of the hearing to conclude whether







 





1)









There is a good reason to believe that the technical provisions are calculated in such a way that, taking into account what is reasonably foreseeable, sufficient to cover the company's insurance liabilities at the balance sheet date, but at the same time is not greater than necessary, and







 





2)









the insurance undertaking complies with the requirements according to lovgivnigens investment regulations, including information about any comments made after notice of the registration of assets in insurance companies, etc.







 





(2). The external audit of the Protocol on the financial statements account for the checks carried out pursuant to § 9 (2) of bekendgørelse about registration of assets in direct characters end insurance companies, pension funds, company pension funds interdisciplinary and branches in Denmark by foreign characters end insurance companies. "





 





63.





Technical provisions (§ 38, no. 1) is an area in which the inherent risk is evaluated high, and exercised a substantial degree of discretion, like the accounting entries is significant to the financial statements.





 





64.





In order to be able to give its conclusion on the technical provisions must at a minimum: accountant





 



(a))





Conduct review and assessment of the insurance company's check on the area, including particularly inventories and reporting of technical provisions, and





 



(b))





Assess the need to carry out an independent actuarial valuation of the provision for unearned premiums in selected areas or





 



(c))





Review and assess the approach used for the measurement of the technical provisions including:





 

 



(a).





Identify and validate key controls in appropriate units, including actuarial services, underwriting and claims Department, in order to assess data quality.





 

 



(b).





Assessing the suitability of the methods used, the model used data and documentation of the assumptions underlying the estimates.





 

 



(c).





Random verify calculations on essential areas.





 

 



(d).





Review the insurance company's own process for the inspection of the outcome of the used models comprehensive cause of deviations in the models ' results compared to the realized figures. Auditor's review will be based on an assessment of the Management Board and the Executive Board's guidelines for the area and can URf.eks. include drainage results (back testing) in the form of matching provisions made for previous periods with the actual results for these periods, review of grade calling the company's risk management division as well as used and control models for verification of model results.





 

 



(e).





Assess the management used authorization procedure.





 





65.





If the company has used independent experts when calculating technical provisions, the statutory auditor should assess whether the company has complied with the guidelines for outsourcing, including whether these guidelines and procedures are adequate for the assessment of the above mentioned conditions, as well as the company has the necessary competence to assess the work and conclusions of the independent experts. The auditor must also assess whether the company has business processes and controls in place to ensure that data which are the basis for the independent experts estimating the technical provisions is relevant, useable and without significant errors.





 





66.





In evaluating the adequacy of mathematical provisions must apply employees with relevant insurance technical auditor and actuarial skills. This may be the auditor trained staff who have built up expertise in these areas or employees, there is insurance or actuarial trained.





 





67.





On the basis of the work performed shall be a final assessment of the reasonableness of the company's accounting estimates based on the understanding of the company and its environment, including, for example, where available, independent actuarial reviews, and of whether the accounting estimates are consistent with other evidence obtained during the audit.





 





68.





Moreover, reference is made to ISA 540 and ISA 620.





 





69.





Auditor to be relating to section 38, no. 2, review the Board of Directors approved the business times and established key controls that ensure compliance with investment rules in the financial business Act-including the classification and valuation of assets (including special real estate and structured products). Auditor to be random test controls.





 





70.





In addition, the auditor pursuant to section 9, paragraph 2, of the Decree on the registration of assets make two unannounced inspections a year, where the existence and valuation of the registered assets verified. Be drawn up in accordance with article 8, paragraph 3, of the Ordinance on the registration of assets quarterly statements that the registered assets in relation to the provisions, which the assets will cover, is in accordance with the investment rules in the financial business Act. To be in the court minutes shall be accounted for in accordance with the Ordinance on the registration of assets in direct characters end insurance companies, pension funds, company pension funds interdisciplinary and branches in Denmark by foreign direct characters end insurance companies section 9, paragraph 2, without prejudice to checks carried out. Audit notice section 38, paragraph 2.





 







The insurance company's statement of capital







 







The wording of section 39-
"The external audit in the minutes relating to the annual accounts conclude whether the to FSA reported inventories of capital conditions and risks at 31 December 2003. December has been calculated in accordance with the applicable guidelines, see. Guidance for reporting forms for disclosure of capital and risks in life, non-life and reinsurance companies, and occupational pension funds cross-cutting companies. "





 





71.





Auditor must review the business processes and established controls, dealing with the statement of capital and risk, as well as random verification of the inventory as at 31 December 2003. December, including for life insurance companies to ensure that the statement is made in accordance with the declared basis, etc., see. section 20 of the law on financial business.





 







Stockbroking companies







 







The wording of that provision-section 40











"The external audit in the minutes concerning the annual accounts of stockbroking companies to conclude whether







 





1)









stockbroking company's activities are in line with the company's permission to operate the stockbroking company, see. Annex 4 of the financial business Act, and of the EVS. ownership of shares is in accordance with § 26 (1) of the financial business Act, 2)









stockbroking company can calculate the individual contributor and the investor's assets and covered







 





3)









stockbroking company if it does not have permission to carry on business for its own account, has placed the company's capital base in line with rule 157 of the financial business Act.







 





(2). Paragraph 1 shall apply mutatis mutandis to investment management companies, which are allowed under section 10, paragraph 2, of the basic regulation. § 9 (1) of the financial business Act. "





 

 

 





72.





Regarding paragraph 40, nr. 1, the Auditor based on knowledge of the stockbroking company acquired through the revision of the company's annual accounts to assess whether the services, stockbroking company has delivered, in accordance with annex 4 of the financial business Act. For securities assessed each in relation to section 26 of the financial business Act (authorisation to "other activities"). If the auditor identifies the services which are not covered by Annex 4, this must be mentioned in the audit of the hearing relating to the financial statements. Possessions that are not in accordance with section 26 of the financial business Act, referred to in the audit of the hearing relating to the financial statements.





 





73.





Auditor to be relating to § 40, nr. 2, review business procedures and established controls, which ensures that the stockbroking company can calculate the individual contributor and investors covered assets. The assessment can be carried out as part of the exported it audit. Random auditor must verify the controls and spot checks ensure that covered the assets is calculated in accordance with the applicable rules.





 





74.





Auditor to be relating to § 40, nr. 3, to ensure that the company at 31 December 2003. December does not have placed the company's capital base in other than those referred to in section 157 of the financial business Act listed financial instruments. Auditor shall select two random dates in the financial year in order to check whether the location is in accordance with the provisions of section 157 of the financial business Act.





 







Investment associations and special associations as well as fåmandsforeninger







 







The wording of that provision-section 41











"The external audit in the minutes concerning the annual accounts of investment associations and special associations and fåmandsforeninger conclude whether







 





1)









calculations of emission and redemption price shall be made in accordance with the under section 54, paragraph 3, section 55, paragraph 8, § 187, (3) and § 188, paragraph 5, of the Act on investment associations, etc. issued Executive order,







 





2)









placement rules, see. Chapter 13-14 for mutual funds, see. Chapter 15 for special associations and section 1 of fåmandsforeninger of the law on investment funds, etc., are complied with, and







 





3)









Association or a Department has been or is under the law's minimum requirements for assets size, see. § 4, paragraph 10, section 6, paragraph 4, and section 162 (1) (8). 6, of the Act on investment associations, etc. "







 





75.





Auditor must respect section 41, no. 1 conduct a random review of the calculations of emission and the redemption rates. If the calculation is done in an it system, the sample will display the review could be carried out by a review of the calculations in the it system, where the Auditor in fact regard this as a workable approach.





 





76.





Auditor is that the principles for the estimation of emissions and redemption rates follows the provisions of the Act on investment associations, etc., as well as the under the law issued Executive order on calculation of emission and the redemption rates. In addition, ensure that the emission allowances and redemption deductions approved by the company's Board of Directors.





 





77.





The review will be based on business processes and controls for measurement of securities, etc. as well as procedures for ongoing recognition of the cost of the inventory of the internal value.





 





78.





Auditor must respect section 41, no. 2, make random review of placement rules are respected. The review can be carried out at the end of the fiscal year, as well as by reviewing whether investment management company has proven to have carried out an inspection on an ongoing basis throughout the year. Year-end reviewed the present complianceopfølgning.





 





79.





Professional associations, fåmandsforeninger and hedge funds are not subject to the placement rules in the law on investment funds, etc.





 

 





80.
Auditor must respect section 41, no. 3, carry out random review of whether the Association or a Department has been or is under the law's minimum requirements for assets size. Such inspections may be carried out at the end of the fiscal year, as well as through an examination of whether the investment management company has proven to have carried out an inspection on an ongoing basis throughout the year.





 







Hedegeforeninger







 







The wording of that provision-section 42











"The external audit in the minutes relating to the annual accounts for hedge funds, which are covered by section 7, paragraph 1, of the Act on investment associations, etc. to conclude whether







 





1)









calculations of emission and redemption price shall be made in accordance with in the under section 54, paragraph 3, section 55, paragraph 8, and article 1, paragraph 4, of the Act on investment associations, etc., issued the Executive order, and







 





2)









Association or a Department has been or is under the law's minimum requirements for assets size, see. section 7, paragraph 4, of the Act on investment associations, etc. "







 





81.





Auditor must on § 42, nr. 1 conduct a random review of the calculations of emission and the redemption rates. If the calculation is done in an it system, the sample will display the review could be carried out by a review of the calculations in the it system, where the Auditor in fact regard this as a workable approach.





 





82.





Auditor is that the principles for the estimation of emissions and redemption rates follows the provisions of the Act on investment associations, etc., as well as the under the law issued Executive order on calculation of emission and the redemption rates. In addition, ensure that the emission allowances and redemption deductions approved by the company's Board of Directors.





 





83.





The review will be based on business processes and controls for measurement of securities, etc. as well as procedures for ongoing recognition of the cost of the inventory of the internal value.





 





84.





Auditor must on § 42, nr. 2, make random review of whether the Association or a Department has been or is under the law's minimum requirements for assets size. The review can be carried out at the end of the fiscal year, as well as through an examination of whether the investment management company has proven to have carried out an inspection on an ongoing basis throughout the year.





 







Securities traders







 







The wording of that provision-section 45











"The internal audit is required to prepare and implement an audit plan to investigate and evaluate whether securities handler systems, internal control mechanisms and arrangements are appropriate and effective.





(2). The internal audit as part of the performance of work referred to in paragraph 1, the operations review the reporting to the Board of Directors of the compliance function and the risk management function, see. section 6 of the Executive order on the organisational requirements and the conditions for the operation of the company as a securities dealer. Internal audit must, as a minimum, in the audit of the hearing concerning the financial statements reporting on the comments on audit relationship, as the review gives rise to, indicating that adequate arrangements have been made in case of any shortcomings. If the review does not give rise to observations, this must also be reflected in the minutes. "





 







Bestemmelsens ordlyd - § 46











"If no one has created an internal audit, external audit review reporting to the Board of Directors of the compliance function and the risk management function, see. section 6 of the Executive order on the organisational requirements and the conditions for the operation of the company as a securities dealer. The external audit must, as a minimum, in the audit of the hearing concerning the financial statements reporting on the comments on audit relationship, as the review gives rise to, indicating that adequate arrangements have been made in case of any shortcomings. If the review does not give rise to observations, this must also be reflected in the minutes. "





 







Bestemmelsens ordlyd - § 47











"The external audit in the minutes concerning the financial statements and the consolidated financial statements conclude whether securities handler comply with the provisions of § 72, paragraphs 1 to 3, of the law on financial activities including the external audit have not been aware of facts which run counter to the requirements of the Executive order on the organisational requirements and the conditions for the operation of the business of securities dealer."





 





85.





The background for the relinquishment of this conclusion are all auditor's other labour actions in the review of the financial statements and the auditor's other knowledge about the Department. The auditor must also inform the Protocol here, if identified areas with potential conflicts of interest.













Annex 3 Summary of the comments in the audit of the hearing relating to the financial statements 1.









Clause









The following is a detailed explanation of the content of the provision, including an interpretation of the key words in this provision.





 







1.1









The wording of









The requirement for summary of all the comments stated in section 7, paragraph 1, and article 27, paragraph 1, of the Court of Auditors notice:





 





In a separate section in the minutes concerning the financial statements, the Auditors must (the external audit, respectively, internal audit) summarize all comments, as the review has given rise to carry over to the Board of Directors. The summary must contain a balance sheet relating to the comments that have been raised relating to the financial year in question, as well as the status relating to the comments, which appeared in the minutes concerning the sweet open as previous annual report.





 







1.2









The requirement for a separate section









The requirement for a separate section on comments is indispensable. It will say that the separate section on comments must always be included, regardless of whether there is a comment or not. This applies both in the external audit and internal audit in the minutes.





 
If the external audit is in agreement with the contents of the internal audit protokollat1), it is sufficient that any comments only reflected in the internal audit minutes. Where appropriate, the separate parts of the external audit institutions indicate that the comments reflected in the internal audit minutes. Certain conditions, however, is of such a nature that they should be discussed in the external audit as well as the internal audit minutes, URf.eks. conditions that result in reservations and/or additional information in the audit report.





 





The separate section should be placed in a location where it is easy to find, and must be marked with a heading that makes it clear where the comments are summarized. If a table of contents for audit of the hearing to the annual report, paragraph's placement must be apparent thereof.





 







1.3









The requirement for summary









The idea behind this provision is to provide an overview. A summary (in a few lines) of each of the raised arguments are therefore better than a repeat of the entire description. The actual problem must be stated in the summary. Several comments regarding the same should also be written together, where appropriate, URf.eks. It may be appropriate to compile several comments on the business of lending to one point.





 





The summary of observations must be made at company level. For groups with must there also included remarks from subsidiaries which are relevant assessed at group level, see. § 5, paragraph 3 of the Audit Ordinance.





 







1.4









The requirement for all comments









All-all without exception-the in-form audit report raised arguments should be summarized in the separate parts of the hearing relating to the financial statements.





 





There cannot therefore be brought a materiality assessment for the purpose of determining whether a note should be added up.





 





A relationship that once in the audit report is made as a comment, be included in future in the annual summary of comments in the audit of the hearing to the financial statements. Thus, it is not sufficient that an audit of the minutes in the course of the year, it emerges that a point had been clarified. It shall also be indicated in the next annual summary. Only then deleted the comment of the future annual summaries.





 







1.5









Notes vs. comments









A comment is to be understood as auditor's observation that a relationship is not in accordance with the relevant agreements or regler2), standards (including ' good usage '), which may be in force for the area in question. A comment may also include a relationship as auditor during use of her professional experience did not find appropriate, without that relationship, however, is in violation of specific rules, agreements or standards.





 





A comment is to be understood as auditor's supplementary information regarding a given relationship.





 





Comments are therefore not the same as comments. A comment function is to draw the Board's attention to the fact that is not in accordance with the rules, etc., or that are not appropriate. A comment function, on the other hand, is only to clarify a fact that did not give rise to observations.





 





Another difference between a comment and a comment is that a comment relates to a relationship that is overcome.





 





The following conditions will typically give rise to comments of relevance to the Board:





 



-





overshoot of the solvency limits, exposure limits, mortgage lending limits, violation of provisions, speculative overshoot bin boundaries, failure to comply with the Act's minimum requirements for assets size/capital requirement, etc.,





 



-





failure to comply with the obligations of the Board of Directors of the iht. corporate law, financial business Act and the specific sectoral laws, accounting law, financial statements,





 



-





breach of reporting requirements for the FSA,





 



-





andre lovovertrædelser,3)





 



-





the conclusions required by the FSA/information in the audit of the hearing, which the auditor has notes to,





 



-





conditions that result in reservations and/or additional information in the audit report,





 



-





business processes, where there is a pronounced need to strengthen the internal controls (without affecting the information that business corridors are reassuring),





 



-





overshoot of the of the Board of directors laid lines/guidelines, and





 



-





systems, internal control mechanisms or arrangements that are not appropriate and/or effective regulation. section 45 (1) of the Audit Ordinance.





 





It must be stressed that the above list is not exhaustive, but only a number of examples of relevant types of comments.





 







1.6









The requirement to give a status







 

 





In the provisions required to be granted a status of





 



-





the comments that have been raised relating to the financial year in question, and





 



-





the comments appeared as sweet open in the hearing relating to the previous annual report.





 





Comments that have been made in the current fiscal year, include comments in the minutes of meetings during the year as well as of the hearing relating to the annual report. What matters is whether the note is raised as part of the review relating to the financial year in question.

Status shall bear a reference to the pages where comments have been discussed in the relevant minutes concerning the annual report, or references to protokollaterne relating to the previous annual reports, if it is not the first time the comment referred to.

Comments can have two types of status-resolved or not.





 
Clarified comments







 





Comments can be resolved in one of two ways:





 



-





the relationship is no longer relevant, or





 



-





the ratio is fixed





 





Comments that have lost their relevance, can URf.eks. be notes about problems with the calculation of value adjustments on securities in a fund system, which fund the system subsequently has been replaced with a new fund system that can calculate the value adjustments correctly. Further include comments regarding a specific violation of the rules, there is no speculative expression of poor internal controls. Cases of fraud are also examples of comments that mentioned once and then lose their relevance.





 





Comments that have been remedied, may URf.eks. be comments on lack of forretningsgangs description, which subsequently is drawn up.





 





For each of the clarified comments must indicate how the relationship is resolved.





 







Sweet open comments







 





Comments that are not eliminated, is inherently sweet open. For each of the sweet open comments must indicate, at which point the management expects that the relationship is resolved. If the relationship is partly remedied, this must also be reflected in. Furthermore, it should be reflected in the status, if the expected remediation time changes along the way.





 





Since the review is carried out, taking into account, among other things, the company's internal control environment, it is appropriate that the Auditor verifies whether previously raised arguments are clarified. The review is conducted on the basis of an assessment of materiality and risk, why that, among other things, made use of a system of rotation, so that there are longer between review of areas that are less essential and risky than areas that are essential and risky. Auditor will at the latest should relate to earlier raised arguments when the review next time include the area to which the comment applies.





 





Information about how the individual comments are clarified or resolved, therefore, is not expected to be part of the review, and information on this matter can therefore be based on the information received by the management (Organization).





 





If the auditor's professional scepticism means that the auditor has reason to doubt the enlightened, the auditor verify the validity of enlightenment.





 





Auditor during his revision becomes aware that the information provided by the management (Organization) on the clarification of comments is misleading or erroneous, the accountant do the Board alerted the audit Protocol.





 





If the Auditor, incidentally, become aware of conditions that should be remedied, but has not yet been the auditor must examine that area the following year. Relate comment central conditions for the presentation of accounts, re-examine the audit plan and the auditor must, where necessary, carry out compensatory audit work for this year.





 







2. Examples below are shown two examples that illustrate how the Auditor can summarize his remarks in such a way that they meet the requirements of the Audit Ordinance. The first model can be used in cases where the external auditing refers to the internal audit observations. The second model shows how the separate section on comments can be designed.





 







Example 1











X. Summary of comments ' pursuant to the Audit Ordinance must review in a separate section of the annual report and the consolidated financial statements, the audit of the hearing to summarize all comments, as the review has given rise to carry over to the Board of Directors. The summary must contain a balance sheet relating to the comments that have been raised relating to the financial year in question, as well as the status relating to the comments, which appeared in the hearing concerning sweet open as the previous financial year.







It has been agreed with the internal audit, that the summary in accordance with the notice alone is demonstrated by internal audit Audit audit minutes, to which we refer.

We have no further comments. "





 







Example 2











X. Summary of comments ' pursuant to the Audit Ordinance must review in a separate section of the annual report and the consolidated financial statements, the audit of the hearing to summarize all comments, as the review has given rise to carry over to the Board of Directors. The summary must contain a balance sheet relating to the comments that have been raised relating to the financial year in question, as well as the status relating to the comments, which appeared in the hearing concerning sweet open as the previous financial year.







Comments that have been clarified in the fiscal year 20xx, is tagged with A, and entries open standing, is tagged with Å. The listed page references refer to the pages in the audit report, which comments have been addressed. In those cases where it is not the first time the remark referred to, reference also includes references to the minutes of meetings relating to previous annual reports in addition to the reference to the minutes relating to the financial year in question.







Unless otherwise provided, we have not verified information about whether comments are rectified/under remediation.





 







Speculative rules (A-page xxx)



The ban on .... has been violated in two cases. According to the enlightened ... ... ...





 







Lending area (z-page xxx, page xxx)









There is a general need to update forretningsgangs descriptions so that they correspond to the actual-and, in fact, reassuring-business times. According to the reported, will be updated in the course descriptions of forretningsgangs xxxxx-simultaneously with the implementation of the new xxx-system.





 







Securities field (Å – page xxx, page xxx and A – z – page xxx)









We have found that on stock area has been problems in connection with the vote of the foreign securities. Launched action to strengthen the internal controls in connection with the restatement of foreign securities, and according to the expected work carried out during the autumn of 20xx.





 





We have found that the Board's instructions now contains a description of the products front-office must act, as well as requirements for the management of market risks.

Absence of an up-to-date register of shareholders in accordance with section 50 of the Danish companies act. We have been informed that an updated register of shareholders will be presented at the Board meeting the x March 20xx.





 







It-application (Å – page xxx)
There is a need for the establishment of a contingency plan for the servers that run the Internet Bank operation. Management has prepared an action plan for improving disaster preparedness, which is expected to be implemented in 1. quarter 20xx.





 







Intra-group transactions (A – page xxx, page xxx and A – z – page xxx)



In the year 20xx portfolio 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 guidelines approved by the Board of Directors.





 





The agreement with xxxxx, which was put into effect without the formal approval of the Executive Board. We have found that the agreement has now been approved by the Executive Board.





 





Payment of commissions is done on the basis of an agreement with yyyyy, are not updated. We have subsequently found that an updating of the agreements relating to commissions has been initiated and is expected to be completed in the second quarter 20xx. "









1) There is a requirement for external audit in its minutes to the financial statements should disclose, whether external audit is in agreement with the contents of the internal audit Protocol, see. § 8 nr. of the Audit Ordinance.

2) including special requirements from URf.eks. the Board of directors or the shareholders.

3) as the auditor's performance is done in order to deliver an Auditors ' report on the annual accounts, the auditor only rarely encounter violations of law other than corporate law, tax law and sector-specific laws. However, the auditor must audit the minutes shall disclose violations of any law to the extent that the auditor becomes aware of this.



Annex 4 internal audit tasks and behaviour Which is in the Audit Ordinance provided a framework within which, the internal audit function must perform tasks.





 





The purpose is to ensure the independence of the internal audit activities, which are audited.

In the following sections 1 outlined the conditions that internal audit should be aware of before a task is taken. Then there is section 2 provided a number of examples of tasks which the internal audit can respectively cannot perform.





 







1.









Provisions of audit notice







 

 







1.1









Only audit









Under section 21 (2) of the Audit Ordinance



 











must audit the head and employees of the internal audit function cannot participate in other work within the company or group than revision.





 

 







1.2









Independence









Pursuant to section 21 (3) of the Audit Ordinance



 











internal audit must not assume tasks when there are circumstances which are apt to arouse doubts with an informed third party about the internal audit independence.





 

 





It is clear from article 23, paragraph 3, of the audit notice



 











Audit tasks must not cause the audit Chief comes in a situation where he or she declares herself or inform you of facts or documents, as the audit manager or the employees of the internal audit function has prepared the basis for.





 

 





Provisions to ensure the internal audit independence. Audit Manager performs tasks according to the Audit Ordinance and also endorse the annual report, if this is selected by the Board of Directors.





 





The internal audit function must therefore always upholding its independence, like external audit must safeguard its independence. The internal audit function, however, has a slightly different starting point for its independence, due to its particular role in the financial business.





 





Internal audit must, in order to safeguard its independence, always be aware of the fact that the audit manager and the employees of the internal audit function:













have a duty to identify and assess the circumstances and relationships that create threats to independence, and prove that they have arranged for this













take the necessary steps to eliminate those threats or reduce them to an acceptable level through the application of security measures, in so far as this is possible given that the starting point is that they are employed in the company and













must not perform audit missions, which causes the emergence of circumstances which are apt to arouse doubts with an informed third party about the internal audit independence.





 

 







1.3









Sufficient competence







 

 





In addition, the internal audit function, see. Article 23, paragraph 2 of the audit notice







-





alone must assume the functions which it has sufficient competence to perform.





 

 





The following is the definition of which tasks are carried out in accordance with the provisions of the audit manager and staff in the internal audit, deepened.





 







2.









Examples of workspaces for internal audit







 







2.1









Financial audit and review









Financial audit and review includes review and review of historical financial information, including annual reports, interim reports, etc. work includes a review and evaluation of the business processes as well as the manual and system-based controls that relate to the making of the historic financial information.





 





Internal audit tasks include-depending on the level of competence and of whether it is selected, the internal audit shall endorse the annual report or not, such as:













revision and submission of Auditors ' report on the annual reports,













review of period reports








submission of declarations, information and information in accordance with the Danish financial business Act and the audit notice,













submission of statements against public authorities,













assistance for external audit in connection with the issuance of subordinated capital and offering of shares













assessment of whether procedures and internal controls meet the section 71 of the Act on financial business with accompanying notice and













assistance with due-diligence for the purchase/sale of business.





 





In most cases, the key task for internal audit be participation in the financial review.





 

 





However, more and more often, it can be seen that internal audit focus to a greater extent directed against the operational audit, see. the reference below, IE. that internal audit's involvement in the financial audit of the annual report be deselected or reduced.





 

 





If the audit manager shall endorse the annual report, audit manager must participate in the review of the essential and risky areas, see. section 24 (2) of the Audit Ordinance. Assessment of which areas are significant and risky, is done in accordance with the guidelines of the ISA 315 and will depend on the type and complexity of each company.





 

 





In credit institutions will URf.eks. lending, fees, commercial inventory, property, unlisted equity securities and derivative financial instruments, as well as liabilities as URf.eks. pension obligations and guarantees as a starting point would be essential as well as risky, inter alia. because of complex rules, use of models, compliance with placement rules and statement of solvency.





 

 





In insurance companies will URf.eks. premium income, replacement costs/insurance benefits as well as the return on investment is considered as essential and risky. Also the associated investment assets and provisions for insurance and investment contracts, as well as reinsurance and derivative financial instruments are usually significant and risky areas.





 





Annual report content, including management report, accounts/consolidated accounts, 5-year view, and notes, as well as accounting practices, be considered in all cases as being essential and risky.





 

 





The above examples for each of the types of company are only meant as inspiration, since in all cases to be made a specific and individual assessment of which documented significant and high-risk areas that are associated with the individual business activity.





 

 





The internal audit as part of the review may not assume tasks when there are circumstances which are apt to arouse doubts with an informed third party about the internal audit independence.





 

 





In the performance of the financial audit, the internal audit, for example, must not:













help to make decisions or take responsibility,





 



carry out the control tasks – be a part of the internal control,













compile or run the annual report or other statements of historical financial information,













post or otherwise register,













participate in the recruitment of employees to the company, except for recruitment of employees for the internal audit function,













Manage salaries, real estate, remodeling or similar or













assigning payments or be procuration gardens for the financial business on matters other than those relating to costs related to the internal audit.





 

 





This applies regardless of whether the audit manager shall endorse the annual report or not.





 

 





The mentioned tasks are not reviewed, see. section 21 (2) of the Audit Ordinance, like internal audit will come into conflict with the ban on self-review by performing the tasks referred to in annex IX. section 23 (3) of the Audit Ordinance.





 





In internal audit undertake tasks that are not mentioned in the description, or where the function to be used a larger number, audit manager Board of Directors ' Audit Committee acceptance or a possible catch up before the task is taken.





 







2.2









Operational audit









Operational review involves an assessment of the company's processes with the aim to test and report whether they are in accordance with the objectives set by the management.





 

 





Operational audit involves depending on the company's activity and size, among other things. a process review with a focus on efficiency, an assessment of the reliability of the financial and operational reporting, compliance with laws and regulations as well as protection of the company's values. Investigation of fraud may be included.





 

 





The internal audit, for example, must not:













help to make decisions or take responsibility,













carry out the control tasks – be a part of the internal control,













responsible for the implementation of the amended operating routines, including efficiency measures and rationalizations,













responsible for the preparation of the daily monitoring and reporting of corrective action,













participate in the setting of the operational objectives,













decide or be responsible for execution of sanctions at the uncovered fraud or













lay down or stand for the preparation of operational strategies and processes.





 





The extent of the operational review agreed with the Management Board in the function description, however, so that the agreed tasks are kept within the framework of the Audit Ordinance.





 

 







2.3
Review of risk management









Financial firms are exposed to different risk types. The main types of risks are credit risk, market risk, liquidity risk, operational risk and business risk. The revision includes the established risk management within the individual risk types, including the stipulated limits and the established reporting structure.





 





Internal audit must assess whether the established policies is located inside the framework of the financial business Act and related regulations and guidelines. Internal audit cannot assume supervisory responsibilities, thus internal audit will be part of the internal control system.





 





For example, the development of risk management strategies to the Management Board for approval, as well as the setting of the level of risk typical management tasks, which therefore cannot be carried out by the internal audit.





 





Internal audit cannot assume the development and control tasks related to individual risk types, since the internal audit will be able to get in a situation where it must declare themselves about tasks, as it has itself contributed in preparing.





 





As a starting point, there is nothing to prevent internal audit acts as the independent entity in relation to annex 1, nr. 89 to the Ordinance on capital adequacy, if the internal audit is independent, and it is not in 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 not established, is responsible for the day-to-day management to deal with any compliance risks and appoint another entity that is responsible for carrying out the necessary checks.





 





Internal audit shall, on the basis of materiality and risk, review, and assess whether they are in the company of established processes for dealing with compliance function's activities is reassuring. Internal audit cannot carry out compliance function, or parts thereof, as this is not incompatible with the audit engagement (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 seen as an audit assignment, must explicitly appear in the function description.





 





It does not however apply to audit work on the submission of conclusions and information under the Audit Ordinance, which does not relate to the approval of the annual report.





 

 







3.









Behaviour









Audit managers, Deputy Heads and employees of the audit, the internal audit shall abide by the following ethical principles in such a way that both the individual auditor as the Department is not affected negatively.





 







Integrity



Auditor must be fair and honest in all professional and commercial links.





 







Objectivity



The auditor must not be biased, have conflicts of interest or be under undue influence of others so that the professional and business judgment is suppressed.





 







Professional competence and due care



Auditor is obligated to maintain its professional knowledge and skills at a level that is necessary to ensure the provision of a qualified professional performance based on an up-to-date knowledge of the latest developments in good practice, legislation and practices. Auditor by the delivery of professional services must act carefully and in accordance with relevant academic and professional standards.





 







Confidentiality



Auditor must respect the confidentiality of information obtained in the context of the employment relationship, and shall not disclose such information to third parties without proper and specific permission to do so, unless there is a legal or professional right or duty to do so. Confidential information obtained in the context of the employment relationship may not be used to obtain personal benefit of auditor or other third parties.





 







Professional conduct



The auditor must comply with relevant legislation and other regulations and avoid any behaviour which may discredit the internal and external audit.





 





Further inspiration can be retrieved in the IFAC Code of Ethics» Code of Etics for Professional Accountants ', located on the IFAC website (www.ifac.org) or IIA's code of ethics, which is on the IIA's website (URwww.theiia.org). The code of ethics is published also by FSR in an Edition adapted to Danish conditions.









Official notes 1) Ordinance contains provisions that implement Commission Directive 2006/73/EC of 10. August 2006 on the implementation of European Parliament and Council Directive 2004/39/EC as regards organisational requirements and operating conditions for investment firms, as well as definitions of terms for the purposes of that directive, the EC Official Journal 2006, nr. L 241, p. 26.

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