ACCA考试09年6月P1试题答案五
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（e） Letter to Mrs Keefer
Shalala Pension Fund
Spanner Street
Big City
8 June 2009
Global-bank
16 St Thomas‘s Doubt
London
WC2T 8XX
Dear Mrs Keefer，
Internal control issues within Global-bank
I have been asked by the trustees of the Shalala Pension Fund to convey our expectations of you in respect of your roles and responsibilities in internal controls. We very much regret the circumstances that have made this reminder necessary. In line with the COSO recommendations，the trustees of the Shalala Pension Fund expect you to adopt four major responsibilities in respect of overseeing internal controls in Global-bank.
At the outset，the trustees of the Shalala Pension Fund would like to express their disappointment that you should suggest，as you did at the recent EGM，that the loss incurred by Mr Mineta was ‘genuinely unforeseeable’.From our reading of the situation，you are highly complicit in the loss through your failure in respect of the company’s internal controls.
Ultimately，it is the chief executive of any organisation who must assume final responsibility for all internal controls. It is you as CEO who must assume ‘ownership’ of the systems and this ownership must be a part of the manner in which you lead the company. In particular，this means that you must set the tone from the top in both establishing and enforcing the control environment. We understand that a number of failures to return compliance information from Philos were not acted upon and this is a clear failure on head office’s part to enforce the internal control environment throughout the company. The control environment is enforced through having internal control compliance embedded within the culture of the company and it was，in our view，clearly your responsibility to facilitate this. From what we can gather，the culture in the Philos office was more driven by Mr Evora’s personality than by your imposition of norms from head office and this was clearly one of the causes of Mr Mineta’s behaviour.
This setting of the tone should express itself in terms of the way that managers are treated and the way that the tone is cascaded down through the company including to individual branch offices such as Philos and other subsidiary companies if relevant. It seems self-evident，in hindsight，that the Philos office felt they could act in breach of the relevant internal controls with impunity and this most certainly should not have been allowed. Finally， as major shareholders in Global-bank，the Shalala trustees expect you to pay particular attention to those areas most vulnerable or open to damaging breaches. The financial products being traded at Philos clearly fit into this in our view as the company has demonstrated its vulnerability to losses on derivatives trading when inadequately controlled.
In addition，I have been asked in particular to draw your attention to the failure of the company to operate an effective internal audit function. We understand that the audit committee has been compromised by a shortage of members to the point that its reporting was criticised by the external auditors. The Shalala Pension Fund considers the internal audit function to be an imperative part of the governance structure and we are disappointed that you have seemingly failed to give it the priority it clearly deserves. We trust that recent events have reinforced this importance to yourself and other members of the Global-bank board.
I would emphasise again the seriousness with which the trustees of the Shalala Pension Fund view your management failures in this unhappy episode and we look forward to hearing your considered responses to the points made.
Yours sincerely，
M. Haber.
On behalf of Shalala Pension Fund.
[Tutorial note：underlined points are the CEO’s responsibilities；italicised points are the criticisms of Mrs Keefer. Allow for a range of ways of expressing these points.]
