Evaluation of Internal Control Structure: Evidence From Six Listed Private Banks in Bangladesh
Evaluation of Internal Control Structure: Evidence From Six Listed Private Banks in Bangladesh
Evaluation of Internal Control Structure: Evidence From Six Listed Private Banks in Bangladesh
1. Introduction:
Private banking sector is getting increasing attention due to its significant stands in the
financial system of Bangladesh. It plays a crucial role for the development and growth of
the economy. For achievement of proper operational goals and provides reliable and
relevant information, compliance with laws and regulations, Internal Control Structure is
highly important. Considering this importance, we have made an attempt to evaluate the
Internal Control Structure in the listed local private banks and the extent of achievement
of corporate goal by applying different Internal Control techniques. This study mainly
focuses on the evaluation of the internal control structure in local listed private banks. The
present study covers the extent of implementation of internal control structure techniques.
Committee of Sponsoring Organizations of the Tread way Commission (COSCO)s
landmark study titled Internal Control- Integrated Framework is widely used and accepted
by the major U.S Accounting Bodies as the authority on internal controls. The Study
defined internal control structure as a system, structure, or process, implemented by a
firms board of directors, management and other personnel, intended to provide reasonable
assurance about achieving control objectives in the following categories: 1. Effectiveness
and efficiency of operations, 2. Reliability of financial reporting, and 3. Compliance with
applicable laws and regulations.
At the organization level, internal control objectives relate to the reliability of financial
reporting, timely feedback on the achievement of operational or strategic goals and
compliance with laws and regulations. At the specific transactions level, internal control
refers to the actions taken to achieve a specific objective (e.g., how to ensure
organizations payments to third parties are for valid services rendered).
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model mentioned but did not evaluate the control environment and the accounting
information system elements and was deemed too narrow in focus.
Ouchi (1979) argues that design of organizational control mechanisms focuses on
achieving cooperation among individuals having divergent objectives. Goal congruity is a
central mechanism of control in an organization (Ouchi, 1980)
Research in informal controls targeted at the business process level of the organization
include informal responsibility and accountability expectations (Pierce et al, 2001;
Dhillon, 2001), power and politics issues in security decision making.
Anderson and Dekker(2005), Anderson et al. (2000); Chirst et al. (2005); Coletti et al.
(2005) attempted to provide initial evidence on the relationship between transaction
characteristics, the design of inter-organizational control practices and the performance
achieved under alternative control design choices. They found that all the components
have the impact on the pervasiveness and magnitude of the risk management and control
problems in a large cross section of firms.
2.1 Findings from Earlier Studies
Bangladesh is an emerging economy. Internal control and its impact on the corporate
governance systems here are arguably less evolved than those in developed countries such
as the Anglo-American countries, Germany, or Japan. Emerging markets as a whole differ
substantially from developed countries in their institutional, regulatory and legal
environments (Prowse,1999). In Bangladesh analysis on the performances of the banks
has pointed out that an effective internal control system could have contributed
significantly in improving the performance of the commercial banks if the control culture
is brought in through policy guidelines and structural changes at these banks.
Empirical work from Chinas banking systems found that commitment to competence,
organization structure, management behavior, information systems, and assignment of
authority and responsibility proved to be the most significant internal control variables.
(Cockburn and Lee, 1984).
A sample of 210 listed firm of Taiwan by Jung-Hua-Hung and Hui-Lin-Han(1997)
revealed that management attitudes, training and professional abilities of auditors are the
significant control variables in achieving the efficient internal control structure of the
firms. Very few studies of internal control were done related to the developing countries
and especially in context of Bangladesh. One study can be found from Ali, Khan, Fatima
and Masud (2008) that made attempt on the various aspects of internal control variables
on Bangladeshi firms. They analyzed the responses of 25 corporate firms and found that
only very few of them discloses and comply with the systematic control variables and the
corporate governance aspects on a voluntary basis and little efforts made by tem in order
to have an sound internal control systems.
Another study conducted by Fowzia,(2009) investigated into the sound effects of diverse
factors on co-operation between internal and external auditors of listed banks in
Bangladesh. Findings revealed that co-operation promoted through management and the
audit committee is the most important factor for assessing co-operation between internal
and external auditors followed by professional confidence, co-operation and consultation,
reliance on internal audit and communication. This results found consistent with our
study in the sense that external audit committee is the important control environment
variables of the banks.
Control
Environment
Authority
Risk Assessment
1
Effectiveness
ointernal
control
Control
Activities
2
3
Objectives
Dependent Variables
Information &
Communication
Monitoring
Independent
Variables
Working
Relationships
stocks are traded on the Dhaka stock exchange were selected as a sample. The following
banks were selected to investigate the internal control structure: Dhaka Bank Ltd., Islami
Bank Bangladesh Ltd., Standard Bank Ltd., IFIC Bank Ltd., ICB Islamic Bank Ltd., and
Dutch Bangla Bank Ltd. The study uses the details of variables of differtent components
of internal control techniques using the primary data collection method, particularly by
questionnaire, observations and face-to-face communication and document analysis.
We have used SUMMATED (Likert) Scale in the measurement of degree of achievement
of control objectives and implementation of several Internal Control Techniques. It is a
scale, usually of approval or agreement, used in questionnaires. As per Likerts Model we
have given highest score (5) for Always and least score (1) for Never except
management philosophy and operating style. In case of management philosophy and
operating style, as all questions imply negative attitude we have reversed the above scale.
4. Components of Internal Control:
Firms need five interrelated components of (ICS) to ensure strong control over their
activities. These are: control environment, risk assessment, control activities, Information
and communication, and monitoring components. The extent to which each component is
implemented is influenced by the size and complexity of the firm, type of industry,
management philosophy, and corporate culture.
4.1 Control Environment Component:
Every organization, regardless of size, should devise a strong internal control
environment. A weak control environment often indicates weakness in the other
components of the ICS. Management philosophy and operating style, the first sub
component of the control environment, require certain positive actions. These actions
include setting an example of ethical behavior by following a personal code of ethics
establishing a formal corporate code of conduct, stressing the importance of internal
controls and treating personnel fairly and with respect. Integrity and ethical values
represent a second subcomponent of the control environment. The ethical and unethical
behaviors of managers and employees can have a pervasive impact on the entire ICS,
creating an atmosphere that can significantly influence the validity of the financial
reporting process. Every public and non- public firm should prepare a written code of
corporate conduct that establishes the appropriate tone for management, subordinates and
employees.
Commitment to competence is the third subcomponent of the control environment. Firms
must recruit competent and trustworthy employees to encourage initiative and creativity
and to react quickly to changing conditions. The board of directors or audit committee is a
fourth sub component of the control environment. A properly functioning board of
directors should appoint an audit committee of outside directors.
Organizational Structure is the fifth subcomponent of the control environment. It
identifies the framework of formal relationships for achieving firm objectives. Another
subcomponent of the control environment is assignment of authority and responsibility.
Authority is the right to command subordinates. Responsibility is ones obligation to
perform assigned duties and to be held accountable for the results attained. Human
Resource policies and practice, the seventh and final subcomponent of the control
environment, involve a consideration of policies regarding the recruitment, orientation,
As in Table 1, out of 6 banks, IBBL, IFIC, and IIB highly achieved effectiveness and
efficiency of operation 19.99% better than average performance of local listed
private banks. DBL and DBBL are ineffective and inefficient relative to average
performance, 4.00% worse than average performer. Within our sample SBL is
the most ineffective and inefficient which deviates from average performance by
52.00%. IBBL, SBL, IIB, and DBBL provide highly reliable financial
statements, 7.14% higher than the average. DBL and IFIC provide less reliable
financial statements, 14.29% lower than average reliability.
Almost all the banks highly comply with applicable laws and regulation, 3.45% more
than average compliance. Only ICB Islamic Bank Ltd.. moderately complies, 17.24% less
than the average compliance.
Control Environment Component: The estimated results of different variables of
control environment component are presented in table 2 of appendices. The results
indicate that IBBL, SBL, and IFIC banks highly emphasizes on long-term profit and
operating goals, whereas DBL and DBBL moderately emphasize, Management group is
not dominated by one or few individual in case of IBBL, IFIC and DBBL but for DBL,
SBL, and IIB management group is moderately dominated by one or few individual. The
results suggests that IBBL, SBL, and IFIC management takes less business risk to achieve
their objectives but DBL and DBBL management take a little bit business risk in their
decision making.. Only THE ICB Islamic Bank Ltd.s management takes moderate
business risk to achieve their objectives. Out of 6 banks, IBBL, IFIC & IIB management
is conservative toward selecting accounting policies, SBL & DBBL banks management
is less aggressive, and the remaining one bank DBLs, management is highly aggressive
toward selecting accounting policies.
Management behavior is mostly restricted by corporate code of conduct in case of IBBL
& IFIC but for SBL, IIB & DBBL management behavior is less restricted by corporate
code of conduct. Only the DBLs management behavior is least restricted by corporate
code of conduct. Out of 6 banks, DBL, IBBL, and SBL recruit competent and trustworthy
employees, DBBL recruits less competent and trustworthy employees, IFIC and IIB
recruit least competent and trustworthy employees. Through appointment of audit
committee composed entirely of outside directors is not practiced in Bangladesh. We have
found some positive responses. It is found that DBL&IBBL always appoint audit
committee, DBBL very frequently appoints audit committee, whereas SBL, IFIC &IIB
banks do not appoint audit committee. Out of six banks, IBBL, SBL & DBBL banks audit
committee always work closely with BOD, external and internal auditors, one bank i.e.
DBL whose audit committee frequently works closely with BOD, external and internal
auditors, and in case of IFIC &IIB they have no audit committee. So there is no question
of working closely with BOD, external and internal auditors. The results shows that DBL,
IBBL & DBBL banks audit committee always review the actions of the managers
independently but in case of SBL audit committee very frequently reviews the actions of
the managers independently. Most of the banks management always implement the
recommendation provided in the audit report, the rest of 2 banks have no audit committee
for providing recommendation. As shown in Table 5.2, except DBL all banks always
prepared an up-to-date organization chart. Information system function is totally
separated from incompatible function in case of DBL, IBBL & DBBL but for IIB
information system function is frequently separated; SBLs information system function is
seldom separated. Information system function is not separated in case of IFIC.
We have found that banks team members are always empowered to make decisions by
not seeking multiple layers of approval in IBBL, team members are very frequently in
DBLs, banks team members are frequently in SBL, IIB & DBBL.IFIC team members
are seldom to empowered to do. Most of the banks always prepare written employee job
description, only IIB very frequently prepare. We have found that most of the banks
always properly delegate authority to employees and departments, only SBL frequently
properly delegates. As shown by Table 2, DBL, IBBL & SBL have written recruitment
policy and they always comply with it, the rest 3 banks have written recruitment policy
and they frequently comply with it. Most of the banks always provide training program to
new employees, only IIB frequently perform this function. We have found that most of
the banks always provide instructions to new employees with respect to internal control
ethics and corporate code of conduct, SBL very frequently provides and IIB frequently
provides that instructions. Table 2 shows that IBBL always conducts periodic rotation of
duties among key employees, SBL & DBBL conduct very frequently and DBL, IFIC &
IIB conduct frequently.
Risk Assessment Component : The result of component of risk assessment variables as
presented in table 3 of appendices found that most of the banks always conduct risk
assessment to identify, analyze and prevent credit risk, only DBBL frequently conducts.
Control Activities Component: This table 4 demonstrates the different variables to
assess the control activities of internal control structure. The outcome is that all the banks
in our sample except DBBL, properly segregated authorized their authorization function.
We have found that most of the banks always kept the formats and contents of all
documents in simple, only DBL & DBBL kept very frequently. The result shows that
IBBL, IFIC & IIB always use pre numbered documents, but DBL, SBL, & DBBL very
frequently use those documents. Most of the banks always restrict access to computer
rooms, computer files and information by authorized users, But in case of DBL, their
access very frequently and DBBLs access frequently.
Monitoring Component: It can be observed from table 5 of appendices that out of 6
banks, most of the banks always have ongoing monitoring activities, but DBL very
frequently has and IIB frequently has ongoing monitoring activities. In case of IBBL,
IFIC & DBBL have always separate monitoring activities, but in DBL & IIB frequently
have and SBL seldom has separate monitoring activities.
6.1 Conclusion
The study tries to analyze the components of different control variables used for assessing
the internal control systems of banks considered here. The study found that all the banks
considered for the paper achieved the control objectives in a greater extent and the
deviation regarding achievement of control objectives is minimum. Based on average the
local listed private banking sector frequently emphasis on short - term profits and
operating goals and they differ among themselves in a greater extent regarding the extent
of emphasis. One or few individuals seldom dominate management group. The deviation
among them is negligible. It implies that the risk aversive ness of managements grouping
local listed private banking sector. Management is seldom aggressive toward selecting
alternative accounting principles.
Out of 6 banks, all the banks have written corporate code of conduct. Management
behavior is frequently restricted by written corporate code of conduct. All the banks
frequently recruit competent and trustworthy employees to encourage initiative and
8
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10
Control
DBL
IBBL
SBL
IFIC
IIB
DBBL
Objectiv Deviation Percentage Deviation PercentageDeviation Percentage
Deviation Percentage Deviation Percentage Deviation Percentage
es
1*
-0.1667 -4.0008 0.8333
19.999
-2.1667 52.0004 0.8333
19.9990
0.8333
19.9990 -0.1667 -4.0008
0
2*
0.4714
-14.286 0.4714
7.1421
0.4714
7.1421
0.4714
-14.286
0.4714
7.1421
0.4714
7.1421
3*
0.3727
3.4490
0.3727
3.4490
0.3727
3.4490
0.3727
3.4490
0.3727
-17.241 0.3727
3.4490
0.8975
1.8634
1.7951
1.7951
1.8856
0.3727
1.6073
0.9428
0.3727
0.7454
0.5000
0.7455
0.7638
0.7455
19.9990
76.4727
-10.000
50.0015
36.3624
-17.240
42.8571
20.0012
3.4490
7.1421
11.1111
7.1421
11.1111
-18.182
0.8975
1.8634
1.7951
1.7951
1.8856
0.3727
1.6073
0.9428
0.3727
0.7454
0.5000
0.7455
0.7638
0.7455
19.9990
76.4727
50.0015
50.0015
36.3624
3.4490
42.8571
50.0015
3.4490
7.1421
11.1111
7.1421
11.1111
36.3624
0.8975
1.8634
1.7951
1.7951
1.8856
0.3727
1.6073
0.9428
0.3727
0.7454
0.5000
0.7455
0.7638
0.7455
19.9990
-64.705
50.0015
-10.000
36.3624
3.4490
-42.857
-9.9991
3.4490
-35.714
11.1111
7.1421
-11.111
9.0899
0.8975
1.8634
1.7951
1.7951
1.8856
0.3727
1.6073
0.9428
0.3727
0.7454
0.5000
0.7455
0.7638
0.7455
-28.000
-64.705
-69.999
-69.999
-72.727
3.4490
-71.428
-39.999
3.4490
7.1421
-11.111
7.1421
11.1111
-18.182
0.8975
1.8634
1.7951
1.7951
1.8856
0.3727
1.6073
0.9428
0.3727
0.7454
0.5000
0.7455
0.7638
0.7455
-28.000
-64.705
-69.999
-69.999
-72.727
3.4490
-14.285
-9.9991
-17.240
7.1421
-11.111
-35.714
-33.333
-18.182
DBBL
Deviation Percentage
1.5723
0.7454
0.1000
0.7454
.6872
41.1781
9.0899
9.0899
-7.6916
-4.0008
0.8975
1.8634
1.7951
1.7951
1.8856
0.3727
1.6073
0.9428
0.3727
0.7454
0.5000
0.7455
0.7638
0.7455
-4.0008
41.1781
50.0015
50.0015
36.3624
3.4490
42.8571
-9.9991
3.4490
7.1421
-11.111
7.1421
11.1111
9.0899
11
policy and extent of compliance with it, 17* Training program for new employees, 18* New
personnel are given instructions with respect to internal control ethics and corporate code of
conduct, 19* Periodic rotation of duties among key employees
1
2
3
4
0.3727
0.4714
0.5000
0.7638
3.4490
-14.286
-11.111
-11.111
0.3727
0.4714
0.5000
0.7638
3.4490
7.1421
11.111
11.1111
0.3727
0.4714
0.5000
0.7638
3.4490
7.1421
-11.111
11.1111
0.3727
0.4714
0.5000
0.7638
3.4490
7.1421
11.1111
11.1111
0.3727
0.4714
0.5000
0.7638
3.4490
7.1421
11.1111
11.1111
0.3727
0.4714
0.5000
0.7638
-17.240
-14.286
-11.111
-33.333
1* Authorization functions are segregated, 2* Formats and contents of all documents are kept
simple, 3* Sources documents are pre-numbered, 4* Restriction on access to computer rooms,
computer files and information by unauthorized users
12