In accordance with the Statutory Auditors (Transparency) Instrument 2008, issued by the Professional Oversight Board, we submit our transparency report for the year ended 31 March 2011. The Instrument came into force on 6 April 2008 and requires the publication of certain information by statutory auditors that have made an audit report on the annual accounts of a public interest entity during the financial year of that statutory auditor.
This report, which covers the financial year ended 5 April 2011, is Larking Gowen's first transparency report. The report also seeks to incorporate the findings of the POB's "Review of Mandatory Reports" released in May 2010.
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Legal structure and ownership
The practice, Larking Gowen, includes the partnership Larking Gowen and a limited company Larking Gowen Limited each of which provides statutory audit services as well as a range of other accounting services including taxation and general business advice. A further company, Larking Gowen Corporate Finance Limited, provides corporate finance services and certain associated accounting services.
The partnership currently has 19 partners. Larking Gowen Limited is owned by certain of the Larking Gowen partners. The firm operates from offices in Norwich and Ipswich and a further 7 offices in Norfolk, Suffolk and Essex. Larking Gowen has no overseas branches.
The public interest entity audit which prompts the requirement for this report was conducted by Larking Gowen Limited. Due to common systems in operation, the report is compiled in respect of the practice Larking Gowen as a whole, except where otherwise indicated.
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MacIntyre Hudson Association (MHA)
Larking Gowen is one of 8 members of MHA. MHA is an association of accountancy firms from across the UK which exists to provide our clients with an improved range of services and expertise together with a broader geographical coverage. Through this association, the firm is a member of Morison International, a global association of independent accountancy and business advisory firms. Each member firm of MHA remains wholly independent and retains its own identity locally whilst representing the association in its respective region.
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Governance and management
The main elements of the firm's governance structure are as follows:
- A chairman (David Whitehead), elected from the equity partners, acts as a focal point for pastoral care of individual partners.
- A managing partner (Bob Rose) is elected by the partners to act as the main operational executive. The managing partner appoints two further partners to act as a Management Board (Ian Fitch and Grant Pilcher). The primary objective of the Management Board is the pursuit of the firm's business plan. That plan, approved by the partners, is formulated, reviewed and revised where necessary by a Strategic Management Committee (SMC). The SMC consists of the managing partner and three other elected partners (Brian Pring, Mark Balfour and Julie Grimmer).
The firm is organised into three regional groups and deals with both "corporate and commercial clients" and "business and private client" business streams.
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Internal quality control systems
Larking Gowen established a system of quality control designed to ensure that the firm and its personnel comply with professional standards and applicable legal and regulatory requirements, and that reports issued by the firm or engagement partners are appropriate in the circumstances. The firm's system of quality control includes policies and procedures addressing each of the elements within the International Standard on Quality Control (UK and Ireland) 1 - ISQC 1:
Leadership responsibilities for quality within the firm
The firm's Management Board assume ultimate responsibility for the firm's systems of quality control. Operational responsibilities for the firm's quality control system are assigned to the firm's Audit Committee which comprises the Audit Compliance Principal (Julie Grimmer) and the Audit Monitoring Partner (Steve Rudd), who report to Management Board. Policies are communicated to audit staff via the firm's intranet, audit liaison group (a group of nominated audit specialists in relevant departments across the firm) and at regular in-house training sessions.
Ethical requirements
The firm's Ethics Partner (David Whitehead) advises on specific ethical questions as necessary. The firm has developed an Ethics Manual, based on the Mercia Audit System, that contains its general and specific policies on the application of the APB Ethical Standards. This is contained on the firm's intranet and is included in regular staff training.
Acceptance and continuance of client relationships and specific engagements
New appointments are only accepted by audit engagement partners who, amongst other matters, have due regard to the ethical standards and also consider whether the firm has sufficient skills and resources to perform the audit. This may require obtaining detailed information regarding a potential client before a decision can be made. The detailed matters considered are contained in our standard documentation. These points are reconsidered each year during audit planning.
Human resources
Our policy is to recruit and promote audit staff of a suitably high calibre. All RIs are partners in the firm and are qualified with the ICAEW or ACCA.
All partners and staff are subject to annual appraisals which include performance evaluations and compliance with CPD policies. No RI, nor audit staff member is remunerated on the basis of selling non-audit services to audit clients.
Engagement performance
During 2010/11 the firm has introduced a computer-based audit methodology based on an externally produced audit system. This has helped ensure compliance with Clarity ISA audits for periods ending on or after 15 December 2010.
All audit work, other than that of an RI, is reviewed by a more experienced engagement team member.
In addition the firm's procedures require review of higher risk audits at planning and completion by either a technical specialist or a second audit partner (EQCR) or both. Specific areas of audit risk may also prompt a second partner consultation review prior to finalisation.
Monitoring
Cold file reviews are performed on a risk assessed basis across the SSAs. Any audit assignment may be selected for review, but the sampling method aims to ensure that any area previously identified as weaknesses is covered. Periodically a suitably qualified external cold file reviewer is engaged to validate the firms internal reviews process or to conduct actual reviews. The 2011 public interest audit was subject to external cold file review.
Statement on effectiveness of the internal quality control system
Based on information provided to it that include both internal and external cold file reviews, the Management Board confirms that it is satisfied with the operation of the firm's internal quality control system.
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External Monitoring
The last monitoring visit by the Quality Assurance Directorate ("QAD") of the ICAEW took place in November 2009. The firm were extremely pleased by the reassurance as to the quality of financial statements and audit work that came out of the report and closing meeting notes.
The firm has, as yet, not been inspected by the Audit Inspection Unit (AIU).
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Public interest entities
The firm made an audit report on one public interest entity during the year ended 5 April 2011:
Tex Holdings PLC (Premium listing on the London Stock Exchange) for which we issued audit reports on 6 April 2010 and 5 April 2011.
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Independence procedures
In addition to the policies and procedures set out above under the heading Internal control systems, all partners and staff make a declaration of fit and proper status on joining the firm and on an annual basis thereafter. Fit and proper declarations are monitored by the audit monitoring partner. Where circumstances change in the year reports are made to both engagement partner and audit monitoring partner. All partners are also required to make an annual declaration of their own (and associates) financial interests to the Partnership Secretary (David Jefford), who, in turn, provides details to the audit monitoring partner.
The firm's policies and procedures on independence are set out in the firm's procedures and ethics manuals which are based on the Mercia Practice Assurance and Ethics Manuals supplemented by additional internal procedures. The manuals are designed to provide a comprehensive handbook and include specific policies on long association with a client, overdue fees, communication with clients, provision of non-audit services and other factors such as consideration of going concern where the RIs client relationship may be considered to put independence at risk. Independence practices are periodically reviewed by the Audit Committee. Compliance to policies is tested as part of the annual audit cold file reviews with the Audit Committee making any revisions required to stated policy as a result of the audit cold file and annual whole firm compliance review conducted.
As an example, our underlying policy on overdue fees is not to commence an audit until the fees from the previous audit have been paid. Where anything other than a trivial amount of other professional fees for an audit client are long overdue, the ethics partner will confirm whether we may continue with the appointment and the adequacy of the safeguards proposed in the particular circumstances.
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Continuing professional development
As well as the requirements of individuals' professional bodies, Larking Gowen sets minimum requirements for partner and staff CPD, tailored to the requirements of their role. All staff record and report on their CPD activities as part of the annual appraisals, which themselves are designed to indentify training needs for the following year. As a minimum each auditor is required to attend:
- Internal technical training - delivered three times per year by Larking Gowen technical specialists and audit committee.
- An annual firm-wide audit training session delivered by an external training organisation.
- At least one other external course.
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Financial information for the year
| |
2010/11
£000 |
2009/10
£000 |
| Revenues from work on statutory audit work and directly related services |
1,905 |
1,800 |
| Revenue from non-audit services to audit clients |
893 |
1,213 |
| Revenue from non-audit services to non-audit clients |
10,502 |
10,592 |
| Total of the above |
13,300 |
13,605 |
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Basis of remuneration of partners
Partners are remunerated solely out of the profits of the firm with partners being responsible for funding their own pension and other benefits. Each partner's share is determined by reference to responsibility, seniority, equity points and by annual performance appraisal. The performance element of remuneration is determined by the firm's remuneration committee which consists of the firm's Chairman and three other senior equity partners elected by firm's equity partners.
