BACKGROUND NOTE ON ACTION PLANS

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BACKGROUND NOTE ON ACTION PLANS Action Plans are developed by IFAC members and associates to address policy matters identified through their responses to the IFAC Compliance Self-Assessment Questionnaires. They form part of a continuous process within the IFAC Member Body Compliance Program to support the ongoing development and improvement of the accountancy profession around the world. Action Plans are prepared by members and associates for their own use based on the national frameworks, priorities, processes and challenges specific to each jurisdiction. As such, they will vary in their objectives, content and level of detail, consistent with their differing national environments and stages of development, and will be subject to periodic review and update. Refer to responses to the Part 1 Assessment of the Regulatory and Standard-Setting Framework Questionnaire and Part 2 SMO Self-Assessment Questionnaire for background information on each member and associate their environment and existing processes. These responses may be viewed at: http://www.ifac.org/complianceassessment/published_surveys.php Use of Information Please refer to the Disclaimer published on the Compliance Program website. ACTION PLAN IFAC Member/Associate: The Institute Of Chartered Accountants Ghana (ICAG) Approved by Governing Body: ICAG Council Original Publish : February 2011 Last Updated: May 2012 Next Update: May 2013 Status as of of Publication

Glossary ASAC Accounting Standards and Advisory Committee CEO Chief Executive Officer CPD Continuous Professional Development E&TC Education and Training Committee ED Exposure Draft I & D Investigation and Discipline IAASB International Auditing and Assurance Standards Board IASB International Accounting Standards Board ICAEW Institute of Chartered Accountants in England and Wales ICAG Institute of Chartered Accountants Ghana IES International Education Standards IESBA International Ethics Standards Board for Accountants IFAC International Federation of Accountants IFRS International Financial Reporting Standards IPSAS International Public Sector Accounting Standards IPSASB International Public Sector Accounting Standards Board ISA International Standards on Auditing ISAE International Standards on Assurance Engagement ISQC 1 International Standards on Quality Control 1 ISRE International Standards on Review Engagement ISRS International Standards on Related Services MCPD Mandatory Continuous Education Programme Professional Standards and Ethics Committee PWC PriceWaterHouseCoopers QA Quality Assurance SME Small and Medium Enterprise SMO Statement of Membership Obligation Status as of of Publication Page 2 of 20

Action Plan Subject: SMO 1 Quality Assurance Action Plan Objective: Establish a Quality Assurance review system in line with the requirements of SMO 1 Background: ICAG has developed a Quality Assurance (QA) review system which scope includes all statutory audits of public interest entities and other professional services delivered by ICAG members. The professional accountancy organization has also adopted the International Standard on Quality Control (ISQC) 1 as quality control standards. Preparing Quality Assurance Review System 1. 1 November 2008 2. 1 November 2008 3. 1 November 2008 4. 1 November 2008 5. 15 November 2008 Announce mandatory compliance of the QA review system with SMO 1 requirements to ICAG Council Members. Define the scope of the QA Review System in line with SMO 1, Quality Assurance. Quality control is addressed at three levels: the engagement level, the firm level and the member body level. Update the list of practicing members and their current addresses, business locations, membership status, etc. for the purpose of the QA reviews. Register all practicing firms and categorize them based on turnover, clientele base, numerical strength of partners, numerical strength of employees, etc. Communicate to all ICAG members in practice the Institute s intention to establish a QA review system in line with SMO 1 requirements. Completed Completed Chief Executive Officer (CEO) of Completed CEO CEO Completed CEO CEO Completed CEO ICAG Staff of Professional Standards and Ethics Committee () of 6. 15 November 2008 7. 10 January 2009 Engage a consultant to prepare QA Review Manual. Completed Council PriceWaterHouseCoopers (PWC) Organize sensitization seminar to explain the scope of QA Review to all members. Completed CEO of Status as of of Publication Page 3 of 20

8. 10 January 2009 Submit draft QA Review Manual to Practice Society for comments. Completed CEO Practice Society Recruiting and Training QA Reviewers 9. 3 January 2011 Define Qualifications for QA reviewers in line with the requirements of SMO 1. Completed Council of 10. 10 January 2012 11. 1 February 2012 Advertise for job vacancy for reviewers and recruit QA reviewers. Organize training for QA Reviewers. ICAG would sponsor the QA Reviewers to UK for some internship program with the Institute of Chartered Accountants in England and Wales (ICAEW). 1 February 2012 CEO /Council OF ICAG March 2012 CEO ICAEW CEO/Council of ICAG Implementation of the Quality Assurance Review System 12. 28 May 2012 Organize a seminar to educate ICAG members in practice on the QA review system with particular reference to the following: Scope of Quality Assurance Review Program; Quality Control Standards; Other Quality Control Guidance; The Design of the Quality Assurance Review Program; Review Cycle; Quality Assurance Review Team Procedures; Documentation; The Quality Assurance Review Team; Reporting; and Corrective and Disciplinary Actions 28 May 2012 CEO Review Team/ICAEW Status as of of Publication Page 4 of 20

13. 1 June 2012 Start the QA review process. CEO/ of Maintaining Mechanisms 14. 1 January Include courses on ISQC 1 in the annual curriculum of the Mandatory Continuous Professional Development (MCPD) programs. QA Reviewers CEO MCPD facilitators Review of ICAG s Compliance Information 15. April Perform periodic review of ICAG s response to the IFAC self assessment questionnaire, and update section relevant to SMO1 as necessary. Once updated, inform IFAC Compliance staff in order for them to republish updated information. CEO CEO Status as of of Publication Page 5 of 20

Action Plan Subject: Action Plan Objective: SMO 2 International Education Standards and other IAESB guidance Set ICAG qualifying examinations and training programs in accordance with IESs Background: Candidates for ICAG membership have to complete a program of professional accountancy education, complete practical experience requirements and pass final examinations. ICAG s education system incorporates all the requirements of the International Education Standards (IES). ICAG s MCPD has also been reviewed in line with the requirements of IES 7, Continuing Professional Development. The Institute is in the course of further enhancing its education system to benchmark that of ICAEW. Improving Entry Requirements 16. May Revise the minimum ICAG studentship requirements to be at least equivalent to that required for admission into a recognized university degree program. Completed Education and Training Committee (E&TC) E&TC Members Encouraging Other Institutions Involved in Accountancy Education to Improve their Education Program 17. 1 March Promote compliance with International Education Standards (IESs) 2, Content of Professional Accounting Education Program, 3, Professional Skills and General Education, 4, Professional Value, Ethics and Attitudes to the National Council for Tertiary Education (NCTE) and National Board for Technical Education (NABTEC). E&TC E&TC Members These bodies respectively set education standards for Universities and Polytechnics, which deliver part of the professional accountancy education programs to ICAG students. Enhancing Quality of Qualifying Education 18. 1 May Revise content and structure of qualifying Completed E&TC E&TC Members Status as of of Publication Page 6 of 20

2009 examinations of ICAG in line with IES 2, IES 3 and IES 4. 19. 1 May Review questions set at the final stage of the professional examinations so as to ensure that they solicit responses that demonstrate professional capabilities and competences, in accordance with IES 6, Assessment of Professional Capabilities and Competence. The questions at the professional stage of the qualifying examinations should test for application, analysis and synthesis. of Examinations Committee Chief Examiners and Moderators Setting New Practical Experience Requirements 20. 1 January 2008 Revise the period of practical experience required by graduates of ICAG before gaining professional membership to a minimum of three years, in line with provisions of IES 5, Practical Experience Requirements. Completed of Admissions Committee of ICAG Council Admissions Committee of ICAG Council 21. 1 May Institute pre-qualification and post-qualification practice logging system (articleship) to monitor and enforce compliance with IES 5. E&TC E&TC Members Students are to provide annual returns of practical accountancy experience to the Institute as a way of monitoring their accumulated practical experience requirement for membership Establishing Mandatory Continuous Professional Development Program 22. 1 May 2008 Institute MCPD program and ensure that compliance is fulfilled before good membership status is bestowed on members of ICAG. of Admissions Committee Admissions Committee Members Compile members earned points on MCPD and apply the fulfillment of 35 credit hours a year as condition for Status as of of Publication Page 7 of 20

good membership status. Incorporating IES 8 into ICAG Education Requirements 23. 1 February 2011 Draft new knowledge and skills requirements in accordance with IES 8, Competence Requirements for Audit Professionals for members of ICAG who would want to obtain their audit practice license. Completed Director Member Services Admissions Committee Members 24. 1 April 2011 Approve the new knowledge and skills requirements to be satisfied by prospective professional auditors and communicate same to all ICAG members. Completed CEO ICAG Council Maintaining Mechanism 25. 1 May E&TC to continually review the training and education curricula in accordance with new and revised IESs. E&TC E&TC Members Review ICAG s Compliance Information 26. Perform periodic review of ICAG s response to the IFAC self assessment questionnaire, and update section relevant to SMO 2 as necessary. Once updated, inform IFAC Compliance staff in order for them to republish updated information. ICAG Council CEO Status as of of Publication Page 8 of 20

Action Plan Subject: Action Plan Objective: SMO 3 International Standards, Related Practice Statements and other Papers issued by the IAASB Adopt all IAASB pronouncements and disseminate relevant application guides to ICAG members Background: ICAG has responsibility for adopting the auditing standards in Ghana. The professional accountancy organization has established mechanisms for adopting the International Standards on Auditing (ISAs) and the other pronouncements of the International Auditing and Assurance Standards Board (IAASB) as auditing standards. Adoption of ISAs and Other IAASB Pronouncements 27. 1 January 2007 28. 1 June Adopt ISAs and other pronouncements of the IAASB as the framework for auditing and assurance services in Ghana. ICAG has adopted the clarified ISAs and other pronouncements from the IAASB. Publish and announce the adoption of the ISAs and other pronouncements of IAASB as the framework for auditing and assurance services in Ghana (by way of public announcement and website publication). ICAG Council ICAG Council and Practice Society Completed ICAG Council ICAG Council Assisting ICAG Members with the Implementation of ISAs, ISQC 1, ISRE, ISAEs and ISRSs 29. 1 January 2007 30. 1 January 2007 Organize seminars to explain the contents and application of ISAs, ISQC 1, International Standards on Review Engagement (ISREs), International Standards on Assurance Engagement (ISAEs), and International Standards on Related Services (ISRSs) to members in professional audit practice. Communicate to ICAG Members any amendments, revisions, and additions to the ISAs and other IAASB pronouncements. CEO Senior Managers and Partners of Auditing Firms CEO Practice Society Status as of of Publication Page 9 of 20

31. 1 January Promote inclusion of courses on ISAs and other 2007 IAASB Pronouncements in the Auditing Syllabus of Universities and Polytechnics in Ghana by seeking collaboration with NCTE and NABTEC. E&TC E&TC Members 32. 1 January 2007 Include in extant, ISAs and all pronouncements of IAASB in the auditing syllabus of ICAG qualifying examinations. Include courses on ISAs and other IAASB pronouncements in the MCPD programs. E&TC and Examination Committee E&TC and Examinations Committee Members 33. 11 June 2008 Organize MCPD programs on the Guide to Using International Standards on Auditing in the Audits of Small- and Medium sized Entities developed by the IFAC Small- and Medium-Practices (SMP) Committee. CEO Senior Managers and Partners of Auditing Firms Monitoring Compliance with Auditing Standards 34. 1 August Monitor ICAG members audit practice through the QA review system developed by the Institute to ensure they respect the ISAs and other IAASB Pronouncements in the course of their activities. of Quality Assurance Reviewers Maintaining Processes 35. 1 June Provide comments on IAASB Discussion Papers and Exposure Drafts (EDs) on a regular basis on new and revised ISAs and other pronouncements. Monitor the standard setting activities of the IAASB to ensure that ICAG adopts new and revised standards., Accounting and Auditing Standards Advisory Committee Practice Society Obtain copies of all new or revised standards and make them available to members. Status as of of Publication Page 10 of 20

Review of ICAG Compliance Information 36. Perform periodic review of ICAG s response to the IFAC self assessment questionnaire, and update section relevant to SMO 3 as necessary. Once updated, inform IFAC Compliance staff in order for them to republish updated information CEO CEO Status as of of Publication Page 11 of 20

Action Plan Subject: Action Plan Objective: SMO 4 Code of Ethics for Professional Accountants Issued by IESBA Adopt and support implementation of the IESBA Code of Ethics Background: ICAG has responsibility for adopting ethical requirements for its members. ICAG s adoption process automatically switches on to any revised version of the Code of Ethics of the International Ethics Standards Board for Accountants (IESBA) and seminars are organized for members on revised aspects of the version of the code. The professional accountancy organization has also developed training activities to further assist its members with the implementation of the standards. Adopting the Revised IESBA Code of Ethics 37. 1 August 2009 Adopt the revised IESBA Code of Ethics and make its requirements compulsory for all members and member firms. Completed ICAG Council Members 38. 1 August 2009 Provide copies of the Code of Ethics to members or indicate to members where soft copies of the revised code can be obtained. Completed CEO / ICAG Council Members Assisting ICAG Members with the Implementation of the Code 39. 1 September 2009 Organize MCPD programs on Ethics for members. CEO Members Maintaining Processes 40. Provide comments on EDs published by the IESBA relating to revision/amendments of the Code of Ethics. Members Review of ICAG s Compliance Information 41. Perform periodic review of ICAG s response to the IFAC self assessment questionnaire, and update CEO CEO Status as of of Publication Page 12 of 20

section relevant to SMO 4 as necessary. Once updated, inform IFAC Compliance staff in order for them to republish updated information. Status as of of Publication Page 13 of 20

Action Plan Subject: Action Plan Objective: SMO 5 International Public Sector Accounting Standards Accelerate the process of adopting IPSAS as the financial reporting framework for the public sector Background: ICAG has responsibility for adopting public sector accounting standards in Ghana and is in the course of establishing mechanisms to adopt and implement International Public Sector Accounting Standards (IPSAS) as public sector accounting standards. Adopting IPSAS as the Public Sector Accounting Standards in Ghana 42. 1 January 2009 Engage stakeholders in public sector financial reporting (Controller and Accountant General, Ghana Audit Service, Ministry of Finance, Internal Audit Agency) and reach an agreement on the need to adopt IPSAS as the public sector accounting standards for public sector entities in Ghana. Completed ICAG Council / Accounting Standards and Advisory Committee (ASAC) ASAC Members 43. 1 January 2009 Organize Train the Trainers seminar for potential facilitators of IPSAS adoption. The facilitators are members of the Institute who occupy senior management positions in the public sector. Completed CEO / ICAG Council Experts from South Africa Institute of Chartered Accountants South Africa (SAICA) 44. 1 January 2009 Acquire copies of bound volumes of IPSAS from the International Public Sector Accounting Standards Board (IPSASB) to be distributed to members. Completed CEO / ICAG Council CEO 45. 1 January 2009 Constitute IPSAS Implementation Task Force to establish the adoption process in Ghana. Completed, Technical and Research Committee of ICAG Council Members of Technical and Research Committee 46. 1 June Provide comments on IPSASB Discussion Papers and EDs (on a regular basis) on new and revised IPSASs and other pronouncements., Accounting Standards Advisory Committee Trained Facilitators Status as of of Publication Page 14 of 20

47. 3 January Monitor adoption of IPSASs and other IPSASB 2011 pronouncements., Accounting Standards Advisory Committee Trained Facilitators 48. 31 March 2011 Adopt IPSAS as the public sector financial reporting framework in Ghana. April 2012 ICAG Council ICAG Council Supporting and Maintaining the Implementation of IPSAS 49. May Include in extant, IPSASs and all pronouncements of IPSASB in the public sector accounting syllabus of ICAG qualifying examinations. E&TC and Examination Committee E&TC and Examinations Committee 50. 1 July Organize seminars to explain the requirements and use of IPSASs to members. 51. 1 July Communicate to members any amendment, revision, and additions to IPSASs and other IPSASB pronouncements. CEO Trained Facilitators CEO Trained Facilitators 52. 3 January 2011 Promote inclusion of IPSASs and other IPSASB Pronouncements in the Public Sector Accounting Syllabus of Universities and Polytechnics in Ghana by seeking collaboration with National Accreditation Board (NAB) and NABTEC. These bodies respectively set education standards for universities and polytechnics. Universities and Polytechnics provide part of the professional accountancy education programs for ICAG students. E&TC E&TC Members Review of ICAG s Compliance Information 53. Perform periodic review of ICAG s response to the CEO CEO Status as of of Publication Page 15 of 20

IFAC self assessment questionnaire, and update section relevant to SMO 5 as necessary. Once updated, inform IFAC Compliance staff in order for them to republish updated information. Status as of of Publication Page 16 of 20

Action Plan Subject: Action Plan Objective: SMO 6 Investigation and Discipline Develop enhanced investigation and disciplinary mechanisms Background: ICAG has established mechanisms for Investigating and Disciplining (I&D) ICAG members for breach of the rules and other professional standards. ICAG is in the process of reviewing these mechanisms and developing activities to ensure that the public and its members are aware that the revised I&D mechanisms exist so that issues they wish to raise may be forwarded to the Disciplinary Committee. Raising Awareness of the Investigation and Disciplinary Mechanisms 54. 1 September 2009 Institute disciplinary procedures for non-compliance with ICAG Code of Ethics. Disciplinary sanctions may include the following: Admonishments, censures or reprimands; Fines; Suspension from membership; and Expulsion from membership ICAG Council Members 55. 1 July Hold seminars to raise members awareness of Revised mechanisms for investigating and disciplining ICAG members for breach of the rules. 56. 1 July Provide information and guidance notes to members about I&D processes. 57. 1 July Disseminate information on appeal procedures via ICAG Members Journal and other publications. CEO / CEO / CEO / Members Members Members 58. 3 January 2011 Constitute Investigation Panel and Disciplinary Committee. The purpose of the Investigation Panel will be to investigate complaints, consider whether a matter Completed CEO / Members Status as of of Publication Page 17 of 20

needs to be referred to the Disciplinary Committee and to summarily reject complaints if deemed spurious or irrelevant to the provisions of the Code of Ethics. The Investigation Panel shall be comprised of the Chair (who must be a member of Council of ICAG) and four other members of ICAG. In the cases where the Investigation Panel recommends a complaint, it shall be heard by a full session of the Disciplinary Tribunal. The Disciplinary Committee shall be composed of the Chair (who must be a member of ICAG Council), two other Council Members and two other members of ICAG. The Disciplinary Committee shall be assisted in all cases by the Institute s Legal Adviser. Maintaining Processes 59. 15 January 2011 60. 15 January 2011 61. 15 January 2011 Review of IFAC Compliance Information Evaluate independence of panel members to ensure objectivity. Establish and operate tracking mechanisms for all cases to prevent undue delay. Maintain records of cases and publish cases where necessary. 62. Perform periodic review of ICAG s response to the IFAC self assessment questionnaire, and update section relevant to SMO 6 as necessary. Once updated, inform IFAC Compliance staff in order for them to republish updated information. CEO / CEO / CEO / CEO CEO Members Members Members Status as of of Publication Page 18 of 20

Action Plan Subject: Action Plan Objective: SMO 7 International Financial Reporting Standards Adopt the IFRS for SMEs and monitor compliance with IFRS Background: The draft Ghana Companies Act requires that companies in Ghana should prepare their financial statements in accordance with the internationally recognised financial reporting standards adopted by ICAG. ICAG, in collaboration with other Regulatory Bodies (Bank of Ghana, National Insurance Commission, Securities and Exchange Commission and State Enterprises Commission) has, since January 2007, adopted International Financial Reporting Standards (IFRS) as the financial reporting framework for all listed entities, banks, insurance companies and state own enterprises. In addition, ICAG has adopted IFRS for Small and Medium Enterprises (SMEs). Adoption of the IFRS for SMEs 63. 1 January 2007 Provide comments on the International Accounting Standards Board (IASB) Discussion Papers and EDs (on a regular basis) on new and revised IFRSs. of ASAC Practice Society 64. 1 August Hold seminar to raise awareness about the need to adopt the IFRS for SMEs. Completed CEO / ASAC Experts from the Accounting Firms 65. 1 August Distribute copies of the IFRS for SMEs to members. Completed CEO / ASAC Experts from the Accounting Firms 66. 1 September Adopt the IFRS for SMEs as the financial reporting framework for SMEs. Completed CEO / ASAC Experts from the Accounting Firms Assist ICAG Members with the Implementation of the Standards 67. 1 September Organize seminars and MCPD courses to educate members and other users on the contents and application of the IFRS, including the IFRS for SMEs. CEO/ ASAC Experts from the Accounting Firms Status as of of Publication Page 19 of 20

Monitoring IFRS Adoption 68. 1 January 2007 Provide comments on IASB Discussion Papers and Exposure Drafts (on a regular basis) on new and revised IFRSs. of ASAC Practice Society 69. 1 January 2008 Examine financial statements presented by the entities to assess the extent of compliance. ASAC External Auditors of the entities / ASAC / Regulatory Bodies 70. 1 March 2011 Constitute teams to monitor compliance. Teams consisting of preparers, users and auditors of financial statements are created to suite specific industrial practices. Such teams would undertake on-site inspection and monitoring processes and necessary technical advice to ensure successful implementation of the standards. CEO / ASAC Experts from the Accounting Firms Review of ICAG s Compliance Information 71. Perform periodic review of ICAG s response to the IFAC self assessment questionnaire, and update section relevant to SMO 7 as necessary. Once updated, inform IFAC Compliance staff in order for them to republish updated information. CEO CEO Status as of of Publication Page 20 of 20