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Disclosures on control over financial reporting: the reporting practice of banks listed on the Warsaw Stock Exchange.

INTRODUCTION

The beginning of the twenty-first century was a kind of turning point in the functioning of the accounting information system. Financial scandals associated with Enron and WorldCom in the United States and the ensuing scandals in the European Union shook the world and exposed the weakness of the reporting process, both financial and non-financial. As noted by T. Clarke (US Crisis of Confidence, 2002, p. 24) 'the collapse of Enron has disclosed that every component of the infrastructure of US capitalism was dysfunctional. Companies' accounts were misleading, their auditors conniving, their lawyers conspiring, the ratings agencies asleep and the regulators inadequate.'

Financial scandals have become a driving force behind legislative actions both in the United States and Europe. New regulations also involved disclosures in the field of corporate governance made by listed companies. Legislative order in this field seems to be particularly valuable because disclosures in the field of corporate governance are an important tool for eliminating information asymmetry. As shown by the results of the research the level of disclosure in the field of corporate governance is positively correlated with the degree of separation of ownership from management and the level of uncertainty about the profits presented in annual reports (Bauwhede & Willekens, 2008, p. 112).

The purpose of this paper is to identify the effects of the implementation of selected regulations on corporate governance in the reporting practice of banks listed on the Warsaw Stock Exchange. The survey examined disclosures on the main features of internal control and risk management systems in relation to financial reporting (in this paper the Author also uses the abbreviated name 'control over financial reporting') in banks.

As noted by M. Marcinkowska (2013, p. 53) banks are unique capital market participants due to their activity and a greater number of stakeholders involved in their operation than in the case of other public companies. In addition, the problem of information asymmetry in banks is more exposed than in non-financial entities.

It should be emphasized that the studies conducted so far have focused on the functioning of internal control and risk management in enterprises (e.g. Hoitash, Hoitash & Bedard, 2009; Tipuric, Tusek & Filipovic, 2009; IFAC, 2011; PricewaterhouseCoopers, 2009; 2013; Banaszkiewicz, Bem, Bryl, Gornik, Kozera, Leski, tapinski, Wietrzyk & Witalis, 2003).

Research studies on disclosures related to control over financial reporting, however, have not yet been conducted.

This paper uses a research method involving the analysis of annual reports disclosed by banks. An induction method was used in the process of reasoning.

CHANGES IN REGULATIONS IN THE UNITED STATES AND THE EUROPEAN UNION AS A CONSEQUENCE OF THE FINANCIAL SCANDALS OF THE EARLY TWENTY-FIRST CENTURY

The issue of changes in regulations following the financial scandals of the early twenty-first century was investigated in a number of scientific publications in the world (Clarke, 2005; Horn, 2012; Bauwhede & Willekens, 2008; Hoitash at al., 2009). From the perspective of this publication changes related to corporate governance are particularly relevant.

It should be noted that falsifying financial statements in order to hide the difficult financial situation was the key abuse at Enron. The bankruptcy of Enron contributed to the modernization of regulations which increase the reliability of the information disclosed in financial statements. The Sarbanes-Oxley Act enacted in 2002 in the United States is an example of such regulations. One of the key provisions of the Act related to disclosures on internal controls over the accounting system (Clarke, 2004, p. 159). The provisions of the Sarbanes-Oxley Act require companies to draw up an internal control report. The institution of internal control is appointed by the managers in order to assure investors that the disclosed financial data are reliable. An internal control report must confirm the fact that management is responsible for establishing and maintaining adequate internal control structures. Furthermore, the effectiveness of internal control over financial reporting data prepared by management must be assessed by outside auditors.

The European legislative response to the Sarbanes-Oxley Act was a report prepared under the direction of J. Winter (2002) presented on 4 November 2002, 'A modern regulatory framework for company law in Europe'. In response to the Enron case, the European Commission and the ECOFIN Council agreed that a team led by Winter dealt with the matter of good practice in corporate governance and auditing. It was also suggested that the annual report on corporate governance contained at least information on the risk management system implemented in the company, a description of the key strategies and a description of the company, as well as information on the various types of risk associated with this activity. If the company does not have such a system it should be disclosed (Winter, 2002, p. 47). As noted by L. Horn (2012, p. 96) of the Winter team, the recommendations have a fundamental impact on further initiatives in the field of company law and corporate governance. Suggestions formulated in the Winter report are reflected in 'Modernising Company Law and Enhancing Corporate Governance in the European Union--A Plan to Move Forward' (hereinafter--'A Plan') developed in May 2003. 'A Plan' was, inter alia, to help stimulate the development of international regulations on company law and corporate governance. This plan was understood as an opportunity for the EU to be a catalyst for a global change for good and reasonable principles of corporate governance. 'A Plan' emphasizes that public companies should be required to include in their annual reports a descriptive statement covering the key elements on the structure and practice of corporate governance. The report should include, inter alia, information on the existence of a risk management system and the nature of this system. The provisions of 'A Plan' are reflected, inter alia, in Directive 2006/46/EC of the European Parliament and of the Council of 14 June 2006 amending Directive 78/660/EEC on the annual accounts of certain types of companies, 83/349/EEC on consolidated financial accounts, 86/635/EEC on the annual and consolidated financial statements of banks and other financial institutions and 91/674/EEC on the annual and consolidated financial statements of insurance undertakings, and thus became a part of EU law. In accordance with paragraph 10 of the Directive, companies whose securities are admitted to trading on a regulated market and whose head office is located in the Community, should be obliged to disclose an annual statement on corporate governance being a specific and clearly identifiable part of the annual statement. This statement should provide shareholders with easily accessible, relevant information about the actual practices of corporate governance of the company, including a description of the main features of any existing systems of risk management and internal controls in relation to the financial reporting process.

The provisions of the Directive have been implemented into Polish law under the Regulation of the Minister of Finance of 19 February 2009 on Current and Periodic Information Provided by Issuers of Securities and Conditions for Recognizing as Equivalent Information Required by the Law of a Non-Member State. Pursuant to the provisions of this Regulation the activity reports (management reports) of all issuers should include--constituting a separate part of the report--a statement of corporate governance, which includes, inter alia, information on the description of the main characteristics of the issuer's internal control and risk management systems in relation to the process of the preparation of financial statements and consolidated financial statements.

It should be noted that the control procedures on reporting are included, inter alia, in an integrated COSO internal control model. This model includes the following components: risk assessment, internal control environment, control activities, information, communication, and monitoring (IAASB, 2006).

Given the wide-ranging legislative actions and their reasons, it seems that the disclosure on the main features of the internal control and risk management systems will increase the reliability of financial reporting.

DISCLOSURE ON CONTROL OVER FINANCIAL REPORTING IN THE STRUCTURE OF ANNUAL REPORTS

The annual report is the primary tool by which a company transfers information to stakeholders about its financial condition, changes in financial condition, and performance. The structure of the annual report is largely determined by the regulations in force in the country. The financial statements seem to be particularly important, they are a kind of window through which stakeholders can 'look' into the enterprise (Gad & Walinska, 2012, p. 109). In turn, non-financial information accompanying the financial statements allows better use of the financial reporting potential.

Since 2009, public companies in Poland have been obliged to disclose information concerning the main characteristics of internal control and risk management systems in relation to the process of financial reporting. These disclosures are part of the statement on corporate governance, which in turn is a component of the annual report. The main task of these disclosures is to provide information on the main principles, tools, internal controls and risk management mechanisms within the accounting information system. These disclosures show whether the company has implemented a control system over financial reporting, and if so, how it functions.

According to the definition prepared by IFAC (2011, p. 9), an internal control system is 'an integrated part of an organization's governance system and risk management, which is understood, effected, and actively monitored by the organization's governing body, management, and other personnel, to take advantage of opportunities and to counter the threats, in line with risk management strategy and policies on internal control set by the governing body to achieve an organization's objectives.' Risk management is defined in turn as 'coordinated activities to direct and control an organization with regard to risk' (ISO 31000:2009).

The key question seems to be whether the obligation to prepare the disclosures on the key features of the internal control and risk management systems in regard to financial reporting will affect its credibility in the long term. A lot depends on how the disclosures will be made by the companies. If they contain generalities transferred from other parts of the annual report then they will not bring additional value to the reporting process. Therefore, empirical research in this area seems significant.

It should be emphasized that the Polish regulations do not contain guidelines as to what information should be included in the disclosures on the main features of the internal control and risk management systems in relation to the financial reporting process.

DISCLOSURE ON CONTROL OVER FINANCIAL REPORTING IN BANKS--RESEARCH RESULTS

The objective of the study was to determine the information content of disclosures on internal control and risk management systems in relation to the financial reporting process in banks.

The survey examined the annual reports of 16 banks operating on the Warsaw Stock Exchange (Alior Bank, Bank Gospodarki Zywnosciowej, BNP Paribas Bank Polska, Bank Ochrony Srodowiska, Bank BPH, BRE Bank, Bank Zachodni WBK, Getin Noble Bank, Getin Holding, Bank Handlowy w Warszawie, ING Bank Slaski, Bank Millennium, Nova Kreditna Banka Maribor D.D., Nordea Bank Polska, Bank Polska Kasa Opieki, Powszechna Kasa Oszczednosci Bank Polski).

From the perspective of this paper it seems important that banks, as part of their management system, have at least (Marcinkowska, 2013, p. 263): a risk management system and an internal control system. The annual reports for the year 2011 have been qualified for the study. It was assumed that as regulations regarding the obligation to disclose information on control over financial reporting had been in force for two years, the practice of reporting would have developed a certain form of presentation of the above information.

The following research questions related to disclosures on internal control and risk management in relation to financial reporting were formulated:

1) is it possible to identify specific groups of information presented by the surveyed banks in disclosures about control over financial reporting?

2) what is the nature of the information concerning control over financial reporting presented by banks (detailed information--aggregated information)?

3) which information relating to control over financial reporting banks is most often disclosed?

The survey results show that the surveyed entities presented information on control over financial reporting within the 10 main groups of disclosures:

1) characteristics of internal control and risk management systems

2) IT tools

3) risk

4) managerial accounting

5) preparation of financial statements

6) regulations

7) external audit

8) audit committee

9) security and data protection

10) internal audit

We can distinguish groups of disclosures in which banks presented detailed information (e.g., 'Characteristics of internal control and risk management systems') and groups of information, which included general information (e.g., 'IT tools').

In the 'Characteristics of internal control and risk management systems' disclosure group, most of the banks presented benefits associated with the operation of the system (75% of the surveyed units). Within this group of disclosures the banks also presented components of the control system and forms of control (Tab. 1). In this group of disclosures the banks presented most of the detailed items.

In the 'IT tools' disclosure group the banks typically indicated only that they use IT tools in the system of control over financial reporting (Tab. 2). In the 'Risk' disclosure group the banks presented i.a. information on the types of risk, risk management tools, and units responsible for risk management (Tab. 3). Least often banks presented information on the risk management policy. n the 'Managerial accounting' disclosure group the examined banks merely indicated that internal (managerial) reporting operates in the bank for monitoring the risk level (Tab. 4). Information on units responsible for preparing the financial statements were presented in the 'Preparation of financial statements' disclosure group. Fifty percent of the banks revealed this information. In this disclosure group the banks also presented information on the financial reporting process (Tab. 5).

In the 'Regulations' disclosure group banks presented information on the internal regulations related to the functioning of the system of control over financial reporting. Some banks also indicated the regulations which were the basis for preparing financial statements (Tab. 6).

In the 'External audit' disclosure group the vast majority (75%) of the surveyed banks indicated that their financial statements were audited by the statutory auditor (Tab. 7).

In the 'Audit committee' disclosure group the banks pointed to the tasks which this unit performs in relation to financial reporting (Tab. 8).

In the 'Security and data protection' disclosure group the surveyed banks indicated that they implemented procedures for, e.g. restricting access to data from the accounting system (Tab. 9).

Almost all surveyed banks indicated in the 'Internal audit' disclosure group that their unit has a functioning internal audit unit (Tab. 10). It should be stressed that an independent organizational unit responsible for internal audit must operate in banks (Marcinkowska, 2013, p. 265).

Regarding detailed items, 50% or more of the banks surveyed presented information on: the benefits associated with the operation of systems, components of systems, forms of control, units responsible for the preparation of financial statements, external audit, and the company's internal audit.

An empirical study identified a total of 36 items of detailed disclosures presented by the banks and which concerned disclosures on internal control and risk management systems in relation to financial reporting (Tab. 1-10). It seems reasonable to question whether the number of detailed disclosures presented by individual banks is related to the size of the bank (measured by interest and commission income generated in a given fiscal year). It turns out that it is not possible to identify such a relationship. The most detailed disclosures (identified by the author) on internal control and risk management systems in relation to financial reporting were revealed by the BNP Paribas bank. In turn, the lowest number of detailed disclosures (identified by the author) on internal. control and risk management systems in relation to financial reporting were provided by Nordea bank.

It was also not possible to identify the relationship between the size of the bank (measured by interest and commission income generated in a given year) and the number of main groups of disclosures on internal control and risk management systems in relation to financial reporting. The most main groups of disclosures were presented by BRE Bank, the least, in turn, by Alior Bank (Tab. 11).

In summary, the results of the study indicate that part of the disclosures do not bring additional value to the reporting process. This concerns disclosures about regulations and external audit. Banks listed on the Warsaw Stock Exchange show in disclosures on control over financial reporting that their financial statements are prepared in accordance with IFRS. This information is also contained in financial statements. In addition, financial statements of all public companies are audited; therefore the disclosure of such general information as crucial from the point of view of control over financial reporting appears to be doubtful. The information that banks use IT tools within the internal control and risk management systems in relation to financial reporting seems vague.

CONCLUSIONS

The results of the study indicate that in 2011, in the reporting practice of the listed banks, there was no uniform reporting form regarding the presentation of information on internal control and risk management systems in relation to financial reporting.

The disclosures were different both in terms of the degree of detail and the content. In some banks the disclosures were made at a high level of generality. Part of the disclosed information does not bring additional value to the reporting process, for example such general terms as 'financial statements are audited by a statutory auditor', when all financial statements of all public companies must be audited.

The study has identified a group of data (concerning control over financial reporting), which were mostly presented by the banks. Most banks describe (in a general or specific way) internal control and risk management systems. Many banks disclose information on a body responsible for the preparation of financial statements; some indicate that it was the management board. The disclosures provide the information that the accounting department is also responsible for the preparation of financial statements. Almost all of the surveyed banks indicated that an internal audit unit operates within the systems of internal control and risk management.

The survey results determine which areas related to internal control and risk management systems are crucial from the point of view of financial reporting in the banks listed on the Warsaw Stock Exchange. The results indicate that this issue requires further, in-depth research.

DOI: 10.14636/1734-039X_11_1_001

Received: 09.12.2014

Accepted: 19.04.2015

REFERENCES

Banaszkiewicz, J., Bem, T., Bryl, A., Gornik, J., Kozera, I., Leski, J., tapinski, G., Wietrzyk, A., Witalis, M. (2003). Audyt wewnetrzny spojrzenie praktyczne. Warszawa: Stowarzyszenie Ksiegowych w Polsce.

Bauwhede, H.V., Willekens, M. (2008). Disclosure on Corporate Governance in the European Union. Corporate Governance: An International Review, 16 (2), 101-115.

Bedard, J. C. (2009). Corporate Governance and Internal Control over Financial Reporting: A Comparison of Regulatory Regimes. The Accounting Review, 84 (3), 839-867.

Clarke, T. (2004). Cycles of Crisis and Regulation: the Enduring Agency and Stewardship Problems of Corporate Governance. Cycles of Crisis and Regulation, 12 (2), 153-161.

Clarke, T. (2005). Accounting for Enron: Shareholder Value and Stakeholder Interests. Corporate Governance: An International Review, 13 (5), 598-612.

Directive 2006/46/EC of the European Parliament and of the Council of 14 June 2006 amending Council Directive 78/660/EEC on the annual accounts of certain types of companies, 83/349/EEC on consolidated accounts, 86 / 635/ EWG on the annual and consolidated accounts of banks and other financial institutions and 91/674/EEC on the annual accounts and consolidated accounts of insurance undertakings.

EU, (2003). Modernising Company Law and Enhancing Corporate Governance in the European Union--A Plan to Move Forward. Communication from the Commission to the Council and the European Parliament. Brussels, 21.5.2003, COM 284 final. Retrieved from: http://ec.europa.eu/internal_market/company/docs/modern/governance-consult-responses_en.pdf

Gad, J., Walinska, E. (2012). Raporty rady nadzorczej jako uzupetnienie koncepcji raportow biznesowych--zarys koncepcji. Acta Universitatis Lodziensis Folia Oeconomica, 263, 109-119.

Hoitash, U., Hoitash, R., Bedard, J. C. (2009). Corporate Governance and Internal Control over Financial Reporting: A Comparison of Regulatory Regimes. The Accounting Review, 84 (3), 839-867.

Horn, L. (2012). Corporate Governance in Crisis? The Politics of EU Corporate Governance Regulation. European Law Journal, 18 (1), 83-107.

IAASB, (2006). Internal Control over Financial Reporting--Guidance for Smaller Public Companies, COSO. Retrieved from http://www.coso.org/ICFR-GuidanceforSPCs.htm.

IFAC, (2011). Evaluating and Improving Internal Control in Organizations. International Good Practice Guidance. Professional Accountants in Business Committee. Retrieved from http://www.ifac.org/publications-resources/evaluating-and-improving-internal-control-organizations-0.

IFAC, (2011). Global Survey on Risk Management and Internal Control, Results, Analysis, and Proposed Next Steps. Published by the Professional Accountants in Business Committee. Retrieved from: http://www.ifac.org/publicationsresources/global-survey-risk-management-and-internal-control.

ISO 31000, (2009). Risk management. Principles and guidelines. Retrieved from: http://www.iso.org/iso/home/standards/iso31000.htm.

Marcinkowska, M. (2013). Corporate governance w bankach. Teoria i praktyka. todz: Wydawnictwo Uniwersytetu Lodzkiego.

Nitkowski, K. (2013). Kontrola wewnqtrzna instytucjonalna w systemie kontroli w przedsiqbiorstwie. Warszawa: Wydawnictwo Naukowe PWN.

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Ritcher, P. (2002). US Crisis of Confidence. Australian Financial Review, 4/5 May, 26.

Tipuric, D., Tusek, B., Filipovic, D. (2009). Internal and External Supervisory Mechanisms in Corporate Governance. SEE Journal of Economics and Business, 4 (2), 57-70.

Winter, J. (2002). Report of the High Level Group of Company Law Experts on a Modern Regulatory Framework for Company Law in Europe. Brussels. Retrieved from: http://ec.europa.eu/internal_market/company/docs/modern/report_en.pdf

JACEK GAD (1)

(1) University of Lodz, Faculty of Management, Department of Accounting, e-mail: jgad@uni.lodz.pl.
Table 1: Detailed disclosures within the--'Characteristics of
internal control and risk management systems' disclosure group

Disclosure                Detailed items             % *
group

Characteristics   The definition of internal        6.25%
of internal       control and risk management
control and       systems in relation to the
risk management   financial reporting process
systems
                  The benefits associated with      75.00%
                  the functioning of the system
                  (principles of an effective
                  system)

                  The unit (s) responsible for      18.75%
                  the operation of the control
                  system (e.g. management board,
                  chief accountant)

                  The tasks of the individual       6.25%
                  units operating within the
                  company related to the
                  functioning of the system

                  Information on the procedures     6.25%
                  associated with the
                  functioning of the system

                  The components of the internal    56.25%
                  control and risk management
                  systems. The concept of the
                  three lines regarding the
                  internal control and risk
                  management systems

                  Forms of control operating        56.25%
                  within the system (functional
                  control, institutional
                  control, self-control of
                  correctness of own work)

                  Tasks of functional control       6.25%
                  (checking whether the
                  processes are running
                  properly, analysing whether
                  the procedures are performed
                  by the personnel, if there is
                  conflict of interest,
                  monitoring financial
                  reporting, checking compliance
                  with the rules)

Source: Author's own compilation

* Percentage of companies presenting an item.

Table 2: Detailed disclosure within the 'IT tools' group

Disclosure      Detailed items       % *
group

IT Tools      Information on the    37.5%
             use of IT tools for
             the (e.g. integrated
                  IT system)

Source: Author's own compilation

* Percentage of companies presenting an item.

Table 3: Specific disclosures within the 'Risk' group

Disclosure           Detailed items            % *
group

Risk         Units responsible for risk       12.5%
             management associated with the
             preparation of financial
             statements

             Types of risks associated with   12.5%
             the preparation of financial
             statements

             The Risk management tools        25.0%

             Information on the               31.25%
             implementation of the risk
             management process in relation
             to the financial reporting
             process (identification and
             assessment of risk areas and
             identifying the actions
             necessary to reduce or
             eliminate risk, separating the
             units responsible for
             different types of
             transactions on the market
             (possibly exposed to various
             risks))

             Information on risk management   6.25%
             policy. The use of internal
             procedures for managing risk.

Source: Author's own compilation

* Percentage of companies presenting an item.

Tabela 4: Disclosures on non-financial risk exposures

Disclosure           Detailed items            % *
group

IT Tools      Information on the use of IT    37.5%
             tools for the (e.g. integrated
                       IT system)

Source: Author's own compilation

* Percentage of companies presenting an item.

Tabela 5: Detailed disclosures within the 'Preparation of
financial statements' group

Disclosure             Detailed items            % *
group

Preparation    The units responsible for the    50.0%
of financial   preparation of financial
statements     statements (and supervision)

               Information on the process of    37.5%
               preparing financial statements
               (including the internal
               segregation of duties for
               preparing financial
               statements)

               Information on the use of        6.25%
               control mechanisms of a
               technical nature (numerical
               and logical control formulas)
               and substantive (analysis of
               control reports) in the
               process of preparing financial
               statements

               Information on the fact that     18.75%
               the process of preparing
               financial statements is
               described in the internal
               regulations and in the order
               of the chairman of the board

               Indication of a committee's      6.25%
               responsibility on disclosures
               for the correctness of the
               data contained in financial
               reports and their compliance
               with the law

               Information about the adoption   6.25%
               of solutions aimed at avoiding
               incorrect estimates made in
               accordance with the guidelines
               of IAS/IFRS

Source: Author's own compilation

* Percentage of companies presenting an item.

Tabela 6: Detailed disclosures within the 'Regulations' group

Disclosure            Detailed items            % *
group

Regulations   Information on internal          12.5%
              regulations concerning the
              process of preparing financial
              reporting (procedures,
              directives, inventory
              instructions, lists of duties,
              material liability, code of
              ethics, rules, documentation
              of accounting policy,
              instructions, detailed
              procedures concerning e.g.,
              incurring obligations)

              Information on the sources of    12.5%
              regulation on financial
              reporting (Polish Accounting
              Act, IAS/IFRS, Stock Exchange
              regulations)

              Information on tracking          25.0%
              changes in regulations
              relating to the preparation of
              financial statements and
              interim reports

Source: Author's own compilation

* Percentage of companies presenting an item.

Tabela 7: Detailed disclosures within the 'External audit' group

Disclosure           Detailed items             % *
group

External     Information on submitting         75.0%
audit        financial statement for an
             audit (review) by a statutory
             auditor

             The process of selection of a     37.5%
             statutory auditor (the
             selection is mostly done by
             the supervisory board)

             Information Information on the    12.5%
             remuneration of a statutory
             auditor

             At the meetings of the audit      6.25%
             committee, an auditor presents
             key findings on financial
             reporting

             Information about the adoption    6.25%
             of solutions aimed at avoiding
             incorrect estimates made in
             accordance with the guidelines
             of IAS/IFRS

Source: Author's own compilation

* Percentage of companies presenting an item.

Table 8. Detailed disclosures within the 'Audit committee' group

Disclosure group           Detailed items            % *

Audit committee    The tasks of an audit            37.5%
                   committee related to the
                   functioning of the system
                   (e.g., monitoring the
                   financial reporting process,
                   monitoring the independence of
                   an auditor, recommending the
                   supervisory board to accept or
                   reject financial statements)

Source: Author's own compilation

* Percentage of companies presenting an item.

Table 9. Detailed disclosures within the 'Security and data
protection' group

Disclosure group    Detailed items    % *

Security and data   Information on   6.25%
protection          the safety and
                    protection of
                      data from
                      financial
                      reporting

Source: Author's own compilation

* Percentage of companies presenting an item.

Tabela 10: Detailed disclosures within the 'Internal audit' group

Disclosure       Detailed items                   % *
group

Internal audit   Information on the company's     93.75%
                 internal audit which is
                 involved in risk
                 identification and evaluation
                 of control mechanisms
                 (institutional internal
                 controls implemented by an
                 internal auditor)

                 Information about the            31.25%
                 subordination of internal
                 audit to the management)

                 Internal audit department        25.00%
                 submits to the supervisory
                 board and the audit committee
                 information about any
                 irregularities in the
                 operation of the system

                 Information about the            6.25%
                 existence of the annual
                 internal audit plan

                 Internal audit performs an       6.25%
                 independent assessment of the
                 adequacy, accuracy and
                 efficiency of the internal
                 control and risk management
                 systems

Source: Author's own compilation

* Percentage of companies presenting an item.

Tabela 11: Detailed disclosures within the 'Internal audit' group

Name of the company      Interest and      The number of
                       commission income   main groups of
                       for the year 2011   disclosures *
                       (in thousands of
                             PLN)

Powszechna Kasa           15 874 927             5
Oszczednosci Bank
Polski

Bank Polska Kasa          10 338 275             6
Opieki

BRE Bank                   5 169 745             8

Getin Holding              5 149 837             5

Bank Zachodni WBK          4 972 397             6

ING Bank Slgski            4 555 600             7

Bank Millennium            3 366 850             3

Bank BPH                   2 939 860             6

Bank Handlowy w            2 680 123             5
Warszawie

Alior Bank                 1 323 602             3

Nordea Bank Polska         1 190 977             4

BNP Paribas Bank           1 181502              7
Polska

Bank Ochrony                968 398              5
Srodowiska

Bank Gospodarki             510 133              4
Zywnosciowej

Getin Noble Bank            94 563               7

Nova Kreditna Banka         90 632               5
Maribor D.D.

Name of the company      The number
                        of detailed
                       disclosures **

Powszechna Kasa              9
Oszczednosci Bank
Polski

Bank Polska Kasa             8
Opieki

BRE Bank                     11

Getin Holding                10

Bank Zachodni WBK            12

ING Bank Slgski              12

Bank Millennium              9

Bank BPH                     8

Bank Handlowy w              9
Warszawie

Alior Bank                   8

Nordea Bank Polska           5

BNP Paribas Bank             13
Polska

Bank Ochrony                 11
Srodowiska

Bank Gospodarki              6
Zywnosciowej

Getin Noble Bank             10

Nova Kreditna Banka          6
Maribor D.D.

Source: Author's own compilation

* Up to 10 main groups of disclosures.

** Up to 36 detailed disclosures.
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