RAAP

Group Audit Strategy Memorandum

For 2009 Audit Plan

FOR CAS INTERNAL USE ONLY
This document is for CAS planning purposes only and does not constitute or represent the final agreed audit plan. The distribution of this document or parts of it to any parties outside of CAS is not permitted without the prior written consent from the Chief Auditor.

Version Control

Version / Last Update
1.0

Table of Contents

1.Introduction......

2.Business LineSummary Overview......

3.Business LineStrategic Objectives and Value Drivers......

4.Business Line Economic Capital Considerations......

5.Conclusions......

6.Business Line and Other Stakeholder Contacts......

1.Introduction

This objective of this document is to present information regarding global themes and areas of focus that will be the starting point for the 2008 Corporate Audit Services (CAS) audit strategy and related audit plans.These themes/focus areas were derived using various sources of information including:

  • MTP 2008-2010 – Executive Statement
  • Input from CAS Chief Auditors
  • Information obtained from various ING business unit and Group web sites
  • Monthly CAS meetings with ING Chairman
  • Quarterly Audit Committee Meetings

Any key changes in ING priorities arising from meetings will local management will be used to update the RAAP documentation on a quarterly basis. This will help to ensure that CAS overall is in alignment with changes in ING business priorities and risk profile.

In advance of the official planning period, the CAS management team performed its own assessment of key global themes. This assessment was based on the previous year Audit Planning, updated to reflect current information regarding management attention areas, results of audit activities and last, but not least, prior year business MTP’s.

2.Excerpts from Executive Planning Letter

[CEO’s statement regarding strategic objectives and value drivers]

3.Key focus areas for audit activities

[CAS key focus areas based on information gathered]

In addition, the CAS MT has identified the following global areas of focus for potential thematic audits.

Key Global Focus Areas / Related Value Drivers
Global Focus Area #1
Global Focus Area #2
Global Focus Area #3
Global Focus Area #4
Global Focus Area #5

In consideration of the preceding focus areas, CAS will obtain input and steering from the “specialist” audit groups (i.e. Credit/Market/Insurance/Operational Risk and Compliance).

CAS has informed the ING chairman that a rolling plan will be used to ensure CAS covers all the above focus areas. The rolling plan of thematic audits will be re-assessed during RAAP (i.e. 3+9 approach) on a quarterly basis so that we are in a position to adjust our audit plan for changes in ING priorities.

While it is recognized that the new CAS approach places strong emphasis on strategic objectives and value drivers, CAS teams should still take steps to ensure that important business line/business unit risk areas are not omitted from the audit plan (e.g. areas that have not been audited for a significant period of time, regulatory-required audits, greenfields, remote entities). In addition, the CAS MT has identified global areas of focus for potential thematic audits.

4.CAS Global 2008 Internal Priorities

[List CAS internal priorities, including MTP highlights, KPI’s, major projects and initiatives]

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