The growing number of international clients served by member firms, together with the increasing complexity and scope of national and international independence standards, require the adoption and implementation of appropriate policies and systems to provide reasonable assurance that member firms comply with all applicable independence requirements. Accordingly Grant Thornton International has adopted an automated tracking system, the Global Independence System (GIS). This system is Grant Thornton International’s automated solution for assisting member firms and their professionals in the identification and management of potential independence threats arising from direct or indirect financial interests.
The GIS improves the ability of member firm partners and managers to monitor compliance with global independence requirements, and is being introduced in phases. Phase 1, comprising the introduction to all member firms that are registered with the PCAOB has been completed. All other member firms are included in Phase 2, which is scheduled for completion in 2008. This system is designed to assist individual professionals, member firms and Grant Thornton International in complying with the financial interest rules and policies.
Partners and client facing managers in these firms are required to maintain a portfolio in this system of those publicly traded securities in which they have a financial interest. This requirement also extends to financial interests of the member firm and other entities under the control of the member firm. The GIS is also updated weekly with the latest global restricted list and information provided by the participating member firms identifying the partners and managers required to be monitored. The GIS is designed to automatically alert the individual professional and a national compliance officer in the event that a security held becomes restricted and provides a mechanism to assist the individual and the compliance officer in determining whether the security may continue to be held based upon the facts and circumstances.
Compliance reports are also monitored at the global level by a dedicated independence team at Grant Thornton International. Member firm compliance officers are contacted by the Grant Thornton International independence team when compliance reports indicate that such action is necessary.