Terms of appointment and further guidance 1 July 2021

Appendix 8: Complaints procedure

1. PSAA is responsible for monitoring the performance of the firms within its audit regime, but the firms themselves remain responsible for the work and behaviour of their staff.

2. Firms are required to report complaints upheld to PSAA when they progressed through all stages of the firms’ complaints policy for contract monitoring purposes.

3. Each firm already has its own complaints process and complaints about auditors should be dealt with under those processes, independently of PSAA. Therefore, as and when PSAA receives a complaint that has not already been investigated by the relevant firm, the complainant will be directed to the relevant contact partner.

4. The complaint should be progressed through all stages of the firm’s own complaints process, until either a satisfactory resolution is found, or it is clear that the firm will be unable to resolve matters.

5. If the firm is unable to resolve matters, it should refer the complainant to PSAA.

6. Because appointed auditors are statutorily independent of PSAA, PSAA cannot:

  • interfere with an appointed auditor’s exercise of his or her professional skill and judgement in performing his or her statutory functions;
  • substitute its own judgements for those of an appointed auditor in the exercise of those functions; and
  • direct an appointed auditor to act or to review his or her decisions, as only the courts have the powers to do so.

7. PSAA will therefore not consider complaints about:

  • the judgements and decisions of auditors; or
  • the processes followed by auditors of local authorities who are exercising their specific powers in relation to electors’ objections to items in a council’s accounts, as this is a matter for the courts. This extends not just to decisions about matters of substance, but also to the process by which those decisions are made.

8. However, PSAA will consider complaints about auditors which relate to a failure in service or maladministration.

9. The definition of maladministration is very wide, and can include:

  • failure to follow proper procedures;
  • discourtesy and rudeness;
  • discrimination;
  • delays;
  • not informing someone of their rights and entitlements;
  • not responding to phone calls, emails or letters;
  • not providing answers to reasonable questions;
  • not answering complaints fully and promptly;
  • failure to recognise and rectify mistakes; and
  • failure to comply with standards.

10. PSAA will not consider any complaint that relates to ongoing audit investigations, until the investigation has been concluded.

11. Complaints may also be received by the RSBs. A memorandum of understanding has been agreed with the RSBs to ensure that complaints are dealt with by the body most appropriate to deal with them. In concluding or dealing with a complaints investigation PSAA may pass their findings or the complaint to the relevant RSB.

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