---
title: "Calling All Auditors: COSO and Hotlines"
date: 2019-02-27
author: "Aaron Cole"
categories:
  - name: "Uncategorized"
    url: "/category/uncategorized.md"
---

# Calling All Auditors: COSO and Hotlines

Ever wonder how critical your hotline is? Here is what experts on COSO have to say about hotlines:

**Title: Leveraging COSO Across the Three Lines of Defense**

**By**

**The Institute of Internal Auditors**

**Douglas J. Anderson &amp; Gina Eubanks**

Figure Heading: “Principle 1. The organization demonstrates a commitment to integrity and ethical values.”

Section Heading: “2nd Line of Defense (Risk, Control, and Compliance)

Quote: “• Specific members of the 2nd Line may be requested to support compliance hotlines, investigate potential wrongdoing, or perform other specific duties related to integrity and ethical values.”

Figure Heading: “Principle 14. The organization internally communicates information, including objective and responsibilities for internal control, necessary to support the functioning of internal control.”

Section Heading: “1st Line of Defense (Risk Owners/Managers)

Quote: “• Establishes separate communication channels such as whistleblower hotlines, which serve as fail-safe mechanisms to enable anonymous or confidential communication when normal channels are inoperative or ineffective.”

**Title: 2013 COSO Framework Deloitte Training**

**Deloitte**

Heading: “Demonstrates Commitment to Integrity and Ethical Values (cont.)” “ICEFR Examples”

Quote: “Evaluating misconduct reported through an anonymous hotline”

Heading: “Principle 14 Communicates Internally” “Enhanced Aspects of Principle 14:”

Quote: “Providing separate channels of communication for anonymous or confidential communication when normal communication channels are inoperative or ineffective (e.g., through whistle-blower hotlines).”

Heading: “Principle 15 Communicates Externally” “Enhanced Aspects of Principle 15:

Quote: “Providing separate channels of communication for anonymous or confidential communication when normal communication channels are inoperative or ineffective (e.g., through whistle-blower hotlines).”

**The Wall Street Journal**

**Risk &amp; Compliance Journal**

**Deloitte**

**Risk management strategy and analysis from Deloitte**

**Title: The 2013 COSO Framework and the Audit Committee**

Heading: “COSO and the Role of the Board and Audit Committee”

Quote: “The establishment and maintenance of open lines of communication between management and the board, and the provision of separate lines of communication, such as whistleblower hotlines.”

**Title: Updated 2013 COSO Framework – fraud risk assessments**

**Subtitle: Fraud Investigation &amp; Dispute Services**

**(No Stated Author. Source: www.ey.com)**

Previous Heading: “EY fraud risk assessment approach”

“The assessment incorporates a multilevel approach to fully assess the company’s risk of fraud”

Chart Section Heading: “Entity level review”

Examples include:

- Event reporting/whistle-blower hotlines
- Compliance resources/staffing
- Compliance monitoring plan

**Title: An Overview of the COSO 2013 Framework**

**KPMG**

Section Heading: “Information and Communication: Principle #14 and Points of Focus”

Figure Heading: “The organization internally communicates information, including objectives and responsibilities for internal control, necessary to support the functioning of other components of internal control.”

List Heading: “Points of Focus”

Point: Provides separate communication lines – Separate communication channels, such as whistle blower hotlines, are in place and serve as fail-safe mechanisms to enable anonymous or confidential communication

Section Heading: “Information and Communication: Principle #15 and Points of Focus”

Figure Heading: “15. The organization communicates with external parties regarding matters affecting the functioning of other components of internal control.”

List Heading: “Points of Focus”

Point: “Provides separate communication lines – Separate communication channels, such as whistle blower hotlines, are in place and serve as fail-safe mechanisms to enable anonymous or confidential communication”

**Title: Fraud Risk Management Guide**

**Subtitle: A joint publication of COSO and the ACFE**

**Heading: Fraud Risk Assessment Scorecard**

Heading: “Considering Various Types of Fraud”

Quote: “Our fraud risk assessment team gathers information about potential fraud from internal sources such as interviews with personnel, brainstorming sessions, complaints received from the whistleblower hotline, and analytical procedures.”