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DIRECTORS’ STATEMENT ON
INTERNAL CONTROL OVER FINANCIAL REPORTING

Responsibility

In line with the Banking Act Direction 
No. 11 of 2007, section 3(8) (ii)(b), the 
Board of Directors presents this report on 
Internal Control over Financial Reporting. 

The Board of Directors (“Board”) is 
responsible for the adequacy and 
effectiveness of the internal control 
mechanism in place at Bank of Ceylon, 
(“the Bank”). In considering such 
adequacy and effectiveness, the Board 
recognises that the business of banking 
requires reward to be balanced with risk 
on a managed basis and as such the 
internal control systems are primarily 
designed with a view to highlighting any 
deviations from the limits and indicators 
which comprise the risk appetite of the 
Bank. In this light, the system of internal 
controls can only provide reasonable, but 
not absolute assurance, against material 
misstatement of financial information 
and records or against financial losses or 
fraud.

The Board has established an ongoing 
process for identifying, evaluating and 
managing the significant risks faced 
by the Bank and this process includes 
enhancing the system of internal 
control over financial reporting as and 
when there are changes to business 
environment or regulatory guidelines. 
The process is regularly reviewed by 
the Board and is in accordance with the 
guidance for Directors of banks on the 
directors’ statement on internal control 
issued by the Institute of Chartered 
Accountants of Sri Lanka. The Board 
has assessed the internal control over 
financial reporting taking into account 
principles for the assessment of internal 
control system as given in that guidance. 

The Board is of the view that the system 
of internal controls over financial 
reporting in place is sound and adequate 
to provide reasonable assurance 
regarding the reliability of financial 

reporting, and that the preparation 
of Financial Statements for external 
purposes is in accordance with relevant 
accounting principles and regulatory 
requirements. 

The management assists the Board in the 
implementation of the Board’s policies 
and procedures on risk and control 
by identifying and assessing the risks 
faced, and in the design, operation and 
monitoring of suitable internal controls to 
mitigate and control these risks.

Key features of the process adopted 

in reviewing the design and 

effectiveness of the internal control 

system over financial reporting

The vital processes that have been 
established in reviewing the adequacy 
and integrity of the system of internal 
controls with respect to financial 
reporting include the following:

•  Various committees are established 

by the Board to assist the Board in 
ensuring the effectiveness of bank’s 
daily operations and that the Bank’s 
operations are in accordance with 
the corporate objectives, strategies 
and the annual budget as well as the 
policies and business directions that 
have been approved.

•  The Internal Audit Division of the 

Bank checks for compliance with 
policies and procedures and the 
effectiveness of the internal control 
systems on an ongoing basis using 
samples and rotational procedures 
and highlights significant findings 
in respect of any noncompliance. 
Audits are carried out on all units 
and branches, the frequency of 
which is determined by the level of 
risk assessed using approved risk 
rating methodologies to provide an 
independent and objective report. 
The annual audit plan is reviewed 
and approved by the Board Audit 
Committee. In line with the approved 
annual audit plan, the Internal Audit 

Division carries out onsite as well as 
offsite internal audits using a variety 
of methodologies and the audit 
findings are submitted to the Board 
Audit Committee for review.  

•  The Board Audit Committee of 

the Bank reviews internal control 
issues identified by the Internal 
Audit Division, the external auditors, 
regulatory authorities and the 
management, and evaluates the 
adequacy and effectiveness of 
the risk management and internal 
control systems. They also review the 
internal audit functions with particular 
emphasis on the scope of audits and 
quality of the same. All minutes of 
the Board Audit Committee meetings 
are forwarded to the Board. Detail 
analysis of the activities undertaken 
by the Audit Committee of the Bank 
are set out in the Audit Committee 
Report on pages 122 to 123.

•  In assessing the internal control 

system over financial reporting, 
identified officers of the Bank collated 
all procedures and controls that are 
connected with significant accounts 
and disclosures of the Financial 
Statements of the Bank. These in turn 
were observed and checked by the 
Internal Audit Division for suitability 
of design and effectiveness on an 
ongoing basis. The assessment did 
not include subsidiaries of the Bank. 

•  The Bank adopted the Sri Lanka 

Accounting Standard – SLFRS 
9 - “Financial Instruments” with 
effect from 1 January 2018. In order 
to comply with the requirements 
of SLFRS 9, the Bank developed 
Expected Credit Loss (ECL) models 
using a wide range of forecast 
economic scenarios to determine 
impairment provisions with the 
support of an external consultant. 
These models have been validated 
by the Internal Audit Division with 

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the assistance of a firm of Chartered 
Accountants. The Bank has taken 
adequate measures to comply with 
the Directions No.13 and 14 issued 
by the Central Bank of Sri Lanka with 
regard to classification, recognition 
and measurement of credit facilities 
under SLFRS 9 effecting from 
01 January 2022 and the same has 
been audited by the Internal Audit 
Division. 

•  The Bank is in the process of 

implementing an automated financial 
reporting solution in order to comply 
with the requirements of recognition, 
measurement, classification and 
disclosure of the financial instruments 
more effectively and efficiently and 
to facilitate the “Financial Statement 
Closure” process. This automated 
solution enables the calculation 
of impairment provisioning under 
SLFRS 9 - “Financial Instruments” and 
facilitates the fulfilling of internal and 
external reporting requirements. 

•  The Bank continued to appreciate the 

changes in the external environment 
during the year 2023 when making 
provisions for foreign currency 
financial instruments and loans and 
advances. The stringent measures 
adopted by the government to 
ease the fiscal and economic 
stresses including domestic debt 
restructuring, changes in the inflation 
and interest rates were taken into 
consideration in this regard. 

•  In 2023, the Bank continued its 

compliance with the remaining 
moratorium packages which were 
introduced by the government to 
provide relief to those affected by 
COVID-19. The residual impact of 
COVID-19 on the Bank’s customers 
in risk elevated industries such as 
tourism, constructions and textiles 
were also considered when assessing 
the impairment provisioning using 

the ECL models under  
SLFRS 9 - “Financial Instruments”.  
On prudential basis, the Bank 
continued to apply the Economic 
Factor Adjustment (EFA) used in 
mid-2023 in calculating the expected 
losses for 2023, as the management 
is of the view that it is too early to 
capture the favourable movements 
in economic parameters reflected in 
end 2023.                                                        

•  A steering committee composing 

of various disciplines of the Bank 
monitors and coordinates the 
implementation of the automated 
financial reporting solution 
with special emphasis on the 
directions issued by the regulator 
for classification, recognition and 
measurement of credit facilities under 
SLFRS 9. 

•  The Bank is continuously monitoring 

and updating procedures inter-alia 
relating to impairment of loans and 
advances of the Bank and foreign 
branches, financial statement 
disclosures, risk management, related 
party transactions and all other 
significant banking activities based 
on the changing regulatory and 
market conditions. The requirements 
under SLFRSs/LKASs and regulatory 
directions have been communicated 
to the relevant stakeholders including 
the Board and senior management 
through training and awareness 
sessions.

•  The comments made by the 

external auditors in connection 
with internal control system over 
financial reporting in previous years 
were reviewed during the year and 
appropriate steps have been taken to 
rectify them. The recommendations 
made by the external auditors in 2023 
in connection with the internal control 
system over financial reporting will be 
addressed in the future.

Confirmation

Based on the above processes, the Board 
confirms that the financial reporting 
system of the Bank has been designed 
to provide a reasonable assurance 
regarding the reliability of financial 
reporting and the preparation of financial 
statements for external purposes and has 
been done in accordance with Sri Lanka 
Accounting Standards and regulatory 
requirements of Central Bank of  
Sri Lanka.

By order of the Board,

Chairman - Audit Committee

Chairman

Director

Colombo, Sri Lanka
18 March 2024