Strengthening Oversight: Lessons from the 2024 Pakistan Case

In 2024, APSCA conducted a large investigation in Pakistan that revealed how gaps in firm oversight of third parties—consultants, staffing agencies, and even brand representatives—can compromise audit independence and integrity. We’d like to share insights from the case and best practices with our Member Firms, to ensure that the proper steps are in place to fortify our members and uphold professional standards.

Identified Compromises in Pakistan audits:

Confidential audit scheduling information mishandled
Conflicts of interest and Inducement by 3^rd parties undetected
Independence compromised under external pressure

The impact extends beyond individual firms—it undermines industry trust and places workers at risk. It also highlights the opportunity for more focused oversight and controls in regional offices by Member Firms.

Case Highlights

Scope of Review: 96 auditors | 24 firms | 5,196+ audits
Findings: Misreporting attendance, credential misuse, external influence from consultants/brands
Outcomes: Auditor sanctions, firm remediation, Pakistan office closures

Root Causes: Control Gaps in management system control over scheduling and subcontractors. Intentional harm caused by collusion amongst auditors to commit fraud related to proper attendance records and misused credentials.

Key Firm Takeaways

Firms must protect your organizational value by carrying out consistent oversight of anyone acting on their behalf:

✅ Directly manage scheduling – Do not outsource of critical control points
✅ Oversee subcontractors as employees – Equal standards, same accountability
✅ Verify attendance – No assumptions, only verifiable evidence
✅ Protect confidentiality – Track and document communication between consultants, staff, and reps to uphold audit confidentiality
✅ Safeguard independence – Actively resist & report influence attempts both internally and to APSCA
✅ Train continuously – Instill a culture of integrity expectations for auditors and support staff

The Industry Impact

❌ Without Strong Oversight

Damaged trust from brands, programs, and workers
Increased regulatory & reputational risks
Erosion of credibility in social compliance auditing

✅ With Accountability & Equitable Oversight

Stronger industry reputation
Protection of workers’ rights
Trust in firms and the auditing profession

Every auditor (whether employed or subcontracted), consultant, and representative reflects your Firm’s integrity. Firms cannot delegate accountability—oversight is non-negotiable.

Looking Ahead

APSCA calls on all Member Firms to reinforce independence, protect confidentiality, and strengthen accountability across all parties involved in audits. Effective training programs and ample oversight properly implemented at the Member Firm level, are required to set expectations and enforce accountability around audit integrity.

Together, we ensure that audits remain credible and fulfill their purpose: protecting workers worldwide.

Who we are

Our Members

Stay Updated