Wednesday, 19 June 2013

Hai Drone Jin Sim Natter

An eensy bit terser version of this review appeared in Interzone 243. Of course it makes rather bittersweet reading now, especially the last bit. Iain Banks you were wonderful & you are missed.

The Hydrogen Sonata tells the story of a crisis sparked by the impending rapture (“Subliming”) of a major galactic civilisation (the Gzilt) into a sort of extra-dimensional transcendental afterlife or überlife thingamajig. As the blessed day draws closer, scores are settled and secrets revealed; rules, manners and mores unravel; meanwhile, scavengers push and shove on the perimeter, ready at the first sign of a civilisation-wide, blissed-out puff of smoke to pounce on whatsoever cool tech and well-appointed worlds that might be going spare. Pretty swiftly everyone’s favourite super-advanced post-scarcity utopian anarchists (the Culture) can’t resist poking their smug pug noses (or hulls, I guess – many of the Culture characters are, crudely speaking, space ships) into the affair.

So I make that … ten Culture books now? Technically each one is stand-alone, though some – The Hydrogen Sonata for one – will surely bewilder the beginner more than others. That’s not to say The Hydrogen Sonata is “a bad place to start” exactly – there are pleasures peculiar to wandering in in media res and figuring out, detective fashion, an already well-established world, and even to feeling the weight of obscure presences you never fully descry. For Banks aficionados awaiting a fix of courageously intelligent, consistently droll, and sporadically pyrotechnically-savage space opera, The Hydrogen Sonata can’t be said to short-change. The cool tech is cool; the intriguing teamwork is intriguing, the gratuitously exotic backdrops are exotic as ever; the grotesque revels are gross as ever (a minor character can have too many penises, you know, Mr Banks); the lovable sidekicks must needs be loved; and the Imperial pomp is copiously pompous (though not technically Imperial). There are tense, matter-of-fact, “one-hobbit-with-one-HP-survives” style military set-pieces. There are pilgrimages to gurus. There is pluck. There are some links to Surface Detail (2010) too, in which disputes over the ethics of simulated Hell escalates into political and military crisis. We’re also in Excession (1996) territory, with the Deep Space Natter novel form – you feel a bit like you’ve stumbled onto a cosmic Wikipedia talk page waaay above your security clearance.

There’s really so much crammed into The Hydrogen Sonata that it may seem an odd choice to dwell so carefully on the wordy and prying committee of principled AI meddlers (whilst, for instance, the thread about the murderous Septame Bangestyn felt ever-so-slightly cursory). Still, I don’t think Banks was wasting skill by selecting this focus and making it work.

Here’s why. Culture novels have been getting good at extrapolating around various sf mainstays (especially VR simulations, subjectivity saved games, and dealings between AI and biological life) in ways which could be catastrophic for storytelling and emotional investment and pacing, but aren’t. For instance – can scenes ever-liable to dissolve as sims, or sims-within-sims, be built such that readers still care for their outcomes? Maybe not! Do readers care about characters who can be restored off a disc if they die? Maybe not! What can an author give a flesh-and-bones hero to do, if AI and snazzy tech can obviously handle the heroism so much better? Maybe nada — “You won’t be contributing, you’ll be jeopardising,” an AI avatar tells Sonata protagonist Vyr Cossont as she insists on protagging along to a climactic battle (p. 432). In general Banks has been admirably reluctant to fudge these snags. Treated candidly, they can serve as sources of strange energies and cathexes and seemingly-warped-yet-utterly-logical narrative structures (contrasting with the flamboyant structural elegance of books like Use of Weapons (1990), Feersum Endjinn (1994) and Inversions (1998)).

I think that’s part of what’s going on in Matter (2008), Surface Detail and The Hydrogen Sonata, and I think it’s part of a larger struggle in many of Banks’ books between materialism and storytelling. That is, between the obligation to the messiness of the universe, and the obligation to freight history with meanings and values which might distort and artificially neaten it.

If I have a niggle – and how many fans will share in it, I don’t know – I could happily have heard a little more overt moral chat!

Sure, various values are implicitly represented and tested – especially those swirling around the themes of prediction (sims again), risk and self-sacrifice (both pointless and pointed). But more explicit lines might have been drawn, and/or a more contemporary aura invoked – Surface Detail was about Hell, and one of its highlights was a level-headed dispute with a thinly-veiled American theocon. The Hydrogen Sonata in a way is about Heaven, plus the whole connected secular caboodle of utopia, revolt and so on. Subliming offers the opportunity to think about the operation of moral calculation and moral instinct in anticipation of salvation, about the ways in which vangardists confront sacrifices and terrible trade-offs (“to murder so many so that so many more may one day –” yadayadayada), and about how they may successfully solicit and/or delusively project such sacrifices and terrible trade-offs, with stunningly complex outcomes. We know Banks is capable of more in-depth and subtle interrogations of eschatological psychology; so maybe he didn’t think we were capable or inclined to attend to them?

Well, I’m not wistful for The Hydrogen Sermon or anything, and to be fair, whilst Subliming is prodigiously fleshed out (ectoplasm’d out?) in that novel, plenty of new mysteries and prospects are generated in the process. So perhaps there is more about this whole Subliming business yet to come. Actually that's quite an exciting thought.

Corporate Responsibility Reporting Assurance (4)

Okay, a sort of interlude to peer into how the accountancy profession and other assurance providers hope to systematise CR reporting. My info here may be a little archaic (often to the tune of four or five years); I’ll try to bring it more up-to-date eventually, but in the meanwhile anyone who wants to chip in, please do!


Despite the mostly voluntary character of CR reporting and assurance, there are many signs of standardisation. Most of the largest 250 companies worldwide use guidelines developed by the Global Reporting Initiative (“GRI”), and they seem to try to keep pretty up-to-date.

Look a little closer, and the full extent of this standardisation is difficult to decipher. The GRI guidelines are widely used in some form or another, but the guidelines are designed to be incredibly flexible. Compliance with the G3 version of the guidelines comes at three “Application Levels” according to how many CR indicators the company is able to report on; compliance can be self-assessed, or checked by the GRI or by a third party; reports can also be assured or not (the next iteration, G4 is likely to drop this feature).

Assurance may also be restricted to certain aspects of a report, and it may be either at the “reasonable” or “limited” level. This last distinction relates to the amount of work done to verify the subject matter. Reasonable assurance results in a positive form of the assurance statement (“is fairly stated”) whereas limited assurance results in a negative form (“nothing has come to our attention to suggest that it is not fairly stated”). Statutory audit of financial statements is always at the reasonable level. Limited assurance is used in a variety of other contexts, for example, in quarterly reviews of financial statements. A KPMG survey in 2008 showed that “the majority of the G250 (51 percent) obtain report assurance that is a ‘limited level’ of assurance—a lower level that requires less work from the assurance provider and therefore lower costs. […] From a company perspective, choosing a limited level is not surprising since assurance on corporate responsibility information is mainly a voluntary activity.”

The most significant standard of assurance provision applicable to the Big Four is the ISAE3000, maintained by the International Federation of Accountants (“IFAC”) through the International Auditing and Assurance Standards Board (“IAASB”). For member organisations, ISAE3000 has become compulsory where there is no national alternative (such as the Australian AS/NZS 5911 standard). This applies to the Big Four through their memberships in ICAEW. Specialist assurance providers (such as SGS and Two Tomorrows) typically don’t use the ISAE3000. It is a very flexible, generic standard, applicable to a wide range of non-audit assurance engagements. It assumes that the scope of the assurance engagement will be set by the reporting entity. In the UK, the Auditing Practices Board (“APB”) has responsibility for implementing standards issued by the IAASB. It does not currently promulgate the ISAE3000. The APB has expressed the view that the ISAE3000 aims to address too broad a range assurance engagements.

Then there’s the AA1000AS standard. The AA1000AS was developed by the non-profit organisation AccountAbility specifically for the assurance of CR reporting. The Big Four comply with this standard at their clients’ discretion. The AA1000AS (2008) seems still to be the most recent incarnation.

KPMG describe their use of the AA1000APS (2003) as a two phase process. Phase 1 considers whether the scope and materiality of the report is appropriate. During Phase 1, KPMG run their own analysis of scope and materiality. This consists of establishing five input channels: stakeholder engagement; media search; sector knowledge (e.g. peer CR reports, industry body guidelines); client knowledge; and prior year CR commitments. Phase 2 considers whether the individual claims are accurate and complete. Phase 2 is a lengthy process of identifying and taxonomising material assertions. “This results in a detailed assurance plan (including a list of people to be interviewed and a list of the required documentary evidence) at corporate, business/regional and site level (if relevant), together with the selection of sites to be visited. The type and amount of evidence required varies depending on the type of assertion and the level of assurance being sought.”

AA1000AS was developed to complement ISAE3000. For example, AA1000AS’s moderate and high levels of assurance, which the standard recommends for “new” and “mature” issues respectively, are intended to be consistent with ISAE3000’s “limited” and “reasonable” levels of assurance.

One important difference between the AA1000AS series and the ISAE3000 is that the assuror’s consideration of “materiality” is not limited in a scope set by the reporting entity. Materiality is a crucial concept of financial audit methodology, that has been carried over into assurance. Very loosely speaking, material information is significant information. It’s what matters. (I may get more detailed elsewhere).  Under the AA1000AS series, the assuror assesses the degree to which the reporting entity’s scope has correctly identified its stakeholders and their needs. In other words, the assuror must make judge the reporting entity’s choices about what is and is not significant, by appeal to its stakeholders.

So those are the main standards used in the assurance of CR reporting. The Big Four have also developed their own tools relating to CR reporting, for instance Deloitte’s Sustainability Reporting Scorecard (2004), thirty criteria against which to assess a CR report. I’m not sure how much uptake there was of this.


There is comparatively little independent monitoring of this assurance itself (well, you do have to stop somewhere, I suppose). The G3 includes guidance on satisfactory assurance, but compliance must be self-assessed. One GRI representative commented, “An organization should look at the definition on pg. 38 of the GRI Guidelines and make its own assessment in conjunction with the assurance provider as to how they wish to communicate their engagement publicly. We will not take a position on whether a given engagement does or does not constitute ‘external assurance’ as it is impossible for us to assess the full range of engagements put in front of us” (2009).

AccountAbility don’t monitor the use of the AA1000AS (2008) to a detailed level. Each use of the AA1000AS (2008) in an assurance statement requires payment of a license fee to AccountAbility. AccountAbility pre-checks only the statement itself, although an acceptable statement must include a description of methodology. In partnership with the International Register of Certificated Auditors (“IRCA”), AccountAbility offers individuals training and certification in the use of AA1000AS (2008). AccountAbility also has an assuror membership programme (which includes all of the Big Four). However, neither of these are requirements to use the AA1000AS (2008).

The accountancy profession’s self-regulation mechanisms monitor compliance with the ISAE3000. In the context of indepedence, it's worth pointing out that the organisations which embody these mechanisms scoop their members from the cream of the accountancy profession, including Big Four partners. A quick scan suggests that about half the members of the APB are current or former associates of the Big Four, with the remainder drawn from business, law or academic backgrounds. The Big Four are also well-represented on the IFAC board.

High-level oversight of the ISAE3000 is provided by the Public Interest Oversight Board (“PIOB”), an extension of IFAC. In the UK, an infringement of the ISAE3000 would be reported to the professional body of which the firm or one of its employees was a member. All of the Big Four are institutional members of the Institute of Chartered Accountants in England and Wales (“ICAEW”). The Financial Reporting Council (“FRC”) is the UK’s independent regulator responsible for the accountancy and audit profession. The FRC, through its Professional Oversight Board (“POB”) has a statutory responsibility to ensure that these bodies have effective arrangements in place to investigate complaints against their members and member firms. The FRC recommends that professional bodies escalate cases concerning the public interest to its Accountancy & Actuarial Discipline Board (“AADB”). The AADB may also autonomously initiate investigations. As noted above, the APB does not currently promulgate the ISAE3000. In 2009, Executive Director of the APB commented, “While the ICAEW have some sort of monitoring of all services provided by audit firms in the UK (Practice Assurance), in reality I think it is fair to say that there is no monitoring of compliance with it [the ISAE3000].” There is thus something of a regulatory gap; certainly there is less oversight of this standard than of comparable audit standards.

A few more bits & pieces

In addition to all these standards and frameworks described, the Big Four aim to conduct their assurance work in accordance with the Code of Ethics for Professional Accountants, maintained by IFAC’s International Ethics Standards Board for Accountants (“IESBA”), as well as with their own codes of conduct and independence policies, and with appropriate national laws.

Important national legislation includes SOX, enacted in the US in 2002 in the aftermath of a number of major corporate and accounting scandals, above all the collapse of Enron and subsequently of their auditors, Arthur Andersen. Among its provisions, it prohibits professional services firms from doing audit and certain consultancy work for the same client. SOX also extends the scope of statutory audit to a range of internal fraud-prevention controls. ICAEW comments, “The most effective way to ensure the reality of independence is to provide guidance centred around a framework of principles rather than a detailed set of rules that can be complied with to the letter but circumvented in substance.” The focus of these blog posts is the UK system, characterized by this “principles”-based approach. It should be noted however that in the US context, largely as a consequence of SOX, threats to independence are subject to far greater “bright line” legislative specification and governmental regulation.

Finally, an there is the Audit Firm Governance Code, a code of best practice applicable to firms that audit more than twenty listed companies. This comprises the Big Four and four other large professional services firms. As far as I’m aware this doesn’t contain any provisions which are not chiefly oriented to the audit of financial statements.

Okay! Onward!

Monday, 10 June 2013

Rather dull note for Public Administration Select Committee about digital democracy

This is a note about the way forward for online participation of the UK citizenry in our government.

Public consultations justly have a bad name. So indeed do stakeholder consultations.

For a period of several years I was involved with private sector market research and, frequently, public sector consultations. Confidentiality forbids me from sharing specific examples, but I grew used to hearing the growing horror of stakeholders gradually realising how limited their scope of influence was, on issues on which they were more passionate, more informed, and more directly influenced by than whoever was driving policy, and despite the trappings of open and responsive governance.


(a) I think the government tends to forget that it has a responsibility to assess the invested interests of those who participate in consultations. In particular, there is a tendency to think that businesses are experts in their own affairs, and that they can therefore be expected to make the best decisions for the economy and the country on sector-specific issues. In fact we live in such an interconnected world that there is no such thing as a purely sector-specific issue; the government have a responsibility to be critical of these sources, and to try to work out what the big picture is.

(b) I think stakeholder mapping is usually very badly done. There is often a slippage in sense from "anyone whom this issue affects" (a good definition of a stakeholder) to "those who are already influential in this area, and/or already present themselves as knowledgeable" (a poor definition).

(c) My strong intuition is that no matter how hard government (or any organisation) promises to itself it really will listen to its stakeholders this time, the only way to genuinely drive policy change through stakeholder engagement is to delegate real power to stakeholders - or at least to allow stakeholders to impose penalties if, in their considered judgement, the engagement process has not been material.

The issue, of course, is then whether you have the courage to delegate power to stakeholders who may disagree with you!


None of the following suggestions really make my heart leap, but I find it tricky to come up with anything better.

I am slightly worried that such measures might be adopted and executed badly. They might then serve as evidence that online participation is simply impractical.

So here are a few thoughts on online participation (apologies; they are slightly disjointed).

The UK should be leading the way in online participation, not half-heartedly trying out experiments we know will probably fail, so that we can have the excuse, "Well, we gave it a bloody good shot!"

I suppose a good principle to begin with is what the de facto citizen is like.

We shouldn't romanticize the notion of the citizen. We are often: overworked, harried, short on time, money, patience, passionate about issues but also nervous and defensive about a lack of deep knowledge of them, willing to learn, but also distrusting of all information on topics of public interest, without necessarily the time nor the inclination to be critical of that information, and craving the security and simplicity of authoritative information sources, or of timeless truths (typically cynical and/or vague dogmatism).

So "involving" us isn't just a matter of making government more permeable to the pre-existing knowledge, energy & deliberative resources of the citizenry. It is also finding ways to cultivate & nourish those things.

The trouble about polls is that there are just so many of them. One avenue worth exploring is making participation in official polls a bit more like voting: for instance, you can only vote in these polls once per month, so you'll choose the issue that's important to you, and not feel guilty about the rest. (Twelve votes per year might be better than one per month, for the sake of flexibility).

Letter-writing & petitions obviously have their place, but they feel rather dated. They take time and energy. The results are often discouraging (38 Degrees campaigns are a partial exception). They are only indirectly educative. We surely now have the technology to make the activities of government far more transparent, and to be able feedback on those activities at a fine grain, and for our government to be minutely responsive to that feedback. We have social networking and social browsing; why not social scrutiny of government?

We need to think about the notion of the "popularity" of information, and how the effects of particular items "going viral" could be usefully included in the interface between public and government. Not everything can receive equal attention, but it is not for the government to decide what is and isn't important. Nor can we any longer trust the opposition and traditional media to make such a selection. We the public must also be directly involved in determining relevance. At the same time, this is obviously risky territory. Information can become popular based on shallow considerations.

So in terms of online interaction, we also need to think about the relationship between the serious & official, and the casual, satirical, just-for-fun. Obviously not every tweeted joke, every "OMFG!" or ever photoshopped jpeg is an equally venerable and sacred exercise of a democratic right. At the same time, if you simply exclude the flippant, anarchic & playful side of things, you risk creating an arena for engagement which is dull, excessively hard work, and unrepresentative of the citizenry - being dominated by anoraks, humourless sorts, and special interests. You fail to cultivate & nourish the knowledge, energy & deliberative resources of the citizenry. (We also need to think about trolls. We also need to think about astroturf).

I don't have any big answers, but a small example might point us in roughly the right direction. Scenario A is that there is a comments section beneath Parliament TV. It obviously looks rather like the thread of pretty much any YouTube clip, and it confirms everyone's suspicion that we, the British public, are idiots.

Scenario B is that Parliament TV is integrated with Facebook, Twitter, Tumblr, etc., as well as bespoke social networking sites. Users can comment on issues raised and share specific segments of the filmed proceedings, or transcripts thereof, and can filter the annotative activity of other users in a variety of ways. There is, for example, a "readers who liked this comment tended to also like these comments" feature, so it's not just a matter of what's popular or not - people with common purposes or ideas can find one another. There are incentives for independent fact-checking to flourish. Where jargon or specialised language appears, it is easy to click through to get definitions and explanations. Those readers who persevere on such a path can even find educative resources in the underlying theory. You may start your day seeing a funny photoshopped pic, proceed to the news story on which it is based, then find yourself enrolling in an online course in economics or environmental science. Openness is a guiding principle throughout. The online architecture has been designed with the frictionless experience of the end user, the citizen, kept firmly in mind.

But at the same time, we learn what the culture of parliament is like. What is it like to be an MP or a civil servant? What restrictions do they feel upon their speech and action? What is it they think the public don't understand about their position? What is it they feel they are blamed for that is beyond their control? How do even those who are in government feel their ability to govern as they would like, to make the decisions they really want to make, is restricted by their party, by the markets, by the economy, by specific commercial interests, by existing statutes and case law, by the media, by the European and international context? It may sound paradoxical, but e-democracy isn't just about increasing and improving the participation of the public in governing. It's also about increasing and improving the participation of the governors in governing.

To summarise slightly reductively: online participation needs to be frictionless, fun, and educative. It needs to imaginatively exploit cutting edge technologies, not just transfer pre-digital practices online.

What have the more far-thinking and imaginative theorists of e-democracy proposed? Has the Public Administration Select Committee interviewed anyone who fits that description?