preparing the funafuti water and sanitation project ...proposed project readiness facility for...

PROPOSED PROJECT READINESS FACILITY

FOR PREPARING THE FUNAFUTI WATER AND SANITATION PROJECT, TUVALU

FINANCIAL MANAGEMENT ASSESSMENT

FEBRUARY 2020

I. Introduction

1. A financial management assessment (FMA) was conducted in February 2020 for the PRF, in accordance with ADB’s Guidelines for the Financial Management and Analysis of Projects1 and the Financial Due Diligence: A Methodology Note.2 The FMA considered the capacity of the MOF, as the executing agency/implementing agency, including funds-flow arrangements, staffing, accounting and financial reporting systems, financial information systems, and internal and external auditing arrangements. The FMA consisted of: (i) interviews with key staff of MOF and Office of the Auditor General (OAG); (ii) evaluating the organizational structure, personnel, accounting policies and procedures, internal and external auditing, financial reporting and budgeting, with the assistance of responses to the FMA Questionnaire (FMAQ) and other documents; and (iii) identification of potential risks and mitigation measures. The assessment also made extensive use of the Tuvalu Public Finance Act 2008 Revised Edition3, the Public Expenditure and Financial Accountability (PEFA) Report for Tuvalu 20114, IMF 2018 Article IV Consultation5, and the financial management assessments for the ADB-funded Outer Island Maritime Infrastructure Project Additional Financing of April 20186, the Systems Strengthening for Effective Coverage of New Vaccines in the Pacific Project of October 20187 and the Increasing Renewable Energy Project of October 20198. The financial management capacity of MOF is considered adequate, although it is concluded that the overall pre-mitigation financial management risk is substantial. Key findings of the financial management assessment undertaken on MOF are as described in Table 1:

Table 1: Summary of Financial Management Assessment of MOF

Particulars Conclusion

1. Implementing Agency MOF has only been a Borrower/Recipient of all ADB-funded projects and an EA for 2 ongoing ADB-funded projects. MOF has not been an IA for ADB-funded projects.

2. Funds Flow Arrangement

Arrangements are reliable, predictable and secure.

3. Staffing A new CPMU will be setup in MOF and will include a new project manager and a new project accountant, who will be trained on ADB’s disbursements, financial reporting and auditing requirements.

4. Accounting Policies and Procedures

MOF prepared the 2017 TWOG financial statements on an accrual basis in accordance with the Tuvalu GAAP. For the 2018 TWOG financial statements, MOF is preparing it on a modified cash basis in accordance with IPSAS and the project will do the same.

5. Internal Audit An Internal Audit Division was established in MOF in December 2016 and has 2 new staff.

1 Available at: https://www.adb.org/documents/financial-management-and-analysis-projects. 2 Available at: https://www.adb.org/documents/financial-due-diligence-methodology-note. 3 Available at: https://www.global-regulation.com/law/tuvalu/9334495/public-finance-act.html 4 Available at: https://pefa.org/node/1756 5 Available at: https://www.imf.org/en/Publications/CR/Issues/2018/07/05/Tuvalu-2018-Article-IV-Consultation-Press-Release-Staff-Report-and-Statement-by-the-46051

6 Available at: https://www.adb.org/sites/default/files/linked-documents/48484-004-sd-04.pdf 7 Available at: https://www.adb.org/projects/documents/reg-50282-001-pam 8 Available at: https://www.adb.org/sites/default/files/linked-documents/49450-015-sd-02.pdf

6. External Audit Conducted by the OAG in accordance with ISSAI. For the 2016 and 2017 TWOG financial statements, OAG issued a disclaimer of opinion due to limitation of scope and some of OAG’s recommendations remain outstanding.

7. Reporting and Monitoring

The new project accountant might not be familiar with ADB’s financial reporting requirements and ADB will be provided training on this.

8. Information Systems All Ministries use Microsoft Excel for their financial reporting purposes and only MOF uses Sage 300 software (previously known as ACCPAC). As Sage 300 does not have a project module, the CPMU will purchase the MYOB accounting software to use, as is being done under the OIMIP-TUV project.

ADB = Asian Development Bank; CPMU = centralised project management unit; GAAP = Generally Accepted Accounting Practice; IPSAS = International Public Sector Accounting Standards; ISSAI = International Standards of Supreme Audit Institutions; OAG = Office of the Auditor General; MOF = Ministry of Finance; TWOG = Tuvalu Whole of Government.

II. Project Description

2. The Government of Tuvalu (GOT) requested ADB for assistance to support the water and sanitation sector in Funafuti. The proposed PRF is aligned with Tuvalu’s National Strategy for Sustainable Development 2016–20209 and ADB’s country operations business plan 2020–2022 for Tuvalu (and 10 other small Pacific Island countries).10 The Pacific Approach 2016-2020, which is ADB's operational framework for the Pacific, serves as the country partnership strategy for Tuvalu (and 10 other small Pacific island countries).11 3. The proposed PRF will facilitate the preparation of the proposed Funafuti Water and Sanitation Project and the transition to smooth project implementation. It will also streamline the initial investment project contract awards and expedite initial disbursements for the project. The PRF will finance investments to: (i) Output 1 - create an enabling environment for the ensuing investment project and to work closely with ADB to prepare the project; and (ii) Output 2 - identify and procure key project components.

4. Output 1 will: (i) support activities to strengthen the government’s water supply and sewerage services including capacity development in water supply and sanitation, establishment of a Central Project Management Unit (CPMU), and the provision of an international project manager/water supply and sanitation specialist and a project accountant; (ii) support the establishment of a Centralized Water Authority to improve water management in Funafuti; (iii) design and implement a public awareness and community outreach campaign focusing on water resource and sanitation, and related climate change issues with special focus on women and girls, and foster community understanding and support for the project; and (iv) assist the government to review, and if appropriate, implement reforms to its water supply and sewerage tariff framework. 5. Output 2 will: (i) prepare the sector strategy and strategic documents for government to deliver resilient, sustainable, and affordable water supply and sanitation services in Funafuti from 2020 to 2040; (ii) identify the project scope; (iii) prepare the project due diligence; (iv) confirm project financing; (v) design the project’s hygiene awareness and education program; and (vi) procure project components. Deliverables under Output 2 include the preparation of gender-inclusive master plans, strategic plans, feasibility studies, detailed engineering design and surveys, bidding documents, and procurement assistance.

9 Available at: https://www.adb.org/sites/default/files/linked-documents/cobp-tuv-2017-2019-ld-02.pdf 10 Available at: https://www.adb.org/sites/default/files/institutional-document/532541/cobp-pic11-2020-2022.pdf 11 Available at: https://www.adb.org/documents/pacific-approach-2016-2020

6. The proposed PRF will finance consulting firms, nongovernment organizations and individual consultants, to work on the 2 outputs. III. Country and Sector Financial Management Issues 7. Statutory provisions relating to public finance are enshrined in Part IX of the Constitution12 which gives the Parliament, control over public finance in a number of ways, such as approval of the annual budget and appropriations including supplementary budgets and supplementary appropriations, tabling of audited accounts of the government and public enterprises, deliberations through the Public Accounts Committee and questions raised on the floor of the Parliament. 8. The Public Finance Act 200813 details the responsibilities, rules and regulations relating to the Minister of Finance, operation of the Consolidated Fund (CF) and other public funds, management of deposits, powers of the Auditor General (AG) and audit of public accounts. Pertinent provisions include: (i) the appointment of an Accounting Officer for each expenditure head of the budget who is personally accountable for the monies collected/received and disbursed; (ii) creation of a Development Fund separate from the CF as a repository for bi-lateral aid to operate in accordance with rules and regulations under the Public Finance Act; (iii) the Tuvalu whole of government accounts (TWOG) to be submitted to the AG within six months of the financial year end and to include a statement of assets and liabilities, in addition to a statement of receipts and payments, comparison of actual and estimated revenue and expenditure, and statements of funds, deposits and public debt; (iv) AG is required present the audited financial statement to Parliament within nine months of the end of the financial year; and (v) the AG shall be the auditor of every public body set up by an Act of Parliament. 9. Public Financial Management (PFM) is the legal framework which institutions (laws, processes, procedures, entities and systems) use to prepare, plan, execute and control the national budget. The Public Expenditure and Financial Accountability (PEFA)14 is the methodology for assessing PFM performance and reviews are carried out by the PEFA Secretariat, which is part of the World Bank. The PEFA program is managed by seven international development partners - World Bank, IMF, European Commission and the governments of France, Norway, Switzerland and the United Kingdom. The last PFM assessment on Tuvalu was carried out by PEFA in June 2011 and concluded that: (i) the budget formulation process is satisfactory with a meaningful classification system and clear budget calendar. However, there have been instances of the lack of expenditure restraint and over use of supplementary budgets; (ii) the budget classification used is consistent with IMF Government Finance Statistics and is comprehensive and informative although greater dissemination of information to the public is encouraged; (iii) the Medium Term Fiscal Framework provides estimates of future budget aggregates; (iv) release of budget through the warrant system is effective and so is the payroll. However, revenue collection and procurement need improvement; (v) reconciliation delays in bank and vote ledgers, and in the submission of the government financial statements for audit within the statutory period of six months; and (vii) external scrutiny and audit. AG’s audit report has been on time and the Public Accounts Committee (PAC) plays an active role in scrutiny. The lack of an internal audit division was a weakness and a number of the AG’s recommendations remain outstanding.

12 Available at: http://www.tuvaluislands.com/const_tuvalu.htm 13 Available at: https://www.global-regulation.com/law/tuvalu/9334495/public-finance-act.html 14 Under the PEFA framework, performance is assessed in relation to seven dimensions of public financial management: credibility of the budget; comprehensiveness and transparency; degree to which the budget is prepared with due regard to government policy; predictability and control in budget execution; accounting, recording and reporting; external scrutiny and audit operations; appropriateness of development partner practices in country; and intergovernmental fiscal relationships.

10. In September 2015, an Update on the Assessment of National Systems (ANS) was conducted, jointly, with a PEFA self-assessment, which was supported by Pacific Technical Assistance Centre. The 2015 ANS noted that budget management had been strengthened, a payroll reconciliation exercise is conducted annually, non-salary expenditure controls have been tightened by reforms to Treasury and accounting systems, an internal audit function is expected to be established by 201715, and changes that were introduced to reporting systems have been sustained. 11. An IMF Article IV consultation was conducted with the GOT in June 2018 and concluded that medium-term budget framework (MTBF) needs strengthening and improvements are needed to the PFM framework. MTBF could be improved with better revenue and spending forecasting methodologies, which would help improve the credibility of the annual budget process. PFM reform priorities include introducing competitive tendering for procurement under a centralised unit, ensuring adequate maintenance spending on capital assets, and standardising fiscal account classification between the Treasury and Budget Divisions. The authorities also need to improve the reliability of monthly fiscal reporting. Aligning these priorities with program grants of development partners, would help accelerate key reforms. 12. GOT prepared the 2017 TWOG financial statements on an accrual basis, in accordance with the generally accepted accounting practice in Tuvalu (Tuvalu GAAP), which where necessary, looks to the International Public Sector Accounting Standards (IPSAS) and International Financial Reporting Standards (IFRS) to guide general accounting policy. The TWOG financial statements are presented to the AG, GOT’s external auditor, for auditing in accordance with the International Standards of Supreme Audit Institutions (ISSAI). The last audit report issued by the AG was in October 2018, for the financial year ended 31 December 2017 and the AG issued a disclaimer of audit opinion on the basis of limitations of scope resulting primarily from: (i) uncertainty surrounding valuation, completeness and existence of property plant and equipment in the financial statements; (ii) lack of evidence to support prior year comparatives; (iii) cash unable to be reconciled to bank statements, and movement in cash balances unable to be reconciled to the statement of assets and liabilities; (iv) inability to obtain satisfactory explanations and documentation regarding a sample of entries for expenses in the financial statements; (v) non-consolidation of 3 public enterprises16; (vi) lack of evidence to support completeness of account receivable and revenues financial statements; (vii) the non-inclusion of inventory in the financial statements; and (viii) limitation of scope surrounding cabinet minutes and decisions. Most of the limitations are due to the TWOG being done on a cash basis and certain accounting entries are passed at the year-end, to enable it to be considered as on an accrual basis. Furthermore, on the issue of property, plant and equipment, MOF maintains a fixed asset register (FAR) on Microsoft Excel spreadsheets. The non-consolidation of 3 public enterprises due to the non-availability of financial statements present a significant shortcoming, especially as NAFICOT is likely to have relatively large assets and liabilities. GOT is preparing the 2018 TWOG financial statements on a modified cash basis, in accordance with IPSAS. IV. Project Financial Management System

A. Overview of the Executing/Implementing Agency, Financial Management and Institutional Context

13. MOF is the Recipient of the ongoing ADB-funded G6003/G0511/G0512/G0513/G603-

15 An internal audit division was established in MOF in December 2016. 16 National Fishing Corporation of Tuvalu (NAFICOT), Tuvalu Post Limited (TPL) and Tuvalu Maritime Training Institute (TMTI)

TUV: Outer Islands Maritime Infrastructure Project (OIMIP) and the EA for 2 other ongoing ADB-funded projects: (i) G0625-REG: Systems Strengthening for Effective Coverage of New Vaccines in the Pacific Project, which was approved in November 201817; and (ii) G0674-TUV: Increasing Access to Renewable Energy Project, which was approved in November 201918. MOF is also the EA for World Bank, EU, GCF and UN Agencies projects. 14. Currently, only the ADB-funded OIMIP is using ADB’s Client Portal for Disbursements (CPD) system, which facilitates online submission of withdrawal applications to ADB, resulting in faster disbursement. CPD registration arrangements are underway for the other 2 ADB-funded projects to also use the system. For the ongoing OIMIP, some of the withdrawal application authorized signatories are based in MOF and are well-versed with using the CPD system, as they attended ADB’s disbursements and financial management training in-country in 2016 and in Fiji in 2019. Also, for the ongoing OIMIP, other MOF staff are viewers in the CPD system, where they can view the withdrawal applications that are created by the project accountant, who is based in the PMU.

B. Personnel, Accounting Policies and Procedures, Internal and External Audit 15. MOF is a ministry of the GOT and is headed by a Minister. Reporting to the Minister is a Chief Executive Officer, a Deputy Secretary and Directors of the following Divisions: (i) treasury; (ii) planning, budget and aid coordination; (iii) inland revenue; (iv) customs; (v) public enterprise monitoring; (vi) business and private sector; (vii) climate change; (viii) internal audit; (ix) central procurement; (x) statistics. The Treasury Division, where all TWOG payments are centralized, is headed by the Government Accountant and there are three Teams: (i) office and administration; (ii) payroll and imprest; (iii) financial reporting. The total number of staff in MOF is 85 and there are 21 staff in the Treasury Division. Refer to Appendix 3 for the Organisation Chart of MOF and Appendix 4 for the Organisation Chart of the Treasury Department. 16. Under the proposed PRF, MOF will establish a new Centralised Project Management Unit (CPMU) in the Ministry, to oversee implementation. The proposed PRF will fund a new project manager/water supply and sanitation utility consultant, a project accountant, a regulatory and institutional consultant, a community communications consultant, and a Tuvalu-based nongovernmental organisation. Once their funding is confirmed, the World Bank will also fund other positions in the CPMU, to oversee implementation of their projects. The ADB-funded project manager and project accountant may not have the required experience with ADB-funded projects and will need to be trained on ADB’s disbursements, financial reporting and auditing requirements. They will also need to carefully manage their workload and ensure that all of ADB’s requirements, during the implementation of the proposed project, are complied with. 17. MOF will maintain separate PRF project accounts and records, by funding source, for all expenditure incurred on the proposed PRF project, following modified cash basis of accounting. PRF project accounts will follow international accounting standards or standards prescribed by the government’s accounting laws and regulations.19 18. An Internal Audit Division (IAD) was established in MOF in December 2016, following recommendations from the Auditor General (AG) and the PEFA review. The objective of internal audit is to provide assurance of internal controls and compliance with policies and procedures of GOT. The Head of the Division, who has bachelor’s degree in commerce in accounting and economics, was appointed in 2017 and a 5-member audit committee was also established, to

17 Available at: https://www.adb.org/projects/50282-001/main 18 Available at: https://www.adb.org/projects/49450-015/main 19 Available at: https://www.global-regulation.com/law/tuvalu/9334495/public-finance-act.html

meet quarterly. DFAT provided a short-term technical advisor to the IAD, who assisted with their first internal audit in 2018. A second staff, who has a bachelor’s degree in finance, was appointed to the IAD in 2019. In February 2020, DFAT funded a 2 week secondment of the Head of the Division, to the IAD of the Ministry of Economy in Fiji, which he found very useful. As the IAD staff do not have knowledge or experience with ADB-funded projects, they will be invited to future training on ADB’s disbursements, financial reporting and auditing requirements.

19. GOT’s external auditor is Tuvalu’s Supreme Audit Institution (SAI), the OAG. The establishment and independence of the AG is granted under the Constitution of Tuvalu, (Part IX: Finance) and the Audit Act provides for an annual appropriation of a minimum of 0.6%, of the total appropriation of the GOT, to the AG’s office. OAG audits all ADB-funded projects and the AG and some of his staff attended training on ADB’s disbursements, financial reporting and auditing requirements in-country in 2016 and in Fiji in 2019. OAG staff will continue to be invited to future training on ADB’s disbursements, financial reporting and auditing requirements. 20. MOF will cause the detailed project financial statements to be audited following the International Standards for Supreme Audit Institutions, by an independent auditor acceptable to ADB (refer to Appendix 5 for Auditor TOR). MOF will present the audited project financial statements together with the auditor’s opinion, in English, to ADB within 6 months from the end of the fiscal year. 21. The audit report for the project financial statements will include a management letter and auditor’s opinions, which cover: (i) whether the project financial statements present an accurate and fair view or are presented fairly, in all material respects, following the applicable financial reporting standards; (ii) whether the proceeds of the grant were used only for the purposes of the project; and (iii) whether the Recipient or executing agency complied with the financial covenants contained in the legal agreements (where applicable).

22. MOF will monitor compliance with financial reporting and auditing requirements during review missions and normal program supervision, and will follow up regularly with all concerned, including the external auditor. 23. ADB has made the government and MOF aware of ADB’s approach to delayed submission and the requirements for satisfactory and acceptable quality of the audited project financial statements.20 ADB reserves the right to require a change in the auditor (in a manner consistent with the constitution of the Recipient), or for additional support to be provided to the auditor, if the audits required are not conducted in a manner satisfactory to ADB, or if the audits are substantially delayed. ADB reserves the right to verify the project’s financial accounts to confirm that its policies and procedures were followed when the share of ADB’s financing was used.

20 ADB’s approach and procedures regarding delayed submission of audited project financial statements:

(i) When audited project financial statements are not received by the due date, ADB will write to the executing agency advising that (a) the audit documents are overdue; and (b) if they are not received within the next 6 months, requests for new contract awards and disbursement such as new replenishment of advance accounts, processing of new reimbursement, and issuance of new commitment letters will not be processed.

(ii) When audited project financial statements are not received within 6 months after the due date, ADB will withhold processing of requests for new contract awards and disbursement such as new replenishment of advance accounts, processing of new reimbursement, and issuance of new commitment letters. ADB will (a) inform the executing agency of ADB’s actions; and (b) advise that the loan may be suspended if the audit documents are not received within the next 6 months.

(iii) When audited project financial statements are not received within 12 months after the due date, ADB may suspend the loan.

24. ADB’s Access to Information Policy will guide the public disclosure of the audited project financial statements, including the auditor’s opinion on the project financial statements. After the review, ADB will disclose the audited project financial statements and the opinion of the auditors on the project financial statements no later than 14 days of ADB’s confirmation of their acceptability by posting them on its website. The management letter, additional auditor’s opinions, and audited entity financial statements will not be disclosed.21

C. Financial Reporting Systems, including Use of Information Technology 25. As a government ministry, MOF forms part of the GOT budget. MOF takes the lead in the preparation of the budget preparation, according to an established schedule, working towards the approval of the budget in Parliament, in October each year. The budget includes actual expenditure, both recurrent and non-recurrent for the budget year, forecast for the previous year, actual for the year prior to the immediately previous year, and projections for next two years. It also provides a commentary of the major activities and achievements. The government financial year is the calendar year. 26. MOF’s financial operations are reported using the TWOG financial statements which, for the year ended 31 December 2017, was prepared on an accrual basis, in accordance with the Tuvalu GAAP, which where necessary, looks to the IPSAS and IFRS to guide general accounting policy. All Ministries/Departments prepare financial statements on a cash basis which are consolidated by MOF. MOF then recognises fixed assets through an adjustment to equity. Accounts receivable (from revenues from taxation, fisheries licenses and customs) are also adjusted for, by MOF. TWOG statements include those of public enterprises. MOF uses Sage 300 (formerly known as Sage ACCPAC) software as its financial management information system (FMIS) to prepare the TWOG. Sage 300 is only used by the Treasury Division, for the consolidation of TWOG, and not at any of the other government Ministries/Departments, who continue to use manual Votes Ledger on MS Excel to record actual expenditure against budgeted expenditure. These expenditures are then re-entered into Sage 300 by the Treasury Division, MOF for the purpose of TWOG. Once this is done, an attempt is made to convert the hitherto transactions on a cash basis to accrual basis, by incorporating fixed assets, accounts receivable and payables through journal entries. Whilst this approach is error-prone and time consuming, it is against the spirit of double entry accounting where single entry transactions are converted in this manner. The TWOG financial statements for the year ended 31 December 2018, are being prepared on a modified cash basis in accordance with IPSAS. 27. MOF are planning to change to a new accounting system, which TWOG can use, and have hired a local consultant to start work on this. MOF will also look into the new system having a project module, which the CPMU and other PMUs, can use for their project accounting work. As the change to the new accounting system will take time, the proposed PRF can procure the MYOB accounting software to use, as is already successfully being used under the ongoing OIMIP.

D. Disbursement Arrangements, Funds Flow Mechanism 28. As the Recipient of the ongoing OIMIP, MOF staff are viewers and approvers of withdrawal applications that are submitted online in the CPD system, by the project accountant who is based in the PMU. Registration arrangements are underway for the other 2 ADB-funded projects, to also use the CPD system. MOF staff also attended ADB training on disbursements, financial reporting and auditing requirements in-country in 2016 and in Fiji in 2019.

21 Such information generally falls under access to information policy exceptions to disclosure (ADB. 2018. Access to Information Policy: Disclosure and Exchange of Information. Manila [para. 17(1-7)].

29. MOF will disburse the project readiness grant proceeds, following the Asian Development Bank (ADB) Loan Disbursement Handbook (2017, as amended from time to time), and detailed arrangements agreed between the government and ADB. Online training for project staff on disbursement policies and procedures is available.22 Project staff are encouraged to avail of this training to help ensure efficient disbursement and fiduciary control. 30. Direct payment and reimbursement disbursement procedures will be used for disbursements for the consulting services contracts under the proposed PRF. The direct payment disbursement procedure is where the ADB, at the beneficiary’s request, pays a designated beneficiary (e.g. consultant) directly. The reimbursement procedure is where the ADB pays from the proposed PRF grant to the Recipient’s account, for eligible expenditures which have been incurred and paid for by the Recipient, out of its budget allocation or its own resources.

31. The project accountant, who will be based in the CPMU, will create the withdrawal applications, with complete supporting documents, for submission to MOF staff, for their review and approval and then to ADB for the processing of payments. All these processes will be done online in the CPD system. 32. Before submitting the first withdrawal application, the government should submit to ADB sufficient evidence of the authority of the persons who will sign the withdrawal applications on behalf of the government, together with the authenticated specimen signatures of each authorized person. The minimum value per withdrawal application is stipulated in ADB’s Loan Disbursement Handbook. Individual payments below such amount should be paid (i) by MOF and subsequently claimed from ADB through reimbursement, unless otherwise accepted by ADB. The Recipient should ensure sufficient category and contract balances before requesting disbursements. Use of ADB’s Client Portal for Disbursements system is encouraged for submission of withdrawal applications to ADB.23 33. No further disbursements will be made from the PRF account upon refinancing under an ensuing or ongoing loan. The PRF loan amount and accrued financing charges are paid out under the PRF cost category of the ensuing or ongoing loan that will refinance the PRF loan. Provided the following costs are eligible expenditures, the ensuing or ongoing loan will finance: (i) costs incurred under PRF that have not yet been paid from the PRF account by the refinancing date, (ii) costs for activities initiated under PRF and continuing beyond the refinancing date, and (iii) costs incurred during PRF implementation but ineligible under PRF. 34. The Funds Flow Diagram is shown in Diagram 1:

22 Disbursement eLearning. http://wpqr4.adb.org/disbursement_elearning 23 ADB’s Client Portal for Disbursements system facilitates online submission of withdrawal applications to ADB, resulting in faster disbursement. The forms to be completed by the borrower are available at ADB. Guide to the Client Portal for Disbursements.

V. Risk description and rating 35. A Financial Management Internal Control and Risk Management Assessment, based largely on International Standard on Auditing 400 Risk Assessment and Internal Control, was conducted on the existing structure, staffing, resources and procedures of TPL. The results, including recommendations for risk mitigation measures, are summarized in Table 2.

Table 2: Financial Management, Internal Control and Risk Assessment

Risk

Type

Risk Assessment

Risk

Description

Mitigation

Measure

Inherent Risk (the susceptibility of the project financial management system to factors arising from the environment in which it operates, such as country rules and regulations and entity working environment (assuming absence of any counter checks or internal controls)) 1. Country-

specific risks Substantial PEFA identified risks

associated with segregation of duties, FMIS implementation and regular

All payments are initiated and approved by the Line Ministries and payments are centralised at Treasury Division, MOF.

Risk

Type

Risk Assessment

Risk

Description

Mitigation

Measure

reconciliations to facilitate good internal control. OAG has issued disclaimers of opinion for the TWOG statements mainly due to converting cash basis to accrual basis.

Reconciliations are done on a monthly basis by MOF. The latest TWOG audit report is for year ended 31 December 2017, which was submitted to Parliament in 2018 and where OAG noted improvements in the annual reporting process.

2. Entity-specific risks

Moderate MOF is the Borrower/ Recipient for all ADB-funded projects and has only been an EA for 2 ongoing ADB-funded projects, although some of their staff are authorized signatories for all ADB-funded projects. The roles of MOF as a whole, and the CPMU, are to be clearly defined.

A new CPMU will be setup in MOF to implement the project and an organisation structure has been defined and will be implemented, with TORs developed for CPMU staff. A new project accountant will be recruited and ADB will provide training for the project accountant, project manager and new MOF CPD approvers on ADB’s disbursements, financial reporting and auditing requirements.

Overall Inherent

Risk

Substantial

Project Risk (the risk that the project’s accounting and internal control framework are inadequate to ensure project funds are used economically and efficiently and for the purpose intended, and that the use of funds is properly reported). 1. Implementing

Entity Moderate MOF is the Borrower/

Recipient of all ADB-funded projects and has only been an EA for 2 ongoing ADB-funded projects, although some of their staff are authorized signatories for all ADB-funded projects.

ADB will provide training to the new CPMU staff and new MOF CPD approvers, on ADB’s disbursements, financial reporting and auditing requirements.

2. Funds Flow Low Payments to consultants/ contractors will not flow through EA/IA/PMU but will be paid directly by ADB. There may be small recurrent expenditure for the CPMU which will be done on a reimbursement basis.

Reimbursement procedure will require complete documentation.

3. Staffing Moderate A new CPMU will be established in MOF and a qualified and experienced project accountant will be recruited. Some MOF staff will be new CPD Approvers.

MOF to ensure that a qualified and experienced project accountant is recruited. ADB will provide training to the new project accountant and new MOF CPD Approvers on ADB’s disbursements, financial reporting and auditing requirements.


Substantial After preparing the 2017 TWOG financial statements on an accrual basis in

The CPMU will apply accounting policies and procedures consistent with MOF.

Risk

Type

Risk Assessment

Risk

Description

Mitigation

Measure

accordance with Tuvalu GAAP, MOF is preparing the 2018 TWOG financial statements on a modified cash basis in accordance with IPSAS.

5. Internal Audit Moderate A new Division was established in MOF in December 2016 and staff do not have knowledge of ADB’s requirements.

ADB to include IAD staff when training is conducted on ADB’s disbursements, financial reporting and auditing requirements.

6. External Audit

Substantial OAG issued disclaimer of opinions for the 2016 and 2017 TWOG financial statements due to limitation of scope and some of OAG’s recommendations remain outstanding.

OAG audit all ADB projects.

MOF are working towards clearing OAG’s outstanding recommendations. During project review missions, ADB will meet with OAG, to ensure that ADB’s auditing requirements are complied with.


Substantial New project accountant may not be familiar with ADB’s financial reporting requirements.

Training will be provided to CPMU staff and relevant MOF staff on ADB’s disbursements, financial reporting and auditing requirements.

8. Information Systems

Moderate Only MOF uses Sage 300 software and other Ministries use Microsoft excel. MOF are looking into procuring a new software which TWOG, including development partner projects, can also use but this will take time.

The project will purchase the MYOB accounting software to use, as is being successfully used under OIMIP-TUV.

Overall Project

Risk

Substantial

Overall

(Combined) Risk

Substantial

VI. Proposed Time-Bound Action Plan 36. The government of Tuvalu and MOF have agreed to implement an action plan, as key measures to address the deficiencies:

Table 3: Proposed Action Plan

Issue Action Timeline

1. The role of MOF as a whole and the PMU for the ADB-funded project is to be clearly defined.

A CPMU organisation structure has been defined and is to be implemented, with TORs developed for CPMU staff.

By grant

effectiveness

2. New Project Manager and new Project Accountant

ADB to provide training for the new staff on ADB’s disbursements, financial reporting and auditing requirements.

During Inception

Mission

3. ADB’s financial reporting and auditing requirements

CPMU to purchase the MYOB accounting software for the project and ADB to meet with OAG to discuss ADB’s auditing requirements.

During Inception

Mission

Appendix 1 Financial Management Assessment Questionnaire – Ministry of Finance 2 Ministry of Finance Organisation Chart 3 Treasury Division, MOF Organisation Chart 4 Project Accountant Terms of Reference 5 Auditor’s Terms of Reference

Appendix 1

Proposed Project Readiness Facility for

Preparing the Funafuti Water and Sanitation Project Financial Management Assessment Questionnaire24

Ministry of Finance February 2020

Topic Response Potential Risk

Event

1. Implementing Agency 1.1 What is the entity’s legal

status/registration? Government ministry. Moderate.

MOF has only been a Borrower/Recipient and EA, not an IA.

1.2 How much equity (shareholding) is owned by the Government?

Not applicable.

1.3 Obtain the list of beneficial owners of major blocks of shares (non-governmental portion), if any.25

Not applicable.

1.4 Has the entity implemented an externally-financed project in the past? If yes, please provide details.

Yes, Borrower/Recipient for ADB-funded closed L1921/L2055 and ongoing G6003/G0511/G0512/G0513/G603. EA for ongoing G0625-REG and G0674-TUV. EA for WB, EU, GCF and UN Agencies.

Low. EA has sufficient experience with ADB and other donor projects.

1.5 Briefly describe the statutory reporting requirements for the entity.

Financial reporting monthly through TWOG budget versus actual expenditure and remaining expenditure on each vote ledger. TWOG financial statements are audited by the OAG, presented to the Public Accounts Committee and tabled in Parliament.

Low. 2017 Audited TWOG tabled in Parliament in 2018.

1.6 Describe the regulatory or supervisory agency of the entity.

Parliament and the Public Accounts Committee.

1.7 What is the governing body for the project? Is the governing body for the project independent?

EA/IA is MOF and Project Steering Committee comprises CEOs of MOF, MOH, MLGA, MPUIED and other relevant Ministries/Departments.

1.8 Obtain current organizational structure and describe key management personnel. Is the organizational structure and governance appropriate for the needs of the project?

Headed by the Minister, with CEO, Deputy Secretary and Directors of Divisions: (i) treasury; (ii) planning, budget and aid coordination; (iii) inland revenue; (iv) customs; (v) public enterprise monitoring; (vi) business and private sector; (vii) climate change; (viii) internal audit; (ix) central procurement; (x) statistics. Under the proposed project, a new CPMU, including a Project manager and a Project accountant, will be established in MOF.

Moderate. New CPMU will be established and ADB will provide training on ADB’s disbursements, financial reporting and auditing requirements.

1.9 Does the entity have a Code of Ethics in place?

Yes, as a government ministry MOF is subject to Administrative Orders and

24 This questionnaire should be administered by ADB staff or consultant (the Reviewer), and utilized only to obtain information, and to identify and describe potential risk events. Rating of risks should be carried out separately by assessing their likelihood and impact. 25 In such cases, consult OAI on the need for integrity due diligence on non-governmental beneficial owners.

Topic Response Potential Risk Event

violations reported to the Public Services Committee

1.10 Describe (if any) any historical issues reports of ethics violations involving the entity and management. How were they addressed?

None.

2. Funds Flow Arrangements

2.1 Describe the (proposed) project funds flow arrangements in detail, including a funds flow diagram and explanation of the flow of funds from ADB, government and other financiers, to the government, EA, IA, suppliers, contractors, ultimate beneficiaries, etc. as applicable.

Consultants will be paid via direct payment disbursement procedure by ADB. Small recurrent PMU expenses will be paid on a reimbursement basis. Project accountant based in the CPMU will create WAs on CPD, submit them to MOF to review/approve and then to ADB to process payment.

Low.

2.2 Are the (proposed) arrangements to transfer the proceeds of the grant (from the government / Finance Ministry) to the entity and to the end-recipients satisfactory?

Yes.

2.3 Are the disbursement methods appropriate?

Yes, consulting services payments will be via direct payment disbursement procedure. Small recurrent PMU expenses will be paid on a reimbursement basis.

Low.

2.4 What have been the major problems in the past involving the receipt, accounting and/or administration of funds by the entity?

The closed ADB-funded TMTI-TUV project of 2002 was deemed “partly successful” due to protracted delays and poor quality of work. Under the ongoing ADB-funded OIMIP-TUV project, disbursements, financial reporting and auditing requirements are satisfactory and ADB has approved a US$100,000 advance account for project use.

Moderate.

2.5 In which bank will the Advance Account (if applicable) be established?

Not applicable.

2.6 Is the bank in which the Advance account is established capable of − Executing foreign and local currency

transactions? Issuing and administering letters of

credit (LC)? Handling a large volume of

transaction? Issuing detailed monthly bank

statements promptly?

Not applicable.

2.7 Is the ceiling for disbursements from the Advance account and SOE appropriate/required?

Not applicable.

2.8 Does the (proposed) project implementing unit (PIU) have experience in the management of disbursements from ADB?

CPMU staff are yet to be recruited and Moderate. ADB will provide training for the new Project manager and the new Project accountant on ADB’s disbursements, financial reporting and auditing requirements.


2.9 Does the PIU have adequate administrative and accounting capacity to manage the Advance fund and statement of expenditure (SOE) procedures in accordance with ADB’s Loan Disbursement Handbook (LDH)? Identify any concern or uncertainty about the PIU’s administrative and accounting capability which would support the establishment of a ceiling on the use of the SOE procedure.

CPMU staff are yet to be recruited but no Advance account will be used.

Moderate. ADB will provide training for the new Project manager and the new Project accountant on ADB’s disbursements, financial reporting and auditing requirements.

2.10 Is the entity exposed to foreign exchange risk? If yes, describe the entity’s policy and arrangements for managing foreign exchange risk.

No.

2.11 How are the counterpart funds accessed?

Through government budget. Low. Counterpart funding is for taxes and duties.

2.12 How are payments made from the counterpart funds?

Counterpart funding (taxes and duties) will be included in the government budget. Once budget allocation available, MOF issues a warrant against which payments can be made.

Low.

2.13 If project funds will flow to communities or NGOs, does the PIU have the necessary reporting and monitoring arrangements and features built into its systems to track the use of project proceeds by such entities?

NGOs will be recruited to implement public awareness and community outreach campaigns and will be paid via direct payment disbursement procedure. The reporting and monitoring arrangements will be setup once the CPMU staff and consulting services firms have been recruited.

Low.

2.14 Are the beneficiaries required to contribute to project costs? If beneficiaries have an option to contribute in kind (in the form of labor or material), are proper guidelines and arrangements formulated to record and value the labor or material contributions at appraisal and during implementation?

No.

3. Staffing 3.1 What is the current and/or proposed

organizational structure of the accounting department? Attach an organization chart.

MOF’s Treasury Division is headed by the Government Accountant and is in charge of 3 Teams: (i) office and administration; (ii) payroll and imprest; (iii) financial reporting. Organisation Charts for MOF and Treasury Division are attached. A new CPMU will be setup and will include a project accountant who will prepare all withdrawal applications for payment and the annual project financial statements for audit.

Medium. A new project accountant will be recruited and ADB will provide training on ADB’s disbursements, financial reporting and auditing requirements.

3.2 Will existing staff be assigned to the project, or will new staff be recruited?

New staff will be recruited. Moderate. ADB will provide training for the new Project manager and new Project accountant on ADB’s disbursements,

3.3 Describe the existing or proposed project accounting staff, including job title, responsibilities, educational background and professional experience. Attach job descriptions and CVs of key existing accounting staff.

MOF will recruit a new qualified and experienced project accountant who will be based in the CPMU.


3.4 Is the project finance and accounting function staffed adequately?

financial reporting and auditing requirements.

3.5 Are the project finance and accounting staff adequately qualified and experienced?

3.6 Are the project finance and accounting staff trained in ADB procedures, including the disbursement guidelines (i.e., LDH)?

The Project accountant is yet to be recruited but ADB will provide training for the new Project accountant on ADB’s disbursements, financial reporting and auditing requirements.

Medium. A new project accountant will be recruited and ADB will provide training on ADB’s disbursements, financial reporting and auditing requirements.

3.7 What is the duration of the contract with the project finance and accounting staff?

Contracted for one year and renewable, based on performance.

3.8 Identify any key positions of project finance and accounting staff not contracted or filled yet, and the estimated date of appointment.

Project accountant. Medium. A new qualified and experienced project accountant will be recruited and ADB will provide training on ADB’s disbursements, financial reporting and auditing requirements.

3.9 For new staff, describe the proposed project finance and accounting staff, including job title, responsibilities, educational background and professional experience. Attach job descriptions.

Project Accountant is to have a degree in accounting and preferably have ADB or other development partner funded project experience.

3.10 Does the project have written position descriptions that clearly define duties, responsibilities, lines of supervision, and limits of authority for all of the officers, managers, and staff?

Yes.

3.11 What is the turnover rate for finance and accounting personnel (including terminations, resignations, transfers, etc.)?

The longest serving staff in the Treasury Division, MOF has worked there for over 20 years. Some staff are currently on training and MOF has recruited relieving staff to replace them.

Low.

3.12 What is training policy for the finance and accounting staff?

Policy for government in general is to provide a Scholarship program on long term training / Public and Private. For Treasury staff without accounting qualification, MOF are sending them to the USP Campus in TUV, to attain a certificate in accounting.

3.13 Describe the list of training programs attended by finance and accounting staff in the last 3 years.

ACCPAC training USP’s Certificate in Accounting.


4.1 Does the entity have an accounting system that allows for the proper recording of project financial transactions, including the allocation of expenditures in accordance with the respective components, disbursement categories, and sources of funds (in particular, the legal agreements with ADB)? Will the project use the entity accounting system? If not, what accounting system will be used for the project?

Although MOF uses Sage 300 accounting system, expenditure and revenue are inputted manually into Sage 300 from the votes ledgers and from revenue generating activities. As with the ongoing ADB-funded OIMIP, the CPMU will use the MYOB accounting software for its project accounting work.

Medium. Use of manual entry twice, once into Excel at line ministry level and a second time by MOF into Sage 300. MYOB accounting software may be new to the new project


accountant, so training will be provided.

4.2 Are controls in place concerning the preparation and approval of transactions, ensuring that all transactions are correctly made and adequately explained?

All payments requests are initiated and approved by the requesting Line Ministries and payments are centralised at Treasury Division, MOF, where the Govt Accountant authorizes all transactions. The authorization includes the amount and calculations and review of supporting documents. For amounts greater than $500 the modality for purchase is under the Procurement Unit for the government reporting to MOF.

Low. Treasury Division staff always require authorization before they release warrants.

4.3 Is the chart of accounts adequate to properly account for and report on project activities and disbursement categories? Obtain a copy of the chart of accounts.

Yes, the classifications provide a comprehensive coverage of MOF activity.

Low.

4.4 Are cost allocations to the various funding sources made accurately and in accordance with established agreements?

Yes

4.5 Are the General Ledger and subsidiary ledgers reconciled monthly? Are actions taken to resolve reconciliation differences?

Yes, reconciliations are completed on a monthly basis and immediate action is taken to resolve differences.

Low.

4.6 Describe the IA’s policy for retention of accounting records including supporting documents (e.g. ADB’s policy requires that all documents should be retained for at least 1 year after ADB receives the audited project financial statements for the final accounting period of implementation, or 2 years after the loan closing date, whichever is later). Are all accounting and supporting documents retained in a defined system that allows authorized users easy access?

Accounting records are kept for 5 years. While the project is ongoing, records will be kept with the CPMU and after closing, will be kept by MOF for 5 years.

Low. Record keeping exceeds ADB requirements.

4.7 Describe any previous audit findings that have not been addressed.

For the TWOG of 2017, OAG raised the following issues: (i) uncertainty surrounding valuation, completeness and existence of property plant and equipment in the financial statements; (ii) lack of evidence to support prior year comparatives; (iii) cash unable to be reconciled to bank statements, and movement in cash balances unable to be reconciled to the statement of assets and liabilities; (iv) inability to obtain satisfactory explanations and documentation regarding a sample of entries for expenses in the financial statements; (v) non-consolidation of 3 public enterprises26; (vi) lack of evidence to support completeness of account

Substantial. MOF are committed towards resolving the issues raised by OAG.

26 National Fishing Corporation of Tuvalu (NAFICOT), Tuvalu Post Limited (TPL) and Tuvalu Maritime Training Institute (TMTI)


receivable and revenues financial statements; (vii) the non-inclusion of inventory in the financial statements; and (viii) limitation of scope surrounding cabinet minutes and decisions.

Segregation of Duties 4.8 Are the following functional

responsibilities performed by different units or persons: (i) authorization to execute a transaction; (ii) recording of the transaction; (iii) custody of assets involved in the transaction; (iv) reconciliation of bank accounts and subsidiary ledgers?

(i) Govt Acct or alternate are the only ones authorized to execute transactions

(ii) HEO records transactions on the computerized system

(iii) Technical Managers have custody of assets and vote keepers record their possession; and

(iv) reconciliations done by HEO/EO

Low. Although the accounting section in each Line Ministry is too small for proper segregation of duties, no cash transactions or payments are being made, as it is centralized in the Treasury Division, MOF.

4.9 Are the functions of ordering, receiving, accounting for, and paying for goods and services appropriately segregated?

There is a threshold of $500 for spending limits in MOF and anything above this threshold needs to go through the Procurement Unit, MOF. Once approved, Treasury, MOF prepares purchase orders and arranges payment, after.

Low

Budgeting System 4.10 Do budgets include physical and

financial targets? Yes, Budget presentation is detailed and comprehensive.

Low.

4.11 Are budgets prepared for all significant activities in sufficient detail to allow meaningful monitoring of subsequent performance?

Yes Low.

4.12 Are actual expenditures compared to the budget with reasonable frequency? Are explanations required for significant variations against the budget?

Yes, every month financial reports are produced on revenue and spending budgets vs actual. Quarterly reports are submitted to Cabinet.

Low.

4.13 Are approvals for variations from the budget required (i) in advance, or (ii) after the fact?

In advance. Medium. However, there are some virements and supplementary requests.

4.14 Is there a ceiling, up to which variations from the budget may be incurred without obtaining prior approval?

No Ceiling. Virement system approved in advance of payment.

Low.

4.15 Who is responsible for preparation, approval and oversight/monitoring of budgets?

MOF.

4.16 Describe the budget process. Are procedures in place to plan project activities, collect information from the units in charge of the different components, and prepare the budgets?

July: Macroeconomic Policy Committee decides on the parameters of ceilings and CEO MOF distributes Circular to all Ministries to submit their budget requests. July-Aug: Budget rounds and MOF consults with Line Ministries. Aug-Sep: Development Coordination Committee meets on the Budget submission. Sep: Consolidated Budget submitted to Cabinet.

Low Risk. Budget cycle is known and used by GOT.


Oct: Budget presented to Parliament.

4.17 Are the project plans and budgets of project activities realistic, based on valid assumptions, and developed by knowledgeable individuals?

Is there evidence of significant mid-year revisions, inadequate fund releases against allocations, or inability of the EA to absorb/spend released funds?

Is there evidence that government counterpart funding is not made available adequately or on a timely basis in prior projects?

What is the extent of over- or under-budgeting of major heads over the last 3 years? Is there a consistent trend either way?

Minister of Finance approval required for $750,000 above budget for TWOG

Payments 4.18 Do invoice-processing procedures

require: (i) Copies of purchase orders and receiving reports to be obtained directly from issuing departments? (ii) Comparison of invoice quantities, prices and terms, with those indicated on the purchase order and with records of goods actually received? (iii) Comparison of invoice quantities with those indicated on the receiving reports? (iv) Checking the accuracy of calculations? (v) Checking authenticity of invoices and supporting documents?

Yes.

4.19 Are all invoices stamped PAID, dated, reviewed and approved, recorded/entered into the system correctly, and clearly marked for account code assignment?

Yes.

4.20 Do controls exist for the preparation of the payroll? Are changes (additions/deductions/modifications) to the payroll properly authorized?

Treasury Division, MOF prepares the payroll, which the Payroll Committee checks before submitting to National Bank of Tuvalu for payment.

Policies And Procedures 4.21 What is the basis of accounting (e.g.,

cash, accrual) followed (i) by the entity? (ii) By the project?

(i) Accrual for 2017 TWOG FS and modified cash for 2018 TWOG FS. (ii) Will follow MOF.

Substantial. A change in the basis and standards of accounting to be followed.

4.22 What accounting standards are followed (International Financial Reporting Standards, International Public Sector Accounting Standards – cash or accrual, or National Accounting Standards (specify) or other?

For 2017 TWOG FS - generally accepted accounting practice in Tuvalu, which looks to IPSAS and IFRS to guide general accounting policy. For 2018 TWOG FS – IPSAS modified cash.

4.23 Does the project have adequate policies and procedures manual(s) to guide activities and ensure staff accountability?

Yes, will follow the Financial Instructions issued (and revised) under the Public Finance Act 2008.

4.24 Is the accounting policy and procedure manual updated regularly and for the project activities?

Yes, Financial Instructions.


4.25 Do procedures exist to ensure that only authorized persons can alter or establish a new accounting policy or procedure to be used by the entity?

Only Chief Executive Officer, MOF can issue circulars

4.26 Are there written policies and procedures covering all routine financial management and related administrative activities?

Yes.

4.27 Do policies and procedures clearly define conflict of interest and related party transactions (real and apparent) and provide safeguards to protect the organization from them?

Yes.

4.28 Are manuals distributed to appropriate personnel?

Yes.

4.29 Describe how compliance with policies and procedures are verified and monitored.

Director of each Division, Internal Audit Division, MOF and OAG.

Cash and Bank 4.30 Indicate names and positions of

authorized signatories for bank accounts. Include those persons who have custody over bank passwords, USB keys, or equivalent for online transactions.

Chief Executive Officer, Deputy Secretary, Government Accountant and Senior Accountant, MOF.

4.31 Does the organization maintain an adequate and up-to-date cashbook recording receipts and payments?

Sage 300 accounting system.

4.32 Describe the collection process and cash handling procedures. Do controls exist for the collection, timely deposit and recording of receipts at each collection location?

Yes.

4.33 Are bank accounts reconciled on a monthly basis? Or more often?

Is cash on hand physically verified, and reconciled with the cash books? With what frequency is this done?

Yes, on a monthly basis. Yes, on a daily basis.

4.34 Are all reconciling items approved and recorded?

Yes.

4.35 Are all unusual items on the bank reconciliation reviewed and approved by a responsible official?

Yes.

4.36 Are there any persistent/non-moving reconciling items?

No.

4.37 Are there appropriate controls in safekeeping of unused cheques, USB keys and passwords, official receipts and invoices?

Yes.

4.38 Are any large cash balances maintained at the head office or field offices? If so, for what purpose?

No.

4.39 For online transactions, how many persons possess USB keys (or equivalent), and passwords? Describe the security rules on password and access controls.

Not applicable.

Safeguard over Assets


4.40 What policies and procedures are in place to adequately safeguard or protect assets from fraud, waste and abuse?

All assets tagged and recorded in fixed assets register (FAR). Annual verification is carried out.

Medium. The FAR is maintained on MS Excel which is time consuming to maintain and error prone. OAG raised the issue of the uncertainty valuation, completeness and existence of property plant and equipment in the financial statements

4.41 Does the entity maintain a Fixed Assets Register? Is the register updated monthly? Does the register record ownership of assets, any assets under lien or encumbered, or have been pledged?

Yes.

4.42 Are subsidiary records of fixed assets, inventories and stocks kept up to date and reconciled with control accounts?

Yes

4.43 Are there periodic physical inventories of fixed assets, inventories and stocks? Are fixed assets, inventories and stocks appropriately labeled?

Yes

4.44 Are the physical inventory of fixed assets and stocks reconciled with the respective fixed assets and stock registers, and discrepancies analyzed and resolved?

Yes

4.45 Describe the policies and procedures in disposal of assets. Is the disposal of each asset appropriately approved and recorded? Are steps immediately taken to locate lost, or repair broken assets?

Yes

4.46 Are assets sufficiently covered by insurance policies?

No. GOT does not insure assets.

4.47 Describe the policies and procedures in identifying and maintaining fully depreciated assets from active assets.

In Financial Instructions and the Public Tenders Board Regulations

Medium. The FAR is maintained off-system on MS Excel which is time consuming to maintain and error prone. OAG raised the issue of the valuation, completeness and existence of property plant and equipment in the financial statements

Other Offices and Implementing Entities

4.48 Describe any other regional offices or executing entities participating in implementation.

Not applicable

4.49 Describe the staff, their roles and responsibilities in performing accounting and financial management functions of such offices as they relate to the project.

4.50 Has the project established segregation of duties, controls and procedures for flow of funds and financial information, accountability, and reporting and audits in relation to the other offices or entities?

4.51 Does information among the different offices/ implementing agencies flow in an accurate and timely fashion? In particular, do the offices other than the head office use the same accounting and reporting system?


4.52 Are periodic reconciliations performed among the different offices/implementing agencies? Describe the project reporting and auditing arrangements between these offices and the main executing/implementing agencies.

4.53 If any sub-accounts (under the Advance Account) will be maintained, describe the results of the assessment of the financial management capacity of the administrator of such sub-accounts.

Contract Management and Accounting

4.54 Does the agency maintain contract-wise accounting records to indicate gross value of contract, and any amendments, variations and escalations, payments made, and undisbursed balances? Are the records consistent with physical outputs/deliverables of the contract?

For the project, it will be held in the CPMU.

4.55 If contract records are maintained, does the agency reconcile them regularly with the contractor?

Yes, this will be done by the CPMU.

Other 4.56 Describe project arrangements for

reporting fraud, corruption, waste and misuse of project resources. Has the project advised employees, beneficiaries and other recipients to whom to report if they suspect fraud, waste or misuse of project resources or property?

Reporting fraud and corruption is historically done through the Attorney General and Police. An Office of the Ombudsman was established in 2014.

5. Internal Audit 5.1 Is there an internal audit division in the

entity? Yes, an IAD was established in MOF in December 2016.

Low. IAD was established based on recommendations from the PEFA and OAG.

5.2 What are the qualifications and experience of the IA staff?

The Director has a bachelor’s degree in commerce (accounting and economics) from USP and worked as an accountant with the National Bank of Tuvalu for 3 years. His staff is a new graduate who has a bachelor’s degree in finance from India. Both have no previous experience in internal auditing but DFAT funded a technical adviser who helped with a first internal audit exercise. DFAT also funded a 2 week secondment to the IAD, Ministry of Economy in Fiji in Feb-Mar 2020.

Medium. IAD staff will be invited to ADB’s in-country training on ADB’s disbursements, financial reporting and auditing requirements.

5.3 To whom does the head of the internal audit report?

Internal Audit Committee.

5.4 Will the internal audit department include the project in its annual work program?

The scope of the internal audit program includes TWOG, public enterprises and development partner projects.

5.5 Are actions taken on the internal audit findings?

The first audit was carried out in 2019 and a follow-up is yet to take place.

5.6 What is the scope of the internal audit program? How was it developed?

The scope of the internal audit program includes TWOG, public enterprises and development partner projects.


5.7 Is the IA department independent? Yes.

5.8 Do they perform pre-audit of transactions?

Yes, they will.

5.9 Who approves the internal audit program?

Internal Audit Committee.

5.10 What standards guide the internal audit program?

International Internal Auditing Standards.

5.11 How are audit deficiencies tracked? Division will include this in the program.

5.12 How long have the internal audit staff members been with the organization?

3 years and 1 year.

5.13 Does any of the internal audit staff have an IT background?

No.

5.14 How frequently does the internal auditor meet with the audit committee without the presence of management?

According to the Charter, they are to meet quarterly and can invite management to these meetings.

5.15 Has the internal auditor identified / reported any issue with reference to availability and completeness of records?

Not yet.

5.16 Does the internal auditor have sufficient knowledge and understanding of ADB’s guidelines and procedures, including the disbursement guidelines and procedures (i.e., LDH)?

No. Medium. IAD staff will be invited to ADB’s in-country training on ADB’s disbursements, financial reporting and auditing requirements.

6. External Audit – entity level 6.1 Is the entity financial statement audited

regularly by an independent auditor? Who is the auditor?

Yes. OAG.

Low. OAG has audited all ADB-funded projects

6.2 Are there any delays in audit of the entity? When are the audit reports issued?

No. For the 2018 TWOG, the draft financial statements are due to OAG by June, audit is to be completed by September and are tabled in the next Parliament sitting in October.

6.3 Is the audit of the entity conducted in accordance with the International Standards on Auditing, or the International Standards for Supreme Audit Institutions, or national auditing standards?

ISSAI.

6.4 Were there any major accountability issues noted in the audit report for the past three years?

Yes.

6.5 Does the external auditor meet with the audit committee without the presence of management?

No.

6.6 Has the entity engaged the external audit firm for any non-audit engagements (e.g., consulting)? If yes, what is the total value of non-audit engagements, relative to the value of audit services?

OAG only out-sources the financial audits of SOEs.

6.7 Has the external auditor expressed any issues on the availability of complete records and supporting documents?

Yes, (i) valuation, completeness and existence of property plant and equipment in the financial statements; (ii) lack of evidence to support prior year comparatives; (iii) cash unable to be reconciled to bank statements, and

Medium.


movement in cash balances unable to be reconciled to the statement of assets and liabilities; (iv) inability to obtain satisfactory explanations and documentation regarding a sample of entries for expenses in the financial statements; (v) lack of evidence to support completeness of account receivable and revenues financial statements.

6.8 Does the external auditor have sufficient knowledge and understanding of ADB’s guidelines and procedures, including the disbursement guidelines and procedures (i.e., LDH)?

Yes, AG and staff have attended ADB’s training on disbursements, financial reporting and auditing requirements in 2016 and 2019

Low

6.9 Are there any material issues noted during the review of the audited entity financial statements that were not reported in the external audit report?

Outstanding receipts not accounted for by the Line Ministries but AG advised that this was not a pervasive finding

Low

External Audit – project level Low

6.10 Will the entity auditor audit the project accounts or will another auditor be appointed to audit the project financial statements?

Entity auditor. Low

6.11 Are there any recommendations made by the auditors in prior project audit reports or management letters that have not yet been implemented?

Not applicable. Low

6.12 Is the project subject to any kind of audit from an independent governmental entity (e.g. the supreme audit institution) in addition to the external audit?

OAG. Low

6.13 Has the project prepared acceptable terms of reference for an annual project audit? Have these been agreed and discussed with the EA and the auditor?

Yes, follows the ADB TOR template. Low

6.14 Has the project auditor identified any issues with the availability and completeness of records and supporting documents?

Not yet applicable.

6.15 Does the external auditor have sufficient knowledge and understanding of ADB’s guidelines and procedures, including the disbursement guidelines and procedures (i.e., LDH)?

Yes, AG and staff have attended ADB’s training on disbursements, financial reporting and auditing requirements in 2016 and 2019.

Low

6.16 Are there any recommendations made by the auditors in prior audit reports or management letters that have not yet been implemented?

Not applicable.

[For second or subsequent projects] 6.17 Were past audit reports complete, and

did they fully address the obligations under the loan agreements? Were there any material issues noted during the review of the audited project financial statements and related audit report that have remained unaddressed?

Not applicable.


7.1 Are financial statements and reports prepared for the entity?

Yes.


7.2 Are financial statements and reports prepared for the implementing unit?

Yes, will be.

7.3 What is the frequency of preparation of financial statements and reports? Are the reports prepared in a timely fashion so as to be useful to management for decision making?

Monthly, half yearly and annually. Yes.

7.4 Does the entity reporting system need to be adapted for project reporting?

Currently, only MOF can use the Sage 300 accounting software. MOF are looking into procuring a new system which TWOG can use, including having a module specifically for project accounting.

Moderate. The CPMU will use a separate accounting system, MYOB, which the ongoing ADB-funded OIMIP-TUV is also using.

7.5 Has the project established financial management reporting responsibilities that specify the types of reports to be prepared, the report content, and purpose of the reports?

This will be done by the Project accountant, when the person has been recruited.

7.6 Are financial management reports used by management?

They will be.

7.7 Do the financial reports compare actual expenditures with budgeted and programmed allocations?

They will.

7.8 How are financial reports prepared? Are financial reports prepared directly by the automated accounting system or are they prepared by spreadsheets or some other means?

Prepared directly using Sage 300. Medium. FAR still prepared on Excel.

7.9 Does the financial system have the capacity to link the financial information with the project's physical progress? If separate systems are used to gather and compile physical data, what controls are in place to reduce the risk that the physical data may not synchronize with the financial data?

At the CPMU, yes. Medium.

7.10 Does the entity have experience in implementing projects of any other donors, co-financiers, or development partners?

Yes, WB, EU, GEF and UN Agencies. Low.

8. Information Systems 8.1 Is the financial accounting and reporting

system computerized? Yes, will be

Moderate. The CPMU will use a separate accounting system, MYOB, which the ongoing ADB-funded OIMIP-TUV is also using.

8.2 If computerized, is the software off-the-shelf, or customized?

Off-the-shelf Sage 300 software

8.3 Is the computerized software standalone, or integrated and used by all departments in the headquarters and field units using modules?

Only MOF uses the Sage 300 software. Other Ministries use Excel worksheets.

8.4 How are the project financial data integrated with the entity financial data? Is it done through a module in the enterprise financial system with automatic data transfer, or does it entail manual entry?

The Project financial data will be held separate from this system and will entail manual entry into GOT’s financial statements.

8.5 Is the computerized software used for directly generating periodic financial statements, or does it require manual

Yes.


intervention and use of Excel or similar spreadsheet software?

8.6 Can the system automatically produce the necessary project financial reports?

Yes.

8.7 Is the staff adequately trained to maintain the computerized system?

Yes and seller’s online support is provided from New Zealand

8.8 Do the management, organization and processes and systems safeguard the confidentiality, integrity and availability of the data?

Yes. Low.

8.9 Are there back-up procedures in place? Yes. Low.

8.10 Describe the backup procedures – online storage, offsite storage, offshore storage, fire, earthquake and calamity protection for backups.

Separate server for Sage 300 and also a dropbox.

Medium Offsite back up through hard drive etc is also needed.

Appendix 2

MINISTRY OF FINANCE ORGANISATION CHART

Minister for Finance - Seve

Paeniu

CEO - Faiva Leee

Government Accountant -

Treasury

Financial Reporting Team

office Administration

teaml

Payrol

Director -Planning, Budget

and Aid

Coordinatio

Aid Management

Planning

Director Inland Revenue

Tax and compliance

Debt management

Director Customs Department

Border control

Director - Public Enterprise

Monitoring Unit

Director - Business and Private Sector

Prince and income board

Business registration

Director - Climate Change

Director - Internal Audit

Direcotr - Central Procurement Unit

Government statiscian

Macro

Deputy Secretary

Assistant Secretary

Appendix 3

TREASURY DEPARTMENT, MOF ORGANISATION CHART

Appendix 4

CONSULTANT'S TERMS OF REFERENCE PROJECT ACCOUNTANT

The Project Accountant (national, 18 person-months, intermittent) will strengthen CPMU’s financial management capacity and assist CPMU to establish and maintain the PRF accounts and to prepare the PRF financial documentation. The financial management specialist will have a degree in accounting, finance, or a related field, and will have a recognized professional accountancy qualification and at least 5 years’ experience in financial management. The financial management specialist will report to the CPMU Manager. Specific tasks and responsibilities of the project accountant specialist will include:

(i) establish CPMU’s financial management and financial record keeping procedures. Prepare guidelines for financial record management and monitor the implementation of the guidelines;

(ii) establish and monitoring financial indicators, as required; (iii) establish and maintain separate project accounts and records for all expenditures

incurred under the PRF; (iv) prepare and submit PRF grant withdrawal applications and associated

documentation to ADB; (v) monitor the PRF grant financial activities project. Review the project accounts

quarterly and identify project financial risks and recommend corrective actions to ensure the project accounts follow international accounting principles and practices; and

(vi) prepare guidelines for quarterly and annual financial reporting. Prepare quarterly, and annual financial reports and accounts, including the PRF accounts, required for internal and external use, including for the CPMU Annual Report.

Appendix 5

March 2015

Statement of Audit Needs

(Auditor’s Terms of Reference)

CONTENTS

Page

I. INTRODUCTION 2

II. MANAGEMENT RESPONSIBILITY FOR PREPARING PROJECT FINANCIAL STATEMENTS 2

III. OBJECTIVES 2

IV. AUDITING STANDARDS 3

V. PROJECT FINANCIAL REPORTING FRAMEWORK 3

VI. AUDIT DELIVERABLES 3

A. Audited Project Financial Statements 3 B. Reasonable Assurance Opinion over the Use of Loan Proceeds and Compliance

with Financial Covenants 4 C. Management Letter 4 D. Specific Considerations 4

VII. OTHER MATTERS 5

A. Statement of Access 5 B. Independence 5 C. Auditor Experience 6

MINISTRY OF FINANCE, GOVERNMENT OF TUVALU AUDITED PROJECT FINANCIAL STATEMENTS (APFS)

STATEMENT OF AUDIT NEEDS (AUDITOR’S TERMS OF REFERENCE27)

I. INTRODUCTION

1. [A description of the project will be provided with a focus on the purpose for which the funds are intended consistent with broad project objectives and budget. A description of the executing and implementing agencies will be included along with the related accounting and financial management practices, loan amount, financial reporting periods to be audited, and other relevant information that should be brought to the attention of the auditors.]

II. MANAGEMENT RESPONSIBILITY FOR PREPARING PROJECT FINANCIAL STATEMENTS

2. Management is responsible for preparing and fairly presenting the project financial statements, and for maintaining sufficient internal controls to ensure that the financial statements are free from material misstatement, whether due to fraud or error. In addition, management is responsible for ensuring that funds were used only for the purpose(s) of the project, for compliance with financial covenants (where applicable), and for ensuring that effective internal controls, including over the procurement process, are maintained. In this regard, management must:

(i) Prepare and sign the Audited Project Financial Statements. (ii) Prepare and sign a Statement of Compliance.

3. Management must include the following in the Statement of Compliance:

(i) That project financial statements are free from material misstatements including omissions and errors, and are fairly presented;

(ii) That the borrower or executing agency has utilized the proceeds of the loan only for the purpose(s) of the project;

(iii) That the borrower or executing agency was in compliance with the financial covenants of the legal agreement(s) (where applicable);

(iv) That effective internal control, including over the procurement process, was maintained.

III. OBJECTIVES

4. The objectives of the audit of the project financial statements is to enable the auditor to (i) express an independent and objective opinion as to whether the project financial statements present fairly, in all material respects, or give a true and fair view of the project’s financial position, its financial performance and cash flows, and (ii) provide a reasonable assurance opinion over certain specific representations made in the Statement of Compliance.

27 This statement of audit needs was developed to guide project teams and executing and implementing agencies in communicating the Asian Development Bank’s (ADB) auditing requirements to private auditors. This statement of audit needs may also be used as a guide when communicating auditing requirements with supreme audit institutions, where applicable.

IV. AUDITING STANDARDS

5. The audit is required to be conducted in accordance with International Standards of Supreme Audit Institutions (ISSAI). These standards require that the auditor comply with ethical requirements and plan and perform the audit to obtain reasonable assurance about whether the project financial statements are free from material misstatement. An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the project financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the project financial statements whether due to fraud or error. In making those risk assessments, the auditor considers the internal control relevant to the entity’s preparation and fair presentation of the project financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of accounting estimates made by management, as well as evaluating the overall presentation of the project financial statements. 6. The standards to be applied will be documented in the project/loan documents and will include Standards promulgated by the International Organisation of Supreme Audit Institutions (INTOSAI): International Standards of Supreme Audit Institutions (ISSAI).

7. In complying with ISA, the auditor will pay particular attention to the following standards:

ISA 800/ISSAI 1800 – Special Considerations – Audits of Financial Statements

Prepared in Accordance with Special Purpose Frameworks.

ISA 265/ISSAI 1265 – Communicating Deficiencies in Internal Control To Those Charged with Governance and Management.

V. PROJECT FINANCIAL REPORTING FRAMEWORK

8. The auditor will verify that the project financial statements have been prepared in accordance with International Public Sector Accounting Standards (IPSAS) promulgated by the International Public Sector Accounting Standards Board (IPSASB), or national equivalents. The executing agency and/or implementing agency are responsible for preparing the project financial statements, not the auditor.

VI. AUDIT DELIVERABLES

A. Audited Project Financial Statements

9. An auditor’s opinion providing reasonable assurance over the project financial statements, and project financial statements comprising the following:

Table 1: Content of the Project Financial Statements For Cash-Based Financial Statements For Accrual-Based Financial Statements

A statement of cash receipts and payments A statement of financial position (balance sheet) A statement of budgeted versus actual expenditures A statement of financial performance (income

statement) A statement of advance account (where applicable) A statement of cash flows A summary statement of expenditures (where applicable)

A statement of changes in net assets/equity (where applicable)

Significant accounting policies and explanatory notes A statement of advance account (where applicable)

For Cash-Based Financial Statements For Accrual-Based Financial Statements Any additional schedules agreed (e.g., a summary of assets)

Significant accounting policies and explanatory notes

Statement of budgeted versus actual expenditures Summary statement of expenditures (where applicable) Any additional schedules agreed

B. Reasonable Assurance Opinion over the Use of Loan Proceeds and Compliance

with Financial Covenants

10. The auditor will provide a reasonable assurance opinion following ISSAI 4200 “Compliance Audit Related to the Audit of Financial Statements” for the following confirmations provided by Management in the Statement of Compliance:

(i) That the proceeds of the loan were used only for the purpose(s) of the project; and (ii) That the borrower or executing agency was in compliance with the financial

covenants of the legal agreement(s), where applicable.

11. The auditor will outline the degree of compliance for each of the financial covenants in the grant agreement.

C. Management Letter

12. The auditor will provide a management letter containing, at a minimum, the following:

(i) Any weaknesses in the accounting and internal control systems that were identified during the audit, including any irregularity in the use of the imprest fund and statement of expenditures (SOE) procedures (where applicable);

(ii) Any identified internal control weaknesses related to the procurement process such as, over the bidding, evaluation and contract management domains;

(iii) Recommendations to rectify identified weaknesses; (iv) Management’s comments on the audit recommendations along with the timeframe

for implementation; (v) The status of significant matters raised in previous management letters; (vi) Any other matters that the auditor considers should be brought to the attention of

the project’s management; and (vii) Details of any ineligible expenditure28 identified during the audit. Expenditure is

considered ineligible if it refers to (i) expenditures incurred for purposes other than the ones intended under the legal agreement(s); (ii) expenditures not allowed under the terms of the legal/financing agreements; and (iii) expenditures incurred in violation of applicable government regulations.

D. Specific Considerations

13. The auditor will, during the course of the audit, pay particular attention to the following: (i) The use of external funds in accordance with the relevant legal and financing

agreements; (ii) The provision of counterpart funds in accordance with the relevant agreements

and their use only for the purposes intended;

28 If the auditor reports any ineligible expenditure in the management letter, the details of the findings should include the funding source to which the observation relates.

(iii) The maintenance of proper books and records; (iv) The existence of project fixed assets and internal controls related thereto; (v) Where the audit report has been issued under ISSAI 1800, it shall include the

mandatory Emphasis of Matter paragraph alerting users of the audit report that the project financial statements are prepared in accordance with a special purpose framework and that, as a result, the project financial statements may not be suitable for another purpose. The auditor shall include this paragraph under an appropriate heading;

(vi) Where reasonable assurance has been provided using ISSAI 4200, the assurance report must contain, among others:

- A statement that the engagement was performed in accordance with ISSAI 4200;

- Subject matter; - Criteria for measurement; - A summary of the work performed; and - The auditor’s conclusion.

(vii) Any weaknesses in internal controls over the procurement process.

14. All reports must be presented in the English language within 6 months following the end of the fiscal year. 15. Public disclosure of the project financial statements, including the auditor’s opinion on the audited project financial statements, will be guided by ADB’s Information Disclosure Policy. After review, ADB will disclose the audited project financial statements and the opinion of the auditor on the audited project financial statements no later than 14 calendar days of ADB’s confirmation of their acceptability by posting them on ADB’s website. The management letter and the additional auditor’s opinions will not be disclosed29.

VII. OTHER MATTERS

A. Statement of Access

16. The auditor will have full and complete access, at all reasonable times, to all records and documents including books of account, legal agreement(s), bank records, invoices and any other information associated with the project and deemed necessary by the auditor. 17. The auditor will be provided with full cooperation by all employees of the Ministry of Finance and the project implementing units, whose activities involve, or may be reflected in, the annual project financial statements. The auditor will be assured rights of access to banks and depositories, consultants, contractors and other persons or firms hired by the employer.

B. Independence

18. The auditor will be impartial and independent from any aspects of management or financial interest in the entity or project under audit. In particular, the auditor should be independent of the control of the entity. The auditor should not, during the period covered by the audit, be employed by, or serve as director for, or have any financial or close business relationship with the entity. The auditor should not have any close personal relationships with any senior participant in the

29 Such information generally falls under access to information policy exceptions to disclosure (ADB. 2018. Access to

Information Policy: Disclosure and Exchange of Information. Manila [para. 17(1-7)].

management of the entity. The auditor must disclose any issues or relationships that might compromise their independence.

C. Auditor Experience

19. The auditor must be authorized to practice in the country and be capable of applying the agreed auditing standards. The auditor should have adequate staff, with appropriate professional qualifications and suitable experience, including experience in auditing the accounts of projects or entities comparable in nature, size and complexity to the project or entity whose audit they are to undertake. To this end, the auditor is required to provide curriculum vitae (CV) of the personnel who will provide the opinions and reports, together with the CVs of managers, supervisors and key personnel likely to be involved in the audit work. These CVs should include details of audits carried out by these staff, including ongoing assignments.

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