world bank document · 2017-03-15 · world bank grant agreement number- tf 18449-001 bz project...

Audit of International Bank grant recipient Belize Marine Conservation and Climate Adaptation Project (MCCAP)

INTERNATIONAL BANK FOR RECONSTRUCTION ANDDEVELOPMENT

AUDIT REPORT

AUDIT OF THE INTERNATIONAL BANK GRANT RECIPIENT

Marine Conservation and Climate Adaptation Project (MCCAP)

FUNDED BY THE GLOBAL ENVIRONMENT FACILITY TOSTRENGTHEN THE CLIMATE RESILIENCE OF THE BELIZE BARRIER

REEF SYSTEM AND ITS PRODUCTIVE MARINE RESOURCES

World Bank Grant Agreement number- TF 18449-001 BZ

Project number: P131408 BZ Marine Conservation and Climate Adaptation

Country. Belize

Auditor: Moore Stephens Magafla LLP

Period subject to audit. 3 June, 2015 to 31 MarKh, 2016

This report is established by request of theInternational Bank. The views expressed in thisreport are those of the external auditor and in noway reflect the official opinion of the InternationalBank. This report has been prepared solely foruse of the International Bank for the purpose ofthe control of the use of funds of the projectconcerned by the audit. It may be disclosed to -

those official authorities having regulatory right ofaccess to it. This report should not be used by anyother party or for other than its intended purpose.

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Table of Contents

EXECUTIVE SUMMARY ......... . ....... ,..,...., .................................................... ........... 3THE AUDIT EN. . .... . .. .......... .. ......... ... . - .... .. .. 4

AUDIT OPINIONS ....8

STATEMENT OF CUMULATIVE kNESTMENTS ....................................... 8STATEMENT OF DESIGNATED ACCOUNT........... .................-. --...... 10STATEMENT OF COMPLIANCE .................................................. 12

MANAGEMENT LETTER ................... 13

REVIEW OF GRANT RECIPIENT'S EFFECTIVENESS IN THE MANAGEMENT OF FUNOS............. ..... 13ASSESSMENT OF THE GRANT RECIPIENT'S INTERNAL CONTROL SYSTEM...............--- ................ 13ORGANZATION AND STAFFING ---........................................................ .13REVIEW ON THE MANAGEMENT OF FUNDS .. .......... . .......................................... 14PROCUREMENT..................... ..................... ........... 15CONTROL MECHANISM Or EXPENDrTURE.................................................................. 15DESGNATED ACCOuNT..-------..................................... ..................... 16AccoubTING SYSTEM ..................................... ............. ... 17FLLOw up oN PREvious AuDiTS.-....................................................---- 17GENERAL INFORMATION- -- - - - . . .-......................................................... ...... 1

ANNEXES .....- -.....- .. ....................... -. -. - -..... - . . - .. . .....- 19

ANNEX 1: SUMMARY OF WORLD BANK FUNDS -- - - - -. ............................. ...... 19ANNEX 2 STATEMENT OF CUMULATIVE INVESTMENTS...............-...................... 20ANNEx 3; DESIGNATED AccouNT RECONCIUATION STATEMENT ........................ 20ANNEX4: STATEMENT OF SOURCES AND USES OF FUNDS.. ........................................... 21ANNEX S BALANCE SHEET FOR YEAR ENDEo 31 MARCH. 2016 - ..... ....................... 22ANNEX 6: FIXED ASSETs SCHEDVUI.E FOR YEAR ENDED 31& MARCH, 2016 ......................... 23ANNEX 7: AUDIT AREA RAT INGS .................................................. 24ANNEX 8: AuDIT F INDING PRIORITY RATNGS.......... ....... .......................... 24

EXECUTIVE SUMMARY

Moore Stephens MagarAa LLP entered into an Engagement Agreement with the Protected AreasConservation Trust ("The national implementing entity") on 19 May 2016 to carry out an audit ofInternational Bank Grant recipient which is funded by the Global Environment Facility to strengthen theclimate resilience of the Belize Barrier Reef System and its productive marine resources. The Grantrecipient (Belize Marine Conservation and Climate Adaptation Project) MCCAP was selected for audit aspart of World Bank's 2016 audit plan. The period subject to audit was 3 June 2015 to 31 March 2016.

We have issued audit opinions as summarised in the table below and as detailed in the Audit Opinionssection:

Statement of expenses Unqualified

Statement of designated account Unqualified

Statement of compliance Unqualified

The audit findings are summarised in the table below:

h Medium 'Low

Management,and use of-funds Satisfactory - - -

Procurement of;goods and Satisfactorservices .

Control mechanisms for expenditure Satisfactory -- - -

Designated account management Satisfactory - -

Acc6untihlysteiths Partiallysatisfactory

Follow-up.on previous:audits N -i- -'Not appl icable d

General information. PartlillySatisfactory

TOTAL.- 1 1 -

THE AUDIT ENGAGEMENT

Audit Objective

The main purpose of the audit was to enable the auditors to express an opinion on the grant recipient's(Belize Marine Conservation and Climate Adaptation Project) financial statements as of 3 June 2015 to31 March 2016.

The project's accounting system (books and records) provides the basis for the preparation of the PFS.was established to record the financial transactions of the project, and is maintained by the Project'snational implementing entity, Protected Areas Conservation Trust (PACT).

Scope of the Audit

The audit was conducted in accordance with International Standards on Auditing (ISA) as published bythe International Auditing and Assurance Standards Board of the International Federation of Accountants(IFAC), with special reference to ISA 800 (Auditors Report on Special Purpose Audit Engagements) andto relevant World Bank guidelines. In conducting the project audit, special attention was paid to thefollowing:

* Whether external funds have been used in accordance with the conditions of the relevant generalconditions, relevant financing agreements and disbursement letter, with due attention to economyand efficiency, and only for the purposes for which the financing was provided.

* Whether counterpart funds have been provided and used in accordance with the relevant generalconditions, relevant financing agreements and disbursement letter, and only for the purposes forwhich they were provided.

* Whether the goods and services financed have been procured in accordance with the relevantgeneral conditions, relevant financing agreements and disbursement letter.

* Whether necessary supporting documents, records, and accounts have been kept in respect ofall Project ventures including expenditures reported via Summary Report or Statements ofExpenditures (SOEs) or Designated Accounts (DAs). Clear linkages should exist between theaccounting records and the financial reports presented to the Bank.

* Whether designated Accounts have been maintained in accordance with the provisions of therelevant general conditions, relevant financing agreements and disbursement letter.

* Whether the Project's Financial Statements (PFS) have been prepared in accordance withInternational Financial Reporting Standards and practices and relevant World Bank guidelines.and give a true and fair view of the financial position of the projects as of 31 March, 2016 and ofthe resources and expenditures for the period 3 June, 2015 then ended 31 March 2016.

* Whether there is compliance on each of the financial covenants in the Financial Managementsection of the Grant Agreement in Section II.B.4 of Schedule 2.

Our assessment of the internal control system covered the following areas as applicable:

Summary Reports or Statement of Expenditures

As part of the audit of the Project's Financial Statements (PFS), the auditor is required to audit allSummary Reports or SOEs used as the basis for the submission of withdrawal applications. TheseSummary Reports should be compared for project eligibility with the relevant general conditions, relevantfinancing agreements, and disbursement letter, and with reference to the Project Appraisal Document forguidance when considered necessary. Where ineligible expenditures are identified as having beenincluded in withdrawal applications and reimbursed against, these should be separately noted in separatenote disclosures and also in the management letter, by the auditor. The Project Financial Statements (orincluded within the notes to the project financial statements) should be a schedule listing individualSummary Reports or SOEs (used as the basis of disbursement) withdrawal applications by specificreference number and amount.

The auditor should pay partIcular attention as to whether:

* The Summary Reports or SOEs have been prepared in accordance with the provisions of therelevant financing agreement.

* Expenditures have been made wholly and necessarily for the realisation of project objectives.

* Information and explanation necessary for the purpose of the audit have been obtained;

* Supporting records and documents necessary for the purpose of the audit have been retained, and

* The Summary Reports or SOEs can be relied upon to support the related withdrawal applications.

Designated Accounts

In conjunction with the audit of the Project Financial Statements, the auditor is also required to audit theactivities of the Designated Accounts associated with the Project. The Designated Accounts usuallycomprises:

Deposits and replenishments received from the Bank;Payments substantiated by withdrawal applications;Interest that may be earned from the balances and which belong to the Recipient; andThe remaining balances at the end of each fiscal year.

The auditor should pay particular attention as to the compliance with the Bank's procedures and thebalances of the Designated Accounts at the end of the fiscal year (or period). The auditor should examinethe eligibility of financial transactions during the period under examination and fund balances at the endof such a period, the operation and use of the DAs in accordance with the relevant general conditions,relevant financing agreements and disbursement letter, and the adequacy of internal controls for this typeof disbursement mechanism.

For this Project, the Designated Accounts are referred to in the Disbursement Letter attached to theGrant Agreement, and Disbursement Guidelines.

Audit Reports

The auditors will issue an audit opinion on the BELIZE MARINE CONSERVATION AND CLIMATEADAPTATION PROJECT (refer to the "Project Financial Statements' paragraph above for a definition ofthe statements included therein).

In addition to the audit opinion, the auditor will prepare a "management letter," in which the auditor will:

* Give comments and observations on the accounting records, systems, and controls that wereexamined during the course of the audit;

* Identify specific deficiencies and areas of weakness in systems and controls and makerecommendation for their improvement. These should be reported in accordance with thefollowing elements: condition, criteria, cause and effect. It is important that the findings alsoinclude a recommendation to help correct the cause;

* Report on the lack of compliance of each financial covenant in the relevant financing agreement* Communicate matters that have come to their attention during the audit which might have a

significant impact on the implementation of the project;* Bring to the Recipient's attention any other matters that the auditor considers pertinent and

include management's comments in the final management letter.

The financial statements, including the audit opinion, and management letter should be received by theProject's national implementing entity, PACT, no later than 15"' July after the end of the audited fiscalyear. The Project's national implementing entity should then promptly forward two copies of the auditedproject financial statements (including audit opinion) and management letter to the Bank.

General

The responsibility for the preparation of financial statements including adequate disclosure is that of themanagement of the National Implementing Entity (PACT). This includes the maintenance of adequateaccounting records and internal controls, the selection and application of accounting policies, and thesafeguarding of the assets of the entity. As part of the audit process, the auditor will request frommanagement written confirmation concerning representations made to the auditor in connection with theaudit.

The PROTECTED AREAS CONSERVATION TRUST will co-operate fully with the auditor and will makeavailable to the auditor whatever records, documentation and other information is requested by theauditor in connection with the audit. The auditor should be given access to all legal documents,correspondence, and any other information associated with the project and deemed necessary by theauditor. Confirmation should also be obtained of amounts disbursed and outstanding at the Bank and ofamounts disbursed under other donor agency.

It is highly desirable that the auditor become familiar with the relevant World Bank guidelines, whichexplain the Bank's financial reporting and auditing requirements.

These guidelines include:

Guidelines:Annual Financial Reporting and Auditing for World Bank-Financed Activities dated June 30, 2003;Anti-Corruption Guidelines, dated October 2006Disbursement Handbook for World Bank Clients, dated May 2006Disbursement Guidelines for Projects, dated May 2006

The auditor should understand that working papers under World Bank project can be subject to thereview by Client's and/or World Bank designated staff.

MOORE STEPHENS

Moore Stephens Magaiia LLPNew Horizon Building3 YZ Phillip S. W, Goldson HighwayBelize City, Belize

T +501 223 2144F +501 223 2143E [email protected]

www.moorestephens.bz

AUDIT OPINIONS

Independent Auditor's Report to WORLD BANK - Financial AuditStatement of Cumulative Investments

Unqualified Opinion

We have audited the expenses recorded in QuickBooks as set out in Annex 2 [Statement of CumulativeInvestment] totalling BZD 746,214.16/ USD 373.107.08 for the Belize Marine Conservation and ClimateAdaptation Project (MCCAP). ('the Grant recipient") representing the expenses reported under WorldBank Grant number TF 18449-001 BZ. Project number P1 31408 for the period 3 June 2015 to 31 March2016. This Statement of Expenses reflects atl disbursements listed in the yearly financial reportssubmitted by the Grant recipient's national implementing entity Protected Areas Conservation Trust(PACT). In total these amounts represent the actual expenses incurred by the Grant recipient inaccordance with the Grant Agreement. Expenses have been classified according to the component forwhich the resources were utilised. As set out in the relevant grant Agreement signed between thegovernment of Belize and the World Bank on 3 June 2015, the proper utilisation of these funds will aid instrengthening climate resilience of the Belize Barrier Reef System and its productive marine resources.This will be achieved by implementing the different components set in the grant agreement over a periodof five years.

Respective responsibilities of the Grant recipient's national implementing entity and auditorsThe staffs assigned by the national implementing entity is responsible for the preparation of requisitionforms and other financial records and supporting documents for the Grant recipient's activities(transactions) and for such internal control as management determines is necessary to enable thepreparation of a Statement that is free from matenal misstatement, whether due to fraud or error.

Our responsibility is to express an opinion on the Statement of Cumulative Investments based on ouraudit. We conducted our audit in accordance with International Standards on Auditing insofar as thesestandards can be usefully applied in this financial audit and its specific compliance context. Thosestandards require that we comply with ethical requirements and plan and perform the audit to obtainreasonable assurance about whether the Statement is free of material misstatement.

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MOORE STEPHENS

A financial audit involves performing procedures to obtain audit evidence about the amounts anddisclosures in the Statement. The procedures selected depend on the auditor's judgement, including theassessment of the risks of material misstalement of the Statement, whether due to fraud or error- Inmaking those risk assessments, the auditor considers internal control relevant to the grant recipient'spreparation of its financial reports in order to design audit procedures that are appropriate in thecircumstances, but not for the purpose of expressing an opinion on the effectiveness of the project'sinternal control. A financial audit also includes evaluating the appropriateness of accounting policies usedand the reasonableness of accounting estimates made by management.

Scope of the auditThe scope of our audit was as set out in the terms of reference and included obtaining evidence for theamounts and disclosures in the Statement of Cumulative Investments sufficient to express an opinion onit within the scope of our audit. We have taken into account all the available evidence presented to usduring our fieldwork which took place from the 23 May 2016 and concluded the 10 June 2016, and anysubsequent information received. We believe that the audit evidence we have obtained is sufficient andappropriate to provide a basis for our audit opinion.

Unqualified opinionIn our opinion, the attached Statement of Cumulative Investments presents fairly, in all material respects,the expenses of BZD 746,214.16/ USD 373,107.08 incurred by the grant recipient under the GrantAgreement for the period 3 June, 2015 to 31 March, 2016 in accordance with World Bank requirements.The expenses incurred were i) in conformity with approved budget allocation for each componentspecified in the grant agreement, (ii) used wholly and necessarily for the realization of the project'sobjectives; (iii) in compliance with the relevant regulations and rules, policies and procedures specified inthe grant agreement; and (iv) are supported by properly approved vouchers and other supportingdocuments. Sufficient information and necessary explanations for the purpose of the audit have beenobtained and the summary of expenses can be relied upon to support the related withdrawal applications.

Chartered AccountantsBelize City, Belize31 July 2016

MOORE STEPHENS

Moore Stephens Magaiia LLPNew Horizon Building3 X6 Phillip S. W. Goldson HighwayBelize City, Belize

T +501 223 2144F +501223 2143E [email protected]


Independent Auditor's Report to WORLD BANK - Financial AuditStatement of Designated Account

Unqualified Opinion

We have audited the Cash and Cash equivalents recorded in QuickBooks as set out in Annex 3[Statement of Designated Accounts[ "the Statement" totalling BZD 593,251.04/ USD 296,625.52 for useby the Belize Marine Conservation and Climate Adaptation Project being ('the Grant recipient")representing the Cash and Bank Balances reported under World Bank Grant number TF 18449-001 BZ,Project number P131408 for the period 3 June 2015 to 31 March 2016, This Statement of Designatedaccounts reflect all transactions listed in the yearly financial reports submitted by the Grant recipient'snational implementing entity the Protected Areas Conservation Trust (PACT). This ba!ance representsthe ending balance for the project account Belize Bank AC# 19079 for which all related bank transactionsincluding, replenishment of funds, payments made and interest earned on the project account areassigned.

Respective responsibilitles of the Grant recipient's national implementing entity and auditorsThe national implementing entity's accounting staff are responsible for the preparation of monthly bankreconciliations and other financial records for the Grant recipient's activities and for ensuring that internalcontrol are in place as management determines is necessary to enable the preparation of a Statementthat is free from material misstatement, whether due to fraud or error.

Our responsibility is to express an opinion on the Statement based on our audit. We conducted our auditin accordance with International Standards on Auditing insofar as these standards can be usefully appliedin this financial audit and its specific compliance context. Those standards require that we comply withethical requirements and plan and perform the audit to obtain reasonable assurance about whether theStatement is free of material misstatement.

A financial audit involves performing bank procedures in order to obtain audit evidence about theamounts and disclosures in the Statement. The procedures selected depend on the auditor's judgement,including the assessment of the risks of material misstatement of the Statement, whether due to fraud orerror, In making those risk assessments, the auditor considers internal control relevant to the grantrecipient's preparation of its financial reports in order to design audit procedures that are appropriate inthe circumstances, but not for the purpose of expressing an opinion on the effectiveness of the project'sinternal control. A financial audit also includes evaluating the appropriateness of accounting policies usedand the reasonableness of accounting estimates made by management.

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MOORE STEPHENS

Scope of the auditThe scope of our audit was as set out in our terms of reference and included obtaining evidence for theamounts and disclosures in the Statement sufficient to express an opinion on it within the scope of ouraudit. We have taken into account all the available evidence presented to us during our fieldwork whichtook place from the 23 May 2016 and concluded the 10 June 2016, and any subsequent informationreceived. We believe that the substantial audit evidence we have obtained is sufficient and appropriate toprovide a basis for our audit opinion.

Unqualified opinionIn our opinion, the attached Statement of Designated Account presents fairly, in all material respects, thedesignated account balance of BZD 593,251.04/ USD 296,625.52 and is in accordance with the WorldBank accounting requirements, for the period 3 June 2015 to 31 March 2016. The Designated BankAccounts (i) have adequate internal controls in place (ii) Project account is used in accordance with therelevant general conditions, relevant financing agreements and disbursement letter; (iii) Designatedaccounts were in compliance with the bank procedures; (iv) End of period bank balances were properlypresented and (v) transactions were recorded for the appropriate periods. Sufficient supporting recordsand documents necessary for the purpose of the audit have been retained and the summary report canbe relied upon.

uJ~up sb'-~LLP.Chartered AccountantsBelize City, Belize31 July 2016

MOORE STEPHENS

Moore Stephens Magaila LLPNew Horizon Building3 Y. Phillip S. W. Goldson HighwayBelize City, Belize

T +501223 2144F +501 223 2143E rfmagana@moorestephens bz


Independent Auditor's Report to WORLD BANK - Financial AuditStatement of Compliance

Unqualified Opinion

We have examined Marine Conservation and Climate Adaptation Project's compliance with procurementguidelines; guidelines on withdrawal of grant proceeds; Anti-Corruption guidelines; project monitoring,reporting and evaluation; and other obligations as specified in Schedule II of the grant agreement for thefiscal year ended 31 March 2016.

Respective responsibilities of the Grant recipient's national implementing entity and auditorsManagement is responsible for Marine Conservation and Climate Adaptation Project's compliance withthose requirements. Our responsibility is to express an opinion on Marine Conservation and ClimateAdaptation Project's compliance based on our examination.

We conducted our audit in accordance with International Standards on Auditing, Those standards requirethat we comply with ethical requirements, plan and perform the audit to obtain reasonable assuranceabout whether the financial statements are free from material misstatement due to fraud or error. Ouraudit accordingly included examining on a test basis, evidence about Marine Conservation and ClimateAdaptation Project's compliance with those requirements and performing such other procedures as weconsidered necessary i the circumstances. We believe that our examination provides a reasonablebasis for our opinion. Our examination does not provide a legal determination on the MarineConservation and Climate Adaptation Project's compliance with specified requirements.

In our opinion, The Marine Conservation and Climate Adaptation Project complied, in all materialrespects, with the aforementioned requirements for the year ended 31 March 2016.

V4vr. SJN.,k.& kq ez LLP.Chartered AccountantsBelize City, Belize31 July 2016

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Annexes

Annex 1: Summary of World Bank Funds

BZD USDProject No: TF 18449-001 BZ

Total Funds available for disbursement 11,060,000.00 5.530,000.00

Documented disbursement 1,280,701.76 640,350.88

Total available funds to date 9,779,298.24 4,889,649.12

Annex 2: Statement of Cumulative Investments

Project No. TF 18449-001 Current Year Prior Period CumulativeUSD USD

Categories

Category 1: Consists of goods,works,non-consulting services, trainingand monitoring and compliance 210,734.89activitiesexcept for part 2 of the project.Category 2: Goods, Works,non-consulting services and 86,028.78trainingfor part 2 of the project.

Category 3: Consisting of 76,343.41Operating Costs.

Total Expenses by Categories 373,107.08

Page 19

Annex 3: Designated Account Reconciliation Statement


Total Advance by World Bank/Co-Financier 1,000,000.00 500,000.00

Less: Eligible Expenditures for the year 31 March 2016

Less: Cumulative Eligible Expenditure

Present Outstanding Amount Advanced to Designated Account 1,000,000.00 500,000.00

Balance of Designated Account as of 31 March 2016

Balance of Project Account as of 31 March 2016 593,251.04 296,625.52

Plus: Expenditures for current year documented after year end 497,035.68 248,517.84PACT No. 6 (30,820.60) (15,410.30)Plus: Total amount withdrawn not yet claimedReason: 2015 Fiduciary Fees under review by World BankPlus: Amounts claimed in previous applications not yet creditedApplication Number:WA #xxWA #xx

Subtotal of previous applications not yet credited

Less:

Total advance accounted for (no. 4 through no. 9) 1,059,466.12 529,733,06

Difference: Excess deposits on project account (59,466.12) (29,733.06)

EXPLANATION OF ANY DIFFERENCE SHOWN [N LINE 10

The difference is USD 29,733.06 which was due to the following:

In January of 2016 the MCCAP Project received an insurance settlement totalling USD 38,800 due to avehicle accident. A total of USD 91.43 was received due to a sickness benefit paid by the Belize SocialSecurity Board. As at 315t March 2016 the amount of USD 18,705 had not been paid as yet to BelizeEnvironmental Technologies. There was also an overpayment of USD 350.89 by the World Bank uponreimbursing the retroactive and non-retroactive expenses. As at 31" March 2016, there was an ineligibleexpense paid as fiduciary management fees of USD 30,000 which was not documented in World BankClient Connection.

Please note an un-reconciled balance of USD 1,785.74 which is part of the difference and will bereimbursed by PACT if the difference cannot be properly supported at the point of project closure,

Page 20

Annex 4: Statement of sources and use of funds

USD USDProject No: TF 18449-001 BZ Current Period Cumulative

Receipts from World Bank

Designated Account 500,000.00Direct PaymentReimbursement 140,350.88Total Receipts 640,350.88

Expenditures by Project

Component 1- Improving the Protection Regimeof Marine and Coastal Ecosystems 158,990.57

Component 2 Promotion of viable alternativeLivelihoods 86,028.78

Component 3 A Climate Change Knowledge,Attitude and Behaviour practice (KAP) survey 51,744.32

Component 4 Project coordination and Management 76,343.41

Total Expenditures 373,107.08

Adjustments on foreign exchange

Bank BalancesOpening Cash Balances

Designated AccountProject Account

Total Opening Balance

Closing Cash BalancesDesignated AccountProject Account 296,625.52

Total Closing Balance 296,625.52

Page 21

Annex 5: Balance Sheet for year ended 31 March, 2016


Cash and Cash equivalents 593,551.00 296,775.50

Total Assets 593,551.00 296,775.50

MCCAP Accounts Payable 37,410.00 18,705.00

Total Equity (retained earnings) 556,141.00 278,070.50

Total Liabilities and Equity 593,551.00 296.775.50

Page 22

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O-

Annex 7: Audit area ratings

Standard Rating Definition

Satisfactory Internal controls and risk management practices were adequately established

and functioning well. No high risk areas were identified. Overall. the GR's

objectives are likely to be achieved.

Partially Satisfactory Internal controls and risk management practices were generally established

and functioning, but needed improvement, One or more high and medium risk

areas were identified that may impact on the achievement of the GR's

objectives.

Unsatisfactory Internal controls and risk management practices were either not established

or not functioning well. The majority of issues identified were high risk. Hence.

the overall GR objectives are not likely to be achieved.

Annex 8: Audit finding priority ratings

The following categories of priorities are used:

High Prompt action is required to ensure that the International Bank is not exposed to high

risks. Failure to take action could result in major negative consequences and issues.

Medium Action is required to ensure that the International Bank is not exposed to risks that are

considered moderate. Failure to take action could contribute to negative consequences for

the International Bank.

Low Action is desirable and should result in enhanced control or better value for money.

Page 24

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