Capital Transparency & Compliance Officer

Job Purpose

The Transparency & Compliance Officer contributes to controlling, on a risk-based audit approach, the implementation of Acted’s processes in compliance with Acted’s guidelines, specific donor guidelines, best practices, and national regulations in the relevant country.

S/he is responsible for developing and actively contributing to action plans to mitigate the risks identified, in collaboration with his/her manager.

S/He provides technical support and capacity building to the Transparency & Compliance staff to implement the action plan and address the issues.

S/he provides technical support and works to build the capacity of the FLATS teams to identify difficulties, propose action plans and follow them up.

S/He also leads on technical support for donor external audits and due diligences preparation and follow-up.

S/He should comply and ensure compliance to the audit code of conduct.

Objectives

Under the supervision of his/her direct supervisor, the Transparency and Compliance Officer must independently :

1)    Manage the FLATS compliance process and internal audit by :

a)    Using a risk-based audit approach, organizing and implementing controls on the implementation of Acted procedures in each bases in accordance with :

-       Acted manuals of procedures,

-       Donors’ specific procedures,

-       Best practices

-       National legislation

b)    Developing and participating in action plans approved by T&CM;

c)     Perfom monthly compliance tasks in accordance with the monthly compliance review plan;

d)    Proactively draft recommandations and lessons learnt in AUD-05 to improve current process implementation and cover identified risks.

2)    Participate in the preparation, on-site visit (including travel) and follow-up of external audits of donors/third parties and due diligences;

3)    Training, lessons learned and best practices: provide training sessions to reinforce the level of compliance of the teams (and partners involved if required), raise alerts and propose improvements to Acted's current procedures, based on lessons learned and best practices.

4)    Travel and supervise the assigned compliance assistants to assist them in carrying out their tasks.

Duties and Responsibilities

1.     Management of the FLATS and program compliance process

The Transparency and Compliance Officer must know Acted's policies and procedures and must ensure that they are properly implemented on the assigned area. S/he must independently:

·      Participate in planning and coordinating the compliance tasks: monthly compliance reviews and relevant ad-hoc spotchecks of FLATS and program departments, including field visits;

·      Prepare the FLA-02 to be used for the new project, completing all tabs;

·      Propose significant and relevant samples (including partners expenses) to be used as a basis for monthly compliance reviews;

·      Review the results and analyses arising from the compliance reviews and ad-hoc spotchecks in order to flag risk, draft lessons learned with the relevant departments, validated by T&CM and HQ;

·      Participate in planning and coordinating the monthly monitoring of the action plan for implementing and updating the AUD-05 recommendations in collaboration with the relevant departments;

·      Report to the line management any difficulties encountered by each department in implementing Acted procedures.

·      Report risky compliance alerts or suspected fraud to the T&CM;

• Participate in conducting the partner due diligences, vetting and organize monitoring of the implementation of risk reduction plans;

·      Ensure information needed to consolidate the monthly compliance report and the related annexes (MCR) are shared and consolidated on server (FLA-04, FLA-02, FLA-05, FLA-06, AUD-05 and lessons learnt)

·      Participate to and lead the server structure uploading

S/he must also support the T&C team :

·      Collect, based on the relevant sample, the necessary documents from the departments and ensure the quality of the organization of their physical and digitized filing systems, in accordance with FLA-01 guidelines;

·      Complete the FLA-02 "Compliance checklist" on a monthly basis to ensure that FLATS documentation is compliant, report any non-compliant issues, propose and conduct corrective action plans and improvement suggestions where necessary;

·      Carry out monthly "Quotes & Invoices Investigation" (FLA-05), analyze results and report any fraud risk;

·      Complete the FLA-06 "Staff files checklist" on a monthly basis to ensure that personnel files are compliant, report any non-compliant issues and propose corrective action plans and improvement suggestions where necessary;

·      Ensure the implementation of compliance tasks associated with expenditure (including supply chain traceability, market survey, review of FLATS and program documentation, etc.) ;

·      Conduct the relevant ad-hoc spotchecks for the hub FLATS and program departments.

2.     Preparing, carrying out and monitoring external audits

The Transparency and Compliance Officer must be familiar with the external audit procedures for each of the projects implemented and ensure that they are properly prepared, implemented and monitored. S/he must independently:

·      Participate in the external audit preparation related to projects expenses and implemented process;

·      Participate if required to draft the internal control questionnaire to external auditors;

·      Coordinate the review of documentations requested by the external auditors and supporting documents by checking the "Compliance Checklists" (FLA-02) completed by the Compliance Assistant and the supporting documents;

·      Coordinate with the relevant department to share efficiently the required corrective action;

·      Contribute (if required) on drafting the external audit follow-up files (AUD-01) and to the preparation and dissemination of lessons learned and good practice;

·      Identify and communicate risks, draft lessons learned and recommendations to be incorporated into the management of the FLATS and program compliance process and followed on AUD-05 after T&CM validation;

·      Participate (if requested) in the preparation of responses to the audit reports in conjunction with the Capital T&C team ;

·      Participate in following-up the external audit recommendations implementation with the departments concerned (AUD-02)

S/he must also support the T&C team :

·      Facilitate each external audit, by collecting, consolidating, and reviewing the selected supporting documents, identifying and rectifying any anomalies and sending the "Compliance checklists" (FLA-02) to his/her direct supervisor.

3.     Preparing, carrying out and monitoring internal audits

The Transparency and Compliance Officer is responsible for assessing and strengthening the level of compliance of the various departments in each of the bases in his/her hub by implementing the internal audit plan once shared and validated by the T&CM. S/he must work independently on:

·      Based on audit work, fraud risk, upcoming external audit, context of the mission and HoD feedback, identifying the main compliance risks and issues inherent in its assigned hub in order to propose the relevant reviews to be included in the internal audit plan (AUD-06);

·      Preparing the Terms of Reference (AUD-03) and sending them to his/her direct supervisor and to T&CM for validation prior to any internal audit;

·      Prepare AUD08 checklist and necessary testing tools accordingly with the ToRs

·      Participate in planning and supervising internal audit assignments in accordance with the audit plan (AUD-06), validated ToRs and the Acted internal audit methodology by developing the necessary testing tools;

·      Assist to kick of meeting and close out meetings with the relevant department and coordination;

·      Conduct interviews with appropriate members of each departement audited;

·      Consolidating the work (AUD08 and testing files), the action plan (AUD-04B) and the audit report (AUD-04A) for validation by his/her direct supervisor and T&CM before sharing it with the departments concerned;

·      Update the internal audit recommendation tracking file (AUD-05) with validated recommendations;

·      Conduct the monthly sharing and monitoring of the action plan for the implementation of the AUD-05 recommendations in collaboration with FLATS and program departments;

• Report to line management any difficulties encountered by each department in implementing Acted procedures.

S/he must also be able to :

·      Carry out internal audit testings in accordance with the audit plan (AUD-06), the validated Term of references (AUD-03) and the ACTED internal audit methodology (by completing the internal audit checklists and documenting each review using the associated testing files or by developing them);

• Complete the internal audit checklists AUD-08 : draft findings and flag risks based on interviews and appropriate documented testing carried out (using the associated testing files or by developing them);
• Based on implementation feedback from department, carry out appropriate testings to evaluate recommandation implementation;

4.     Training sessions / lessons learn / best practices

The Transparency and Compliance Officer will help to improve compliance competences by proposing training sessions on specific process in the procedures, based on internal and external audits compliance review conclusions. S/he will :

·      Provide practical training on specific aspects of Acted procedures and policies to Acted Staff or partners ;

·      To contribute to the proactive dissemination and use of lessons learned during audit activities (internal and external audits) among national and international staff.

• Process improvement : In collaboration with the departement involved, reinforce current procedures and the quality of Acted internal control, based on international best practices, donors’ requirements, and results of internal & external audits.

5.     Internal Coordination

·      Supervise and be accountable of the compliance assistants’ tasks by monitoring action plans and day-to-day activities;

• Review the work of the assistant(s) and provide full written feedback on their work as well as organize their appraisal;
• Ensure training and capacity building for the Compliance team members to increase the technical ability and skills within the department.

6.     Transparency

• Participate in minimizing risk of fraud and corruption by ensuring adherence to Acted FLATS procedures, Acted Code of Conduct and Acted Policies;
• Upon request of the Capital T&C team, participate in Fraud cases investigations;
• Actively promote Acted’s anti-fraud and whistle blowing policy within all Acted offices in the hub.

7.     Other

• Provide regular and timely updates on task ongoing, progress and challenges to the direct line manager;
• Warn the direct line manager and T&CM in case some major problems arise with a potential financial or reputational impact on the mission;
• Proactively propose improvement and new tools to develop and support the T&C department;
• Perform any other related activities as assigned by direct line manager or T&CM
• Travel for any mission on the T&CM request.

Key Performance Indicators

-       % of FLA02 clearly completed

-       % of expense reviewed with no new irregularities identified during the 2nd review

-       % of risks identified during external audits already flagged during monthly review

-       % of timely submission of the hub’s monthly compliance reports.

-       % of ongoing project with external audit risk covered by the monthly review

-       % of project categories of expenditures reviewed in the compliance review

-       % of project expenditures reviewed in the compliance review

-       % of employee files reviewed in the compliance review.

-       % of implementation of external and internal audit recommendations or reported as difficult to implement with mitigation measure

-       # of monthly contributions to the planning of the hubs audit plan.

-       # of targeted program spot checks proposed and conducted on a bi-annual basis.

-       # of targeted FLATS spot checks proposed and conducted on a bi-annual basis.

-       Frequency of updating tracking tools (lessons learned, recommandation, internal and external audit).

-       Frequency and quality of trainings provided to the assistants s/he is responsible for.

-       Frequency of sharing and follow-up of recommendations with relevant departments

-       Quality and relevance of the lessons learned written up based on the work carried out/reviewed and anomalies identified

-       # of testing tools developed for specific ad-hoc spot checks

-       Regularity and quality of feedback to the assistant for whom s/he is responsible

-       # of good quality ToRs and internal audit reports submitted

-       # of meeting conducted with the partners for RMP follow up

-       # of good quality T3 DDL submitted (based on the number of feedbacks)

*Acted's proposed monthly salary: 1059 JOD's