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November 7, 2012 PowerPoint PPT Presentation


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ICGFM Working in the Field in a Time of Increased Oversight Sean Temeemi, Chief Compliance Officer, FHI 360. November 7, 2012. Office of Compliance and Internal Audit (OCIA) MISSION STATEMENT.

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November 7, 2012

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November 7 2012

ICGFMWorking in the Field in a Time of Increased OversightSean Temeemi, Chief Compliance Officer, FHI 360

November 7, 2012


Office of compliance and internal audit ocia mission statement

Office of Compliance and Internal Audit (OCIA) MISSION STATEMENT

“In partnership with internal and external clients, the Office of Compliance and Internal Audit promotes a world-wide culture of compliance through a value-added, independent, training-based, disciplined approach to evaluation of internal controls and processes in a systematic, integrated, and transparent manner.”

Every FHI 360 Employee is an

advocate, partner, and voice for compliance world-wide

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Quick facts about office of compliance internal audit ocia

QUICK FACTS ABOUT OFFICE OF COMPLIANCE & INTERNAL AUDIT (OCIA)

  • An independent, objective assurance & consulting function, managed by Chief Compliance Officer;

  • Preventative, proactive, collaborative&training-based approach with a focus on personal responsibility at all levels;

  • Field-based Compliance team - “First Responders” to reported issues;

  • Conservative position on credible evidence: early disclosure and prompt refunds to the USG;

  • Internal sourcing through leverage of FHI 360 field office and HQ staff, where independence is not compromised;

  • Coordination with project-funded compliance officers in the field;

  • Direct and unrestricted access to FHI 360 records, information and personnel and frequent and open communication with the Audit Committee.


Ocia organizational chart

OCIA ORGANIZATIONAL CHART

Office of the General Counsel

Director of Compliance (HQ)

Regional Compliance Officers (Field 4)

Risk Advisory Group

Internal Audit

Enterprise Risk Management

Compliance

Internal Audit Team

(HQ & Field 9)

Director of Internal Audit (HQ)

Chief Compliance Officer

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Ocia s role in enterprise risk management

OCIA’S ROLE IN ENTERPRISE RISK MANAGEMENT

Host industry round table discussions

Define risk categories

Define risk tolerance

Host “Risk Advisory Group”

Manage Institutional Risk Framework

Develop Best Practices

Define Institutional Risks

Foster “Tone at the Top”

Recommend actions on identified risks

Advise leadership on risk universe

Identify risk through collaborative interviews with key FHI 360 teams

Monitor risks such as business diversification

Compile and analyze data on risk & trends


November 7 2012

Follow up on observations in 6-12 months after the visit of IA

Coordination of activities with other functions (Ops Finance, Program, Contracts, etc.)

Hands-on training to staff in the field at the time of the review

Education and training (online training, modules)

Guidance to programs on third party and funder-audits.

Annual audit plan – risk-based approach

InternalAudit

Compliance

After Audit

Compliance

Before Audit

Management of Agreed Upon Procedures performed by outside audit firms

Assistance to internal stakeholders on compliance initiatives (e.g., subaward management committee, etc.)

Special Audits (time keeping, intercompany transfers)

Compliance Reviews (Country office and project assessments in preparation for the IA visit) ~ 3 months before IA visit

Assistance to projects during funder audits

Hotline management (phone & web-based)

ROLES OF COMPLIANCE & INTERNAL AUDIT

INVESTIGATIONS (Compliance & Internal Audit)

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Ocia communication strategy

OCIA COMMUNICATION STRATEGY

A strong communication strategy is critical to increasing awareness of OCIA’s organizational role and instilling compliance as part of the culture of the organization

AUDIT COMMITEE regular activity updates

FUNDERS

Visits to Missions & presentations

EXECUTIVE/SENIOR MAGANGEMENT updates & discussions of organization-wide compliance trends

TOOLS:

OCIA BROCHURE

PRESENTATIONS

HOTLINE INFORMATION POSTERS

ONLINE TRAINING MODULES

(Conflict of Interest, Kickback, FCPA, etc.)

DESIRED OUTCOME

COUNTRY OFFICE/FIELD STAFF

Presentations, visits, training

ALL STAFF communication:

quarterly e-newsletters and all staff town halls

EXTERNAL AUDITORS – coordination of audit coverage, annual audit assistance

  • Increase awareness and understanding, both internally and externally, of OCIA’s existence, responsibilities, activities, and ways to report non-compliance

  • Uphold corporate standards & expectations of ethical behavior

  • Develop a trust-based relationship with all stakeholders

  • Build confidence in OCIA’s capabilities, approach, and work product.

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Coordination with internal stakeholders

COORDINATION WITH INTERNAL STAKEHOLDERS

Global Portfolio Management (GPM) and Departments

Operations Finance

Procurement

Program Finance

Operations Support

Human Resources

Contract Management Services

Quality Assurance

Communications

Information Management

Project Management Standards Office

Coordination expectations

Advance notification of audit and compliance reviews

Updates on new relevant evidence and recommended action items

Communication on major notifications (i.e., IG notifications, etc.)

In executing its mission OCIA coordinates with a variety of internal stakeholders, including (but not limited to):

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Key to a successful compliance program

KEY TO A SUCCESSFUL COMPLIANCE PROGRAM

QUICK ACCESS & GEOGRAPHIC COVERAGE

CONTINUOUS IMPROVEMENT

FOCUS ON DETECTION & PREVENTION (ASSISTANCE TO STAFF IN MAKING ETHICAL DECISIONS)

EMPLOYEE UNDERSTANDING OF POLICIES

SUPPORT FROM THE BOARD OF DIRECTORS

COLLABORATIVE RELATIONSHIPS WITH SENIOR MANAGEMENT & OTHER ORGANIZATIONAL STAKEHOLDERS

OUTCOMES:

Projected Strength through Compliance

Reputation (a long-term investment)

Better Employee Moral

Guiding Principle: Compliance & ethics program is not just a “check the box” function – rather it is incorporated into the very fabric of all decision-making and actions.


Questions

QUESTIONS?

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