AUDITOR GENERAL'S REPORT · 2020-03-31 · Auditor General's Report on the INCHR For Fiscal Years 2010/2011 & 2011/2012 1 Ensuring Accountability of Public Resources Republic of Liberia

On The Independent National Commission on Human Rights

For Fiscal Years 2010/2011 & 2011/2012

June 2014

Yusador S. Gaye, CPA, CGMA Auditor General

AUDITOR GENERAL'S REPORT

Auditor General's Report on the INCHR For Fiscal Years 2010/2011 & 2011/2012

1 Ensuring Accountability of Public Resources

Republic of Liberia

TRANSMITTAL LETTER

We have undertaken the audit of the Independent National Commission on Human Rights (INCHR)

accounts and related records for the fiscal years 2010/2011 & 2011/2012. We undertook this audit

under the Auditor General's statutory mandate, as provided for under Chapter 53.3 of the Executive

Law of 1972.

As indicated in the methodology segment of this report, all findings conveyed in the report had

been formally communicated to the Management of INCHR. Where responses were provided by the

INCHR's Management on the findings, the responses have been evaluated and incorporated in this

report.

Given the significance of the matters raised in this report, we urge the Honourable Speaker and

members of the House of Representatives and Honourable Pro Tempore and members of the

Liberian Senate to consider the implementation of the recommendations conveyed herein with

urgency.

Monrovia, June 2014



Table of Contents

TRANSMITTAL LETTER ..................................................................................................... 1

1 EXECUTIVE SUMMARY .............................................................................................. 7

1.1 Background ......................................................................................................... 7

1.2 Summary Of Significant Findings And Recommendations ......................................... 8

1.2.1 Financial Issues ................................................................................................... 8

1.2.2 Administrative Issues ........................................................................................... 9

1.2.3 Operational Issues ............................................................................................. 11

1.2.4 Control-Related Issues ....................................................................................... 12

1.2.5 Governance Issues ............................................................................................. 14

1.2.6 Statement of Accountability ................................................................................ 15

2 DETAILED REPORT .................................................................................................. 16

2.1 Introduction ...................................................................................................... 16

2.2 Background of the INCHR ................................................................................... 16

2.3 Objectives of the Audit ....................................................................................... 17

2.4 Scope of the Audit ............................................................................................. 18

2.5 Audit Methodology ............................................................................................. 18

2.6 Scope Limitation ................................................................................................ 18

2.7 Limitation of Responsibility ................................................................................. 19

3 DETAILS OF FINDINGS AND RECOMMENDATIONS ................................................. 20

3.1.1 Financial Issues ................................................................................................. 20

3.1.1.1 Non-preparation of financial statement by the INCHR Management .................. 20

3.1.1.2 Lack of Internal Audit Functions within the INCHR .......................................... 21

3.1.1.3 Irregularity Noted in Monthly Bank Reconciliation Statements .......................... 22

3.1.1.4 Failure to Maintain a Fixed Assets Register ..................................................... 23

3.1.1.5 Non-Existence of Existing Storeroom Procedures/Records ............................... 24

3.1.1.6 Non-Existence of Essential Staff .................................................................... 25

3.1.1.7 Weakness over Internal Control .................................................................... 26



3.1.1.8 Commissioners’ Non-Performance of Roles in the Governance of the INCHR ..... 27

3.1.1.9 Purchase of Vehicles without Bid ................................................................... 28

3.1.1.10 Absence of Documents to Support the Procurement of Fuel and Gasoline ........ 30

3.1.1.11 Payment Made to Third Party Instead of Service Providers.............................. 32

3.1.1.12 Inconsistencies Noted in Financial Records Presented for Palava Hut ............... 33

3.1.1.13 Maintenance of Multiple Accounts for Single Program- Palava Hut Program ...... 34

3.1.1.16 Irregularities Noted with the INCHR Procurement of Good and Services ........... 35

4 ACKNOWLEDGEMENT .............................................................................................. 38

5 STATEMENT OF ACCOUNTABILITY .......................................................................... 39

6 ACCOUNTABILITY SCHEDULE ................................................................................. 40

7 APPENDIX ............................................................................................................... 41

8 EXHIBIT .................................................................................................................. 48



ACRONYMS

ACRONYM MEANING

AOM Audit Observation Memorandum

AAS Auditing and Assurance Standards

Atty. Attorney

A/C # Account Number

Amt. Amount

CBL Central Bank of Liberia

Cllr. Counsellor

COSO Committee on Sponsoring Organizations

COO Chief Operating Officer

CPA Certified Public Accountant

CGMA Certified Government Management Accountant

FAR Fixed Asset Register

GAC General Auditing Commission

GOL Government of Liberia

GRN/SRV Goods Receipt Note/Store Receipt Voucher

HR Human Resources

IAU Internal Audit Unit

IIA Institute of Internal Auditors

INCHR Independent National Commission on Human Rights

INTOSAI International Organization of Supreme Audit Institutions

IPSAS International Public Sector Accounting Standards

LD Liberian Dollar

LBDI Liberia Bank for Development and Investment

N/A Not Available

PFM Public Finance Management

PPCC Public Procurement & Concessions Commission

PPC Public Procurement and Concession

USD United States Dollars

ISPPIA International Standards for Professional Practice of Internal Auditing



AUDITOR GENERAL’S CONCLUSION ON THE INDEPENDENT NATIONAL COMMISSION

ON HUMAN RIGHTS (INCHR) FOR THE FISCAL YEARS 2010/2011 & 2011/2012

The Management of the Independent National Commission on Human Rights did not compile

financial statements and or maintain proper books of account for the two fiscal years 2010/2011 &

2011/2012 as required by Section 36 of the PFM Act of 2009.The total income for these periods

amounted to USD1,903,747.71 and LD9,452,087.7. Also, there was no evidence that the INCHR

prepared financial statements for periods prior to the audit periods.

Income and Expenditure reports presented could not be confirmed due to the absence of a general

ledger, trial balance and other relevant documents.This limitation denied assurance that the income

and expenditure report as presented showed, in all material respects, a true and fair view of the

INCHR’s operations for the periods audited.

There was demostrable evidence in the lack of effective and efficient internal controls over financial

accounting and reporting, including fundamental accounting practices such as, the preparation of

monthly bank reconciliation, the maintenance of proper books of accounts, maintenance of a fixed

asset regiser, and the maintenance of related financial records.

Non-accountability in the use of public funds was evident in a number of situations observed. This

took the form of inadequate documentation on financial transactions of the INCHR.

There was a notable evidence of non-compliance with provisions of existing laws such as the Public

Financial Management Act of 2009, the INCHR Act of 2005, the Public Procurement and

Concessions Act of 2005 & 2010 Amendment and other regulatory frameworks.

For instance, the INCHR operated without a Comptroller, Procurement Director/Officer, Internal

Auditor, Human Resource Manager, Human Rights Investigators, Program Officers and etc.These

staff were not hired and retained by the INCHR during the periods under audit.

The failure of the INCHR’s Management to hire and retain qualified and trained staff to undertake

accounting and other basic functions contributed to some of the lapses noted in the violation of the

various provisions. The INCHR’s Management should ensure that essential and qualified staff are

recruited, hired and retained for the efficient and effective operations of the entity.

Noted also was the fact that the INCHR did not investigate any case or complaint of human rights

abuse brought before it during the periods under audit in keeping with its mandate as enshrined in

the Act establishing the Commission.



Given the significance of the above issues as well as other matters noted in this report, we have not

been able to obtain sufficient appropriate audit evidence to provide a basis for conclusion.

Accordingly, we are unable to conclude on the available financial information and related records of

the INCHR for the fiscal years 2010/2011 & 2011/2012.

Monrovia, June 2014



1 EXECUTIVE SUMMARY

1.1 Background

1.1.1 The audit of the Independent National Commission on Human Rights was commissioned

on April 6, 2013. The audit covered the fiscal years 2010/2011 & 2011/2012. It was

undertaken in accordance with the Auditor General’s statutory mandate as provided for

under Chapter 53.3 of the Executive Law of 1972.

1.1.2 The INCHR was established by an Act of the National Legislature approved March 11,

2005. The Act mandates the Commission, among other things to:

take up any situation of violation of human rights, which it may deem

necessary, for action according to this act;

hear and consider compliant and petition concerning human rights violation

brought before its by victims, their representatives, third parties, non-

governmental organizations;

submit to the government, senate and any other competent body, on an

advisory basis, either at the request of the authorities concerned or on its

own motion, opinion, recommendation, proposal and report on any matter

concerning the protection and promotion of human right;

examine the legislative and administrative provisions in force, as well as

bills and proposal, and make such recommendation as it deems appropriate

in order to ensure that the provisions conform to the international human

rights standards or instruments.

1.1.3 The objective of the audit was to evaluate the operational and financial management

systems of the INCHR. It thus involved reviews that would enable us to appropriately

report on the attainment of the INCHR’s mandate. Additionally, the objectives of

statutory audits as spelt out under section 53.7 of the Executive Law of 1972 were

undertaken.

1.1.4 We conducted the audit in accordance with International Standards of Supreme Audit

Institutions (ISSAIs).These standards require that we plan and perform the audit so as

to obtain reasonable assurance as to whether the annual financial records are free of

material misstatements.

1.1.5 Findings on significant control weaknesses and other lapses noted were addressed to

Management through Audit Observation Memorandums (AOMs). Where responses were

received on the AOMs, they were evaluated and incorporated in the Management Letter

for the INCHR Management’s attention.



1.1.6 The scope of the audit was limited by the failure of the INCHR’s Management to provide

us its financial statements and other relevant documents for the purpose of the audit.

1.1.7 Additionally, the INCHR’s Management was yet to sign and submit to the Engagement

Team the Management Representation Letter as at the time of reporting despite

persistent follow up.

1.1.8 We reviewed the systems and management controls operated by the INCHR only to the

extent we considered necessary for the effective performance of this audit. As a result,

our review may not have detected all weaknesses that existed or all improvements that

could have been made.

1.2 Summary of Significant Findings and Recommendations

1.2.1 Financial Issues

1.2.1.1 The INCHR’s Management did not prepare and maintain proper books of accounts to

enable the preparation of annual financial statements in accordance with cash basis

International Public Sector Accounting Standards (IPSAS) adopted by the Government of

Liberia in February 2010. We found this situation contrary to the requirements of Section

36 (1,2&3) of the PFM Act and Article 19, Section 4 of the INCHR Act which mandate the

Management of the INCHR to prepare and maintain proper books of account that would

enable the preparation of financial statements to reflect the true and fair financial

position of the entity.

1.2.1.2 The total recorded income for 2010/2011 fiscal year amounted to USD1,144,750.64

while the total amount for 2011/2012 amounted to USD758,997.07 and LD9,452,087.7.

Income and Expenditure reports presented could not be fully confirmed due to the

absence of a general ledger, trial balance, budget performance report, schedule of

allotments, and as well as the non-availability of some of the bank statements and

payment vouchers.This limitation denied assurance that the income and expenditure

report as presented showed a true and fair view of the financial position of the INCHR

for the periods audited.

1.2.1.3 We made several attempts to obtain from the Ministry of Finance records on

disbursements made in favor of the INCHR during the periods under audit. We were yet

to receive the requested documents as at the writing of this report.

1.2.1.4 We have recommended that the Management of the INCHR should prepare annual

financial statements as set out in Section 36 (1,2&3) of the Public Financial Management

Act of 2009 and such statements of the INCHR should be compiled on IPSAS cash basis

of accounting with relevant disclosures as statutorily stipulated. Further, the INCHR’s

Management should ensure proper filing and maintenance of relevant accounting

records for the purpose of accountability and transperancy in the receipt and

disbursements of public funds.



1.2.2 Administrative Issues

1.2.2.1 The INCHR procured nine (9) vehicles valued at USD304,419.98 without due adherence

to Section 48 (1) of the PPC Act. There was no evidence that the Management of the

INCHR published any invitation to bid for the vehicles purchased.The PPC Act requires

procuring entities to utilize the National Open Competitive Bidding process for

procurements in which the estimated contract price of the procurement does not exceed

the applicable ceiling threshold for National Open Competitive Bidding.

1.2.2.2 Contrary to the requirement of the PPC Act, we noted that eight of the nine vehicles

valued at USD277,919.98 were purchased from Cactus Motor while the Mini Bus valued

at USD26,500.00 was purchased from Africa Motor. There was no evidence to indicate

that the vendor Cactus Motor and Africa Motor participated in any bidding process in

which they emerged as winners to have been awarded contracts for the supply of the

vehicles.

1.2.2.3 The results from our extended audit procedures revealed that the eight vehicles were

purchased from the husband of the then Executive Director of the INCHR, Mr. S.

Reginald Pratt who is the Executive Vice President/Chief Operating Oficer of Cactus

Motor. This transaction was carried out by the Chairman of the INCHR, Cllr. R. Leroy

Urey and Mrs. Mornjay George-Pratt. As Executive Director of the INCHR which operated

without a Comptroller and a Procurement Officer, Mrs. Mornjay George-Pratt exercised a

lot of influence in procurement decisions.

1.2.2.4 Non-adherence to the PPC Act in the procurement of goods could undermine the value

for money as contracts could be awarded to bogus companies. It could also lead to

awarding contracts on the basis of family connections, friendship and or business

relationship thus resulting to conflict of interest. We recommended that the INCHR’s

Management should adhere to the PPC Act in its procurement of goods and services and

that material justification should be provided by the INCHR‘s Management to acquit its

decision to undertake purchases without adhering to the PPC Act.

1.2.2.5 We also recommended that Mrs. Mornjay George-Pratt should be held for conflict of

interest as spelt out in Section 131(1) a,b&c of the PPC Act. This Section of the PPC Act

states inter alia, that “public officers involved in procurement activities should at all times

avoid conflict of interest and the appearance of conflict of interest in carrying out his or

her duties and if a conflict of interest should arise, he or she shall immediately disclose

the conflict and excuse himself or herself from any further involvement in the matter.”

1.2.2.6 We also noted that the Management of the INCHR did not adhere to the PPC Act in the

procurement of fuel and gasoline. We did not sight evidence of procurement contracts

between fuel and gasoline suppliers and the INCHR’s Management. This was in

contravention of Rule 21 of the Financial Rules and Section 41, c&d of the PPC Act,

which require procuring entities to enter into contracts with contractors and effect



payments for goods and services only upon full and satisfactory completion of contract

as specified in the contract document.

1.2.2.7 Analysis of the INCHR’s bank statements revealed that the Management of the INCHR

spent USD116,801.55 on the purchase of fuel and gasoline. However, analysis of the

payment vouchers for the purchase of fuel and gasoline revealed a total expenditure of

USD67,101.80 thus resulting to a variance of USD49,699.75. The absence of documents

on the procurement and use of fuel and gasoline could provide opportunities for abuse

and waste in the Commission’s management of fuel and gasoline. The failure of the

INCHR’s Management to maintain the requisite documents could undermine the

accountability of fuel and gasoline procured and used.

1.2.2.8 We recommended that the Management of the INCHR should account for the

unexplained variance of USD49,699.75 between the bank statement and payment

vouchers to acquit the expenditure. Failure to do so, the expenditure of USD49,699.75 is

disallowed and should be refunded by Cllr. R. Leroy Urey and Madam Victoria T. York,

Chairman and Executive Director of the INCHR respectively.

1.2.2.9 Checks valued at USD36,002.00 were issued in the name of employees, instead of the

respective service providers. This practice was contrary to Rule 23 of the Financial Rules

of the Government of Liberia which states, “that payment for goods and services

provided/rendered shall be made only to the vendor or service provider. No payment

shall be made to a third party”. The failure of the INCHR’s Management to make checks

payable to the service providers could deny assurance that the payments went to the

intended beneficiaries. This lapse could also expose the Commission’s cash to abuse and

misuse.

1.2.2.10 We recommended that the Management of the INCHR should ensure due compliance

with Rule 23 of the Financial Rules of the Government of Liberia and obtain appropriate

documentations to acquit the expenditure. The employees in whose names checks were

made payable should provide evidence that the amounts were received by the intended

beneficiaries. In the absence of supporting documents, we disallow the payments and

recommend refund of the moneys into the INCHR’s account.

1.2.2.11 Our analysis of documents submitted for audit by the INCHR revealed that there were

discrepancies between the total amounts reflected in the bank statements, expenditure

reports and cashbook of the INCHR. We observed a variance of USD59,204.00 between

the bank statement debits and expenditure as per the cash book. We also observed a

variance of USD49,260.00 between the total credits reflected in the bank statements and

the total income as contained in the income and expenditure report of the INCHR.

1.2.2.12 The discrepancies in the figures reported as per the income and expediture report,

cashbook and bank statments and other underlying records denied assurance that the

financial data contained in the documents submitted for the periods under review were

complete. The omissions could undermine the truthfulness, fairness and the reliability of

the financial record availed for audit. As a result, we recommended that the Managment



of the INCHR should reconcile the bank statements and report on the factors giving rise

to the differences in the reported income and expenditure.

1.2.3 Operational Issues

1.2.3.1 During the course of the audit, it was revealed that the Management of the INCHR

maintained and operated three separate bank accounts for a single program called the

National Palava Hut program. Two of the accounts (USD and LD) for this program were

maintained at Ecobank while the other account (USD) was maintained at LBDI.

1.2.3.2 The INCHR’s Management asserted that two bank accounts were maintained at Ecobank

for the National Palava Hut program and that the account at LBDI was its National

program account. The Management failed to support its assertion by providing the bank

statements for the LBDI account up to the date of writing this report.

1.2.3.3 Multiple program accounts for a single program could be used as means to divert and

siphon monies from the GOL and donors. Therefore, we recommended that the

Management of the INCHR should maintain a single United States dollar account and a

single Liberian dollar account for its Palava Hut program. We also recommended that the

Management of the INCHR should provide the bank statements for its LBDI account.

1.2.3.4 The Management of the INCHR did not adhere to provisions of the Public Procurement

and Concessions Act in the procurement of goods and services totaling USD661,086.98.

The procurement methods provided for, depending upon thresholds for goods and

services bought as stipulated in the PPC Act were not followed. Consequently, control

procedures provided for under the various levels of competitive bidding for efficient

screening and selection of lowest responsive evaluated bidders were not undertaken.

1.2.3.5 Payments were not supported by contract documents. We did not sight any written

agreements with contractors. Accordingly, we were unable to determine compliance with

terms and conditions of any agreements made with the business entities and individuals

dealt with. Besides the fact that there were no contract documents to support the

payments, it was also noted from our review of payment vouchers and other documents

that the service oriented contracts were without service completion report and

certification of satisfactory completion as required by Financial Rules 21&24 and Section

41 of the Public Procurement and Concessions Act.

1.2.3.6 It was also observed that the management of the INCHR did not undertake

procurement planning for the period under audit contrary to section 40(1)(2) of the

PPC Act which requires all procuring entities to undertake procurement planning with a

view to achieve maximum value for public expenditure and the other objects of the

Act.

1.2.3.7 Non-adherence to the PPC Act and other extent laws relative to procurement of goods,

services and works could undermine the value for money and contract could be awarded

to bogus companies.



1.2.3.7.1 Failure to undertake procurement planning undermines value for money and could also

lead to unbudgeted spending. We recommended that the INCHR’s Management should

adhere to the PPC Act in its procurement of goods, services and works and also provide

evidence of delivery of goods and services, to indicate that goods and services valued at

USD661,086.98 were actually rendered to the Commission. Failure to do so, the

unsupported expenditure is disallowed and particularly, Cllr. R. Leroy Urey and Madam

Victoria T. York should be made to refund the amount.

1.2.4 Control-Related Issues

1.2.4.1 It is required by count Six (6) of the Auditing and Assurance Standards (AAS) that

auditors reasonably satisfy that functions are segregated on the authorization of the

transactions and execution, physical custody of assets and maintenance of the records

and documents. Additionally, the standards require that there should be written policies

and procedures on the authorization of transactions.

1.2.4.2 Contrary to the Auditing and Assurance Standards (AAS) requirements, issues of control

deficiency were symptomatic in that the INCHR’s Management failed to establish written

policies to strengthen the overall controls environment of the Commission.The absence

of adequate controls over the processing and execution of transactions could lead to the

lack of accountability of public funds. We recommended that the Management of the

INCHR should put in place the necessary controls over the processing of transactions.

1.2.4.3 There was no internal audit function undertaken at the INCHR during the periods under

review. This situation is contrary to the requirements of the Internal Control Integrated

Framework, published by the Committee on Sponsoring Organizations (COSO) of the

Treadway’s Commission.

1.2.4.4 Also, contrary to the requirements of International Standards for Professional Practice of

Internal Auditing (ISPPIA) 1000, the INCHR failed to develop an Internal Audit Charter.

The absence of an Internal Audit Charter and an Internal Audit Unit in the operations of

the INCHR denied assurance that the typical functions performed by IAU were

undertaken thus, undermining the objectives of the INCHR.

1.2.4.5 We recommended that the Management of the INCHR should develop an Internal Audit

Charter and establish an IAU to undertake the internal audit functions. Also, an Internal

Audit Charter and a comprehensive Code of Conduct should be developed for the IAU in

line with the overall GOL Internal Audit Strategy and Institute of Internal Auditors (IIA)

Professional Practice Standards.

1.2.4.6 Bank reconciliation is an important accounting procedure used to manage bank

information of an entity and a control tool used to facilitate prompt detection of errors,

irregularities, and fraud that otherwise result to the understatement or overstatement of

bank balances.



1.2.4.7 For the periods under audit, the Management of the INCHR maintained five (5) bank

accounts. The bank accounts were USD and LD operational accounts maintained at the

CBL, USD and LD Palava Hut program accounts maintained at Ecobank and the USD

program account maintained at LBDI. We did not receive bank statements and bank

reconciliation statements for the INCHR’s LBDI account.

1.2.4.8 Our analysis was on statements made available. During review of the statements, we

observed that transactions from the cash book and bank statements were not properly

reflected in the bank reconciliation statements. It was noted that components of

transactions contained in the cashbook and bank statements were misplaced in the bank

reconciliation statements.

1.2.4.9 Misrepresentation in bank reconciliation statement undermines public sector

accountability and could lead to fraud. Additionally, misrepresentation of components of

the cashbook and bank statements in the monthly bank reconciliation statements could

facilitate the concealment of irregular payments and errors. We recommended that the

Management of the INCHR should ensure the monthly and proper reconciliation of the

Commission’s accounts.

1.2.4.10 The International Public Sector Accounting Standards (IPSAS) requires that fixed assets

should be categorized. Also, safeguarding the assets of a public entity is an essential

element of an entity’s internal control. Management is required to institute requisite

measures which should include but not limited to the maintenance of an appropriate

Fixed Assets Register and a policy on the disposal of fixed assets.

1.2.4.11 The INCHR’s Management did not maintain a Fixed Assets Register (FAR) for the periods

under audit. Additionally, the INCHR’s Management did not have any policies on the

maintenance and disposal of its assets. There was also no evidence that the INCHR

conducted a routine physical verification of its assets.The non-existence of the FAR could

lead to abuse and theft of assets, as the FAR constitutes a control over the assets. In the

absence of established policies to safeguard the maintenance and disposition of the

Commission’s assets, the likelihood of the assets being disposed of in an inexplicable

manner could not be ruled out.

1.2.4.12 We recommended that the INCHR’s Management should maintain and compile

appropriate Fixed Assets Register to ensure that public assets are adequately

safeguarded and accurately reported. A policy on fixed assets disposal, consistent with

the provisions of section 123 of the PPC Act on asset disposal, should be instituted by

the Board of Commissioners and the Management of the INCHR to guide the disposal of

the entity’s assets.

1.2.4.13 For the periods under audit, there was no evidence that the Management maintained

records for goods procured for the entity.Transactional documents such as receipt

vouchers; goods receipt note, storeroom requisition, storeroom issuance ledger and tally

or stock cards were non-existent.



1.2.4.14 In the absence of these basic storeroom management records, it would be practically

difficult to track receipts and consumption of public supplies and equipment.

1.2.4.15 Therefore, to enhance the storeroom management system of the Commission, we

recommended the following:

Introduction of the use of basic store records at the Commission;

Initiation of capacity building on basic store keeping on supplies and stores;

and

Payment process for orders should only begin from the receipt of the original

copy of storeroom receipt voucher and Goods Receipt Note (SRV/GRN) from

the storekeeper endorsing the SRV as evidence that orders have been

received and taken on store ledger.

1.2.5 Governance Issues

1.2.5.1 Contrary to the requirements of the INCHR Act, there was no evidence that the

Commission heard or investigated any complaint of human rights violation since it

officially began operation in 2010 though there were series of complaints brought before

it. Atty. Macdilla Howard, Commissioner with oversight on Investigations and Complaints

revealed that complaints brought to the INCHR lacked substantive evidence thus

preventing the Commission from investigating and rendering decisions on alleged human

rights violations.

1.2.5.2 Additionally, there was no evidence of operational manual and strategic policy or

roadmap developed by the Commission to enhance and actualize the programs

implementation of the INCHR. We also observed that the INCHR’s Board of

Commissioners did not provide adequate supervision over the day-to-day operations of

the Commission as there was no evidence to indicate that the Board adopted resolution

and policy/plan to enhance the growth and development of the program implementation

of the INCHR.

1.2.5.3 The non-institution of strategic plan and the failure to formulate major policies for the

INCHR could deny the Commission the benefits of effective long-term planning. We

recommended that the Board of Commissioners should concentrate on its supervisory or

over-sight role and institute strategic plan and policies to guide the Commission in the

pursuit of the mandate ascribed to it by the Act.

1.2.5.4 The attainment of institutional goals and objectives become unachievable in the absence

of qualified and essential staff. Human Resources are valuable assets of an organization.

However, it was observed that the INCHR lacks the requisite Human Resource capacity

to actualize its statutory mandate as the staff in the employ of the Commission were

pre-dominantly drivers and janitors.



1.2.5.5 For instance,the INCHR operated without a Comptroller, Procurement Director/Officer,

Internal Auditor, Human Resource Manager, Human Rights Investigators, Program

Officers and etc. These staff were not hired and retained by the INCHR during the

periods under audit.

1.2.5.6 The absence of essential manpower could undermine the achievement of the overall

goals and objectives of the INCHR. We recommended that the Management of the

INCHR should ensure the timely recruitment and hiring of qualified and essential staff.

1.2.6 Statement of Accountability

1.2.6.1 Overall, both financial and administrative activities undertaken by the INCHR’s

Management during the periods under audit were characterized by financial irregularities

and control deficiencies. The financial irregularities and control deficiencies noted

amounted to USD746,788.73.

1.2.6.2 These irregularities and control deficiencies included third party payments without

relevant suporting documents such as payment receipts from intended beneficiaries.

Also, payments for the purchase of petroleum product without payment vouchers as well

as other anomalies noted in the procurement of goods and services undertaken by the

INCHR’s Management which are yet to be accounted for. Details of these deviations are

provided via the Appendixes and Exhibits.



2 DETAILED REPORT

2.1 Introduction

2.1.1 The audit of the Independent National Commission on Human Rights (INCHR) was

commissioned on April 6, 2013. The Audit covered the fiscal periods 2010/2011 and

2011/2012. The audit was undertaken in accordance with the Auditor General’s statutory

mandate as provided for under Chapter 53.3 of the Executive Law of 1972.

2.2 Background of the INCHR

2.2.1 The INCHR was established by an Act of the National Legislature approved March 11,

2005. The Act mandates the Commission, among other things to:

take up any situation of violation of human rights, which it may deem

necessary for action according to this act;

hear and consider compliant and petition concerning human rights violation

brought before its by victims, their representatives, third parties, non-

governmental organizations;

submit to the government , senate and any other competent body, on an

advisory basis, either at the request of the authorities concerned or on its

own motion, opinion, recommendation, proposal and report on any matter

concerning the protection and promotion of human rights;

Examine the legislative and administrative provisions in force, as well as bills

and proposal, and make such recommendation as it deem appropriate in order

to ensure that the provisions conform to the international human rights

standards or instruments.

2.2.2 The following are key management personnel of the INCHR for the periods covered by

this audit:

Table 1

Name Rank Tenure of Service

Cllr. R. Leroy Urey Chairman October 2010-May 7, 2013

Atty. Boakai Dukuly Vice Chairman October 2010-present

Madam Ruby Morris-

Johnson

Commissioner for Administration and Budget October 2010-present

Mr. James D. Torh Commissioner for Planning, Internal Monitoring and

Evaluation

October 2010-present

Madam Sundaywai

Nelson-Amegashie

Commissioner for Education, Training and

Information


Atty. Macdilla Howard Commissioner for Complaints, Investigations and

Monitoring




Name Rank Tenure of Service

Mr. Thomas Bureh Commissioner for Legislative Assistance, Treaty

Matters and Law


Madam Mornjay

George- Pratt

Executive Director October 2010-March 2011

Madam Victoria T.

York

Executive Director April 2011-present

2.2.3 The National budget for 2010/2011 revealed an appropriation of USD1,244,235.00 while

the 2011/2012 National budget showed USD1,119,613.00. Thus, the total amount

appropriated by the National Legislature during the two fiscal years under audit

amounted to USD2,363,848.00. The INCHR’s documents availed for audit revealed a

total income of USD1,903,747.71 and LD9,452,087.7 as opposed to total appropriation

for the two fiscal periods. See Table 2 below and APPENDIX 1A & 1B

Table 2: Table of Appropriation and Amount Received by the INCHR

Fiscal Year Total Appropriation

USD

Total Amount Received

In USD

Total Amount Received

In LD

2010/2011 1,244,235.00 1,144,750.64 -0-

2011/2012 1,119,613.00 758, 997.07 9,452,087.7

Total USD2,363,848.00 USD1,903,747.71 LD9,452,087.7

2.2.4 The INCHR did not provide the exchange rate between the USD and LD to enable us

determine the conversion parity of the both currencies as at the time these transactions

were incurred.

2.2.5 Our audit effort was thus focused on the total receipted amounts of USD1,903,747.71

and LD9,452,087.7 from GOL as reported by the Management of the INCHR covering

July 1, 2010 through June 30, 2012.

2.3 Objectives of the Audit

2.3.1 The objective of the audit was to evaluate the operational and financial management

systems of the INCHR so as to:

Express opinion/conclusion on whether funds received and disbursed were

used for the intended purposes in accordance with applicable laws, regulations

and financial reporting framework;

Assure that the budget objectives for the periods under audit were achieved

by the INCHR; and

Determine whether appropriate internal control measures were put in place by

the Management of the INCHR to ensure proper accountability of monies

received from the GOL.



2.4 Scope of the Audit

2.4.1 The audit covered July 1, 2010 through June 30, 2012. The audit was undertaken to

meet the requirements of the Auditor General as contained in Section 53.7 of the

Executive Law of 1972.

2.5 Audit Methodology

2.5.1 The audit was conducted in accordance with International Standards of Supreme Audit

Institutions (ISSAIs) as prescribed by INTOSAI. These standards require that we plan

and perform the audit so as to obtain reasonable assurance that the financial records are

free of material misstatements due errors, fraud or default.

2.5.2 In the conduct of the audit, we performed the following:

Reviewed and analyzed the available documents of the INCHR to determine

the amounts allotted and received by the entity.

Obtained internally generated financial documents to assure that budget

objectives for the periods under audit were achieved in the operations of the

INCHR.

Established the existence of internal controls at the INCHR to assure that

appropriate measures were implemented to deter and detect irregular financial

and administrative transactions.

Analyzed documents to assure that expenditures incurred were authorized and

duly accounted for; assets of the Commission were properly recorded,

safeguarded and were utilized for the intended purposes.

Conducted interviews with relevant personnel and also carried out third party

confirmation with vendors.

Findings on significant control weaknesses and other lapses noted were

addressed to Management through Audit Observation Memorandums (AOMs).

Where responses were received on the AOMs, they were evaluated and

incorporated in the Management Letter for INCHR Management’s attention.

2.6 Scope Limitation

2.6.1 Our audit scope was limited by the failure of the Management of the INCHR to make

available key documents including:

Financial Statements

Financial Manual

Operational Manual

Trial Balance

Complete Payment Vouchers

Complete Bank Statements and etc.



2.6.2 We were unable to conduct financial statement audit because the Management of the

INCHR did not prepare financial statements. Our review was limited to the analysis of

other available financial records as well as interviews and third party confirmation.

2.7 Limitation of Responsibility

2.7.1 We reviewed the systems and management controls operated by the INCHR only to the

extent we considered necessary for the effective performance of this audit. As a result,

our review may not have detected all material weaknesses that existed or all

improvements that could have been made.

2.7.2 It is the responsibility of the Management of the INCHR to institute effective systems

and controls for the prevention and detection of fraud, error and non-compliance with

relevant laws and regulations such as PPC Act, the PFM Act, the Financial Rules of

Liberia, Budget Laws, the Revenue Code and all other controlling instruments.



3 DETAILS OF FINDINGS AND RECOMMENDATIONS

3.1.1 Financial Issues

3.1.1.1 Non-preparation of financial statements by the INCHR Management

Observation

3.1.1.1.1 Article 19 Section 4 of the INCHR Act mandates Management to prepare proper books of

account annually and that the books of account should reflect the true and fair financial

position of the entity. Also, Section 36, (1) of the PFM law requires Government officials

handling public financial transactions to ensure that financial information is reported in a

timely, comprehensive and accurate manner.

3.1.1.1.2 Contrary to the above provision, it was observed that the INCHR’s Management did not

prepare financial statements for the periods under audit thus contravening provisions

stipulated in the PFM law, the INCHR Act and other extent laws and regulations

sanctioned by the GOL.

Risk

3.1.1.1.3 The non-compliance to GOL reporting framework relative to the preparation of financial

statements could lead to the misapplication and loss of public resources and undermines

controls over financial reporting and donors’ supports.

Recommendation

3.1.1.1.4 The Management of the INCHR should prepare annual financial statements as set out in

36(1) of the Public Financial Management Act 2009 (PFM) and such statements of the

INCHR should be compiled on the cash basis of accounting with relevant disclosures as

statutorily stipulated.

Management’s Response

3.1.1.1.5 The management acknowledges the receipt of your audit observation Memorandum

dated June 3, in which you mentioned its failure to prepare financial statements for the

period under audit. We would like to inform you that we are cognizant of our failure to

prepare financial statements as it was due to budgetary constraints.

3.1.1.1.6 Therefore, management welcomes your recommendation and that as of July 1, 2013 will

begin the implementation of your recommendation regarding the preparation of financial

statements as required by the PFM and other laws.

Auditor General’s Position

3.1.1.1.7 We note your acceptance of our recommendation to adhere to the PFM Law in preparing

financial statements compliant with IPSAS format for future transactions. However, it is

informative to note that budgetary constraints is not a justifiable reason for

management’s failure to produce cash basis IPSAS financial statements as required by

Law. Management hired the services of other staff members during the periods under



audit but did not hire critical staff such as Accountant and Financial Analyst to institute

financial controls at the entity.

3.1.1.2 Lack of Internal Audit Functions within the INCHR

Observation

3.1.1.2.1 Internal Audit (IA) is an important review and monitoring function in any organization.

An effective internal audit will strengthen the internal control structure of an

organization, thereby contributing to the fulfillment of organizational objects as part of

good corporate governance.

3.1.1.2.2 The Institute of Internal Auditors (IIA), in its Professional Standards 300, describes the

function of Internal Audit as an independent, objective assurance and consulting activity

designed to add value and improve organization operations. It helps an organization

accomplish its objectives by bringing a systematic, disciplined approach to evaluate and

improve the effectiveness of risk management, controls and governance processes.

3.1.1.2.3 These functions include attainment of the vision, mission and objectives of the INCHR in

a cost effective and orderly manner; safeguarding the INCHR’s assets against loss,

abuse and misuse; secure the reliability, adequacy and completeness of the INCHR’s

records; detect and correct errors encountered in operations; minimize the incidence of

fraud and irregularities and provision of timely and accurate reports for monitoring and

decision-making purposes.

3.1.1.2.4 However, it was observed that the Management did not establish an internal audit unit

nor develop an internal Audit Charter to guide the operation of an Internal Audit Unit

during the periods under audit.

Risk

3.1.1.2.5 The absence of an Internal Audit Charter and an Internal Audit Unit in the INCHR’s

operations denied assurance that typical functions performed by IAU were undertaken.

Recommendation

3.1.1.2.6 The Management of the INCHR should develop an Internal Audit Charter and establish

an IAU to undertake the functions specified above. Also, an Internal Audit Charter and a

comprehensive Code of Conduct should be developed for the IAU in line with the overall

GOL Internal Audit Strategy and Institute of Internal Auditors (IIA) Professional Practice

Standards.


3.1.1.2.7 As contained in your audit observation memorandum submitted to us on June 3, 2013

concerning the non-existence of an internal audit function at the INCHR, I am pleased to

inform you that management has included in its 2013/2014 fiscal budget provisions for

the establishment of an internal audit department. Consistent with your observation, the

management has begun the process of recruitment for internal auditors.




3.1.1.2.8 We note your response and we will validate management’s acceptance of our

recommendation during the next audit of the INCHR.

3.1.1.3 Irregularity Noted in Monthly Bank Reconciliation Statements

Observation

3.1.1.3.1 Bank reconciliation is an important accounting procedure used to manage bank

information of an entity and a control tool use to facilitate prompt detection of errors,

irregularities, and fraud that otherwise result to the understatement or overstatement of

bank balances.

3.1.1.3.2 For the periods under audit, the Management of the INCHR maintained five (5) bank

accounts. We did not receive bank statements and bank reconciliation statements for the

LBDI account. Our analysis was thus, based on the available statements of the other four

bank accounts maintained at CBL and Ecobank.

3.1.1.3.3 We observed that transactions from the cash book and bank statements were not

properly reflected in the bank reconciliation statements. It was noted that components of

transactions contained in the cashbook and bank statements were misplaced in the bank

reconciliation statement.

Risk

3.1.1.3.4 Misrepresentation in bank reconciliation statement undermines public sector

accountability and could lead to fraud. Additionally, misrepresentation of components of

the cashbook and bank statements in the monthly bank reconciliation statements could

facilitate the concealment of irregular payments, errors and omissions.

Recommendation

3.1.1.3.5 The Management of the INCHR should ensure the monthly and proper reconciliation of

the Commission’s accounts.

3.1.1.3.6 The INCHR’s Management should ensure that the cash books are adequately maintained

and the cash book balances are reconciled regularly with bank statement balances and

remedial action taken on unexplained differences.


3.1.1.3.7 The management acknowledges and accepts the recommendation contained in your

audit observation and that management , as of fiscal year 2013/2014, will put in place

the necessary controls to ensure that bank statement are properly prepared to avoid

errors.


3.1.1.3.8 We note your response and we will validate your acceptance of our recommendation

during the next audit of the INCHR.



3.1.1.4 Failure to Maintain a Fixed Assets Register

Observation

3.1.1.4.1 The International Public Sector Accounting Standards (IPSAS) requires that Fixed Asset

should be categorized. Also, safeguarding the assets of a public entity is an essential

element of an entity’s internal control. Management is required to institute requisite

measures which should include but not limited to the maintenance of an appropriate

Fixed Assets Register (FAR) and a policy on the disposal of fixed assets.

3.1.1.4.2 As observed, the INCHR’s Management did not maintain a Fixed Assets Register (FAR)

for the periods under audit. Additionally, the INCHR’s Management did not have any

policies on the maintenance and disposal of its assets. There was also no evidence to

prove that the INCHR conducted a routine physical verification of its assets.

Risk

3.1.1.4.3 In the absence of the Fixed Assets Register (FAR), the advisability of pursuing asset-

related activities may not be determined due to the absence of relevant information. The

non-existence of the FAR could lead to abuse and theft of assets, as the FAR constitutes

a control over the assets.

3.1.1.4.4 In the absence of established policies to safeguard the maintenance and disposition of

the Commission assets, the likelihood of the assets being disposed of in an inexplicable

manner could not be ruled out.

3.1.1.4.5 Disposal of the entity’s assets not on the basis of approved policy could be exploited to

the detriment of the INCHR.

Recommendation

3.1.1.4.6 Management should maintain and compile the appropriate Fixed Assets Register to

ensure that public assets are adequately safeguarded and accurately reported.

3.1.1.4.7 Management should maintain a general fixed asset account group ledger and subsidiary

ledger on all assets acquired by the Commission.

3.1.1.4.8 Management should carry out periodic physical verification of its assets to ensure that

assets acquired and disposed off are duly accounted for and reflected on the

Commission financial statements.

3.1.1.4.9 A policy on fixed assets disposal, consistent with the provisions of the PPC Act on asset

disposal, should be instituted by the Board of Commissioners and the Management of

the INCHR.



audit observation Memorandum as dated June 4, 2013 indicating management’s failure



to maintain a fixed asset Register. Management is cognizant of its failure to prepare a

fixed asset register for the period under audit and it is therefore in the process of

employing a comptroller who will work along with the finance staff in putting into

place the recommendation from the GAC in order to avoid the risk of adequately

safe guarding the entity assets.


3.1.1.4.11 We note your response and we will validate the acceptance of our recommendation


3.1.1.5 Non-Existence of Existing Storeroom Procedures/Records

Observation

3.1.1.5.1 The ownership, custody and consumption of material and supplies are assured only

when efficient store procedures are in place to ensure accountability and the proper use

of public stores and material. Also, accountability in the normal course of public business

should be satisfied when supplies have been used up and consumed, with records

showing how and for what purposes they have been used. To achieve this, the following

basic storeroom records are required to be maintained:

Storeroom Ledger

Storeroom Receipt Voucher

Goods Receipt Note

Storeroom Requisition

Storeroom Issuance Ledger

Tally or Stock Cards

3.1.1.5.2 For the periods under audit, there was no evidence that the management maintained

records for goods procured for the entity. There were no transactional documents such

as storeroom receipt vouchers; goods receipt note, storeroom requisition, storeroom

issuance ledger and tally or stock cards.

3.1.1.5.3 We also noted that receipts and delivery of supplies were not entered in storeroom

receipt vouchers and stock cards.

3.1.1.5.4 The only record available that indicated the receipt of goods from the storeroom was a

ledger maintained by the store keeper in which recipients of items signed against a list

of items received.

Risk

3.1.1.5.5 In the absence of these basic storeroom records, it would be practically difficult to track

receipts and consumption of public supplies and equipment. The Commission’s

storeroom management could thus not be said to be effective and efficient under the

circumstances to adequately safeguard public supplies and equipment and also to ensure

that stores were used for the intended purposes.



Recommendation

3.1.1.5.6 To enhance storeroom management system of the Commission, we recommended the

following:

Introduction of the use of basic store records at the Commission;

Initiation of capacity building on basic store keeping on supplies and stores;

and

Payment process for orders should only begin from the receipt of the original

copy of storeroom receipt voucher and Goods Receipt Note (SRV/GRN) from

the storekeeper endorsing the SRV as evidence that orders have been

received and taken on storeroom ledger.



audit observation and that management as fiscal period 2013/2014, it will develop the

requisite human resource capacity in the area of storeroom management and keeping.


3.1.1.5.8 We note your response and we will validate management’s acceptance of our


3.1.1.6 Non-Existence of Essential Staff

Observation

3.1.1.6.1 The attainment of institutional goals and objectives become unachievable in the absence

of qualified and essential staff. Human Resources (HR) are valuable assets of an

organization. However, it was observed that the INCHR lacks the requisite Human

Resource capacity to actualize its statutory mandate as the employees in the employ of

the Commission were pre-dominantly drivers and janitors. See Pie chart below and

Exhibit 1A, 1B &1C

59%22%

10%

9%

INCHR Employees

Drivers & Janitors

Administration

Commissioners

Program



3.1.1.6.2 The INCHR operated without a Comptroller, Procurement Director/Officer, Internal

Auditor, Human Resource Manager, Human Rights Investigators, Program Officers and

etc. These staff were not hired and retained by the INCHR during the periods under

audit.

3.1.1.6.3 A review of the INCHR’s personnel listing revealed a total number of Sixteen (16) drivers

and janitors which accounted for 59 percent of the INCHR’s employees, staff in

administration were Nine (9) which accounted for 22 percent of the Commission’s

employees, Seven (7) Commissioners representing 10 percent of the Commission’s staff

and Six (6) staff in program representing 9 percent of the Commission’s employees.

Risk

3.1.1.6.4 The absence of essential manpower could undermine the achievement of the overall

goals and objectives of the INCHR.

Recommendation

3.1.1.6.5 The Management of the INCHR should ensure the recruitment and hiring of qualified and

essential staff.



audit observation and that management has included in its 2013/2014 budget provisions

for the hiring of essential staff who will with other staff foster the program

implementation of the INCHR




3.1.1.7 Weakness over Internal Control

Observation

3.1.1.7.1 It is required by count six (6) of the Auditing and Assurance Standards (AAS) that

auditors reasonably satisfy that functions are segregated on the authorization of

transactions and execution, physical custody of assets and maintenance of the records

and documents. Additionally, the standards require that there should be written policies

and procedures on the authorization of transactions.

3.1.1.7.2 Contrary to the AAS requirements, issues of control deficiency were symptomatic in that

the INCHR’s Management failed to establish written policies to strengthen the overall

controls environment of the Commission.

Risk

3.1.1.7.3 The absence of adequate controls over the processing and execution of transactions

could lead to the lack of accountability of public funds.



Recommendation

3.1.1.7.4 The Management of the INCHR should put in place the necessary controls over the

processing of transactions.



audit observation memorandum and that management as of fiscal period 2013/2014 will

ensure that the necessary controls over the processing of transactions are put in place.




3.1.1.8 Commissioners’ Non-Performance of Roles in the Governance of the INCHR

Observation

3.1.1.8.1 The Act that created the INCHR, among other things, states the functions of the

Commissioners as follows: To hear and consider complaints and petition concerning

human rights violations brought before the Commission by victims, their representatives,

third parties, non-governmental organizational, associations of trade unions or any other

representative organizations.

3.1.1.8.2 Regarding the functions of Chairperson of the INCHR, the Act states that the

Chairperson, in consultation with the Commissioners, may allocate responsibilities among

Commissioners, which may include policy making and supervisory responsibilities.

3.1.1.8.3 Conversely, it was noted that the Commissioners did not hear or investigate any

complaint of human rights violation since they began operation in 2010 though there

were series of complaints brought before the Commission. Atty. Macdilla Howard,

Commissioner with oversight on Investigation and Complaints was interviewed regarding

the inability of the Commission to hear and conduct investigation of alleged human

rights violations. Atty. Macdilla Howard revealed that complaints brought to the INCHR

lacked substantive evidence thus preventing the Commission from rendering decisions

on alleged human rights violations.

3.1.1.8.4 Additionally, there was no operational manual and strategic policy or roadmap developed

by the Commission to enhance and actualize the programs implementation of the

INCHR. It was also noted that the INCHR’s Board of Commissioners did not provide

adequate supervision over the day-to-day operations of the Commission as there was no

evidence to indicate that the Board adopted resolution and policy/plan to enhance the

growth and development of the program implementation of the INCHR.

Risk

3.1.1.8.5 The non-institution of strategic plan and the failure to formulate major policies for the

INCHR could deny the Commission the benefits of effective long-term planning.



Recommendation

3.1.1.8.6 The Board of Commissioners should concentrate on its supervisory or over-sight role and

institute strategic plan and policies to guide the Commission in the pursuit of the

mandate ascribed to it by the Act.



audit Query outlining the commissioners’ failure to perform their statutory mandate and

that commissioner have reached a decision to produce a monthly work-plan which will

be summarized into the INCHR quarterly report.


3.1.1.8.8 We note your response and we will validate your acceptance of our recommendation


3.1.1.9 Purchase of Vehicles without Bid

Observation

3.1.1.9.1 The INCHR procured nine (9) vehicles valued at USD304, 419.98 without due adherence

to the PPC Act. There was no evidence that the Management of the INCHR prepared and

issued bidding documents to solicit the expression of interest for the supply of the

vehicles by means of advertised open bid proceedings to which equal access is provided

to all eligible and qualified bidders without discrimination as required by sections 46 & 48

of the PPC Act.

3.1.1.9.2 The vehicles were intended for use by the Commissioners, Executive Director and a

utility Bus for employees. Eight of the nine vehicles valued at USD277,919.98 were

purchased from Cactus Motor while the Mini Bus valued at USD26,500.00 was purchased

from Africa Motor. APPENDIX 2A&2B & EXHIBITS 2A-2R

3.1.1.9.3 We undertook extended audit procedures to determine the procedure employed in the

purchase of the vehicles. It was revealed that eight vehicles were purchased from

Cactus Motor by the Chairman of the INCHR, Cllr. R. Leroy Urey and Mrs. Mornjay

George-Pratt, Executive Director who is also wife of the Executive Vice President of

Cactus Motor, S. Reginald Pratt.

3.1.1.9.4 Section 131(1) a,b&c of the PPC Act states “conduct of procuring entities, public officers

and their representatives, any public officers involved in requisitioning, planning,

preparing and conducting procurement or concession proceedings and administering

the implementation of contracts shall: discharge his or her duties impartially so as to

ensure fair competitive access to public procurement by bidders, always act in the

public interest and in accordance with the object and procedures set out in this Act ;

at all times avoid conflict of interest and the appearance of conflict of interest in

carrying out his or her duties and if a conflict of interest should arise, he or she shall



immediately disclose the conflict and excuse himself or herself from any further

involvement in the matter.”

3.1.1.9.5 Non-adherence to the PPC Act and other existing laws in the procurement of goods,

services and works could undermine the value for money as contracts could be awarded

to bogus companies. Also, non-adherence to the PPC Act could lead to conflict of interest

as contracts could be awarded on the basis of personal and business relationship.

Risk

3.1.1.9.6 Non-adherence to the PPC Act and other extent laws in the procurement of goods,

services and works could undermine the value for money as contract could be awarded

to bogus company. Also, non-adherence to the PPC Act could lead to conflict of interest

as contracts could be awarded on the basis of personal and business relationship.

Recommendation

3.1.1.9.7 The INCHR’s Management should adhere to the PPC Act in its procurement of goods,

services and works, and that material justification should be provided by the INCHR’s

Management to acquit its decision to undertake purchases without adhering to the PPC

Act.

3.1.1.9.8 Further, Mrs. Mornjay George-Pratt, Executive Director of the INCHR should be held for

conflict of interest as spelt out in Section 131, (1) a,b&c of the PPC Act.



audit observation Memorandum as dated June 4, 2013 in which you indicated that

management made a number of purchases without a bidding process as required by the

PPC Act. On the basis of your observation, I would like to inform you that management

will adhere to the relevant provisions of the PPC Act as we have been in consultation

with the PPC to train the procurement officers when he/she is employed.

Former Executive Director, Mornjay George-Pratt:

3.1.1.9.10 This is in response to your communication concerning the procurement of nine vehicles

by the Independent National Commission on Human Rights (INCHR) which according to

you violated the PPC Act of 2005.

3.1.1.9.11 In the said communication you specifically stated that “further investigation conducted

on the procurement of the vehicles established that the Executive Vice President /coo of

cactus Motor, S. Reginald Pratt, a vendor from whom the vehicles [were] purchased is a

husband of the Executive Director of the INCHR, [Mornjay Pratt], By such assertion, you

are implying that I sought to or did in fact benefit S. Reginald Pratt, my husband,

through the procurement of the subject vehicles.

3.1.1.9.12 I deem it necessary to state that your assertion is completely inaccurate , totally false

and I categorically deny that I at any time during my tenure at INCHR concluded any



transaction in violation of the PPC Act in order to benefit my husband and any other

member of my family.

3.1.1.9.13 For the record, please be informed of the following:

I am the wife of S. Reginald Pratt who is the Executive Vice President /COO of Cactus

Motors; I was employed by INCHR on October 1, 2010 and I resigned the position of

Executive Director in February 2011.

3.1.1.9.14 I neither assisted, participated in nor did I conclude the negotiation resulting in the

procurement of the subject vehicles by INCHR; and

3.1.1.9.15 All documents were left at INCHR with the finance department and in the offices of the

Executive Director which she can verify.

3.1.1.9.16 In light of the above, I request that you make the necessary correction in the records of

your report. Needless to say, you are free to contact me should you desire additional

information and/or clarification.


3.1.1.9.17 We note management’s response and we will validate management’s acceptance of our


3.1.1.9.18 On account of the response provided by Mrs. Mornjay George-Pratt, the Executive

Director of the INCHR, we hold the view that said response failed to address the

substantive issue of apparent conflict of interest as indicated in our observation. Further,

the purchase of the vehicles from Cactus Motor occurred in the month of October 2010

at which time Mrs. Pratt served as Executive Director of the INCHR responsible to ensure

that all the procurement processes were adhered to. Therefore, Mrs. Pratt cannot excuse

herself from the transaction on the basis of resignation and or tenure. Again, see exhibit

2A-2O.

3.1.1.9.19 Mrs. Pratt confirmed that she is the wife of Mr. S. Reginald Pratt, Executive Vice

President of the vendor, Cactus Motor from whom eight vehicles were purchased. Mrs.

Pratt’s actions to ignore the PPC Act by failing to disclose her husband’s position in the

company constitutes a conflict of interest. We therefore maintain our recommendation.

3.1.1.10 Absence of Documents to Support the Procurement of Fuel and Gasoline

Observation

3.1.1.10.1 For the periods under audit, there was no evidence that the Management adhered to the

PPC Act in the procurement of fuel and gasoline. We did not sight evidence of

procurement contract between fuel and gasoline suppliers and the INCHR’s

Management. This was in contravention of Rule 21 of the Financial Rules and the PPC

Act, which require payments for goods and services or works to be made only on full



and satisfactory completion of goods and services as specified in contract. Also, the

INCHR’s Management did not maintain fuel and gasoline requisition and distribution logs

for petroleum products procured and used.

3.1.1.10.2 Absence of documents on the procurement and use of petroleum products could provide

opportunities for abuse and waste in the Commission’s management of fuel and gasoline

procured.

3.1.1.10.3 Additionally, analysis of the bank statement revealed that the Management of the INCHR

spent USD116, 801.55 on the purchase of fuel and gasoline while the vouchers tallied

revealed a total expenditure of USD67, 101.80 thus resulting to a variance of USD49,

699.75 for the periods under audit. APPENDIX 3

Risk

3.1.1.10.4 The absence of documents on the procurement and use of fuel and gasoline could

provide opportunities for abuse and waste in the Commission management of fuel and

gasoline. The failure of the INCHR’s Management to maintain the requisite documents

could undermine the accountability of fuel and gasoline procured and utilized. Non-

adherence to the PPC Act in the procurement of fuel and gasoline could lead to conflict

of interest.

Recommendation

3.1.1.10.5 The Management of the INCHR should account for fuel and gasoline procured and

consumed valued US$49,699.75 by providing the payment vouchers, coupons stocks,

fuel consumption log/report and details of the staff who consumed the fuel.

3.1.1.10.6 The INCHR Internal Audit Unit when established should regularly audit fuel and gasoline

distribution and consumption on the Commission vehicles, generators and the staff.

3.1.1.10.7 Log books should be maintained by the INCHR’s Management for all vehicles/generators

and average fuel consumption per kilometer computed monthly by the transport officer.

Any excess consumption should be noted and remedial action duly instituted.



audit observation and that management is in the process of formulating procedures

which will enable it to implement the GAC recommendation relative to stock purchased

and consumed.


3.1.1.10.9 We note management’s response and we will validate acceptance of our

recommendation in the next audit of the INCHR. Notwithstanding, management is still to

provide explanation for the variance noted.



3.1.1.10.10 Failure to do so, the expenditure of USD49, 699.75 is disallowed and should be

refunded by Cllr. R. Leroy Urey and Madam Victoria York, Chairman and Executive

Director of the INCHR respectively.

3.1.1.11 Payment Made to Third Party Instead of Service Providers

Observation

3.1.1.11.1 During our review of disbursement vouchers for the periods under review, we observed

that several checks valued at USD36, 002.00 were issued in the name of employees,

instead of the respective service providers. This practice was contrary to Rule 23 of the

Financial Rules of the Government of Liberia, which states “that payment for goods and

services provided/rendered shall be made only to the vendor or service provider. No

payment shall be made to a third party”.

3.1.1.11.2 Further, this situation was also indicative of the INCHR Management’s failure to adhere

to the Financial Rule and to establish internal control over cash management. We could

therefore not independently verify whether the total amount of USD36, 002.00 was used

by the INCHR’s Management for the intended purposes. APENDIX 4

Risk

3.1.1.11.3 The failure of the INCHR’s Management to make checks payable to the service providers

could deny assurance that the payments went to the intended beneficiaries. This lapse

could also expose the Commission’s cash to abuse and misuse.

Recommendation

3.1.1.11.4 The Management of the INCHR should ensure due compliance with Rule 23 of the

Financial Rules of the Government of Liberia and obtain appropriate documentations to

acquit expenditure. The employees in whose names checks were made payable should

provide evidence that the amounts were received by the intended beneficiaries. In the

absence of supporting documentation, the expenditure is disallowed and we recommend

that the amounts be refunded.


3.1.1.11.5 Management acknowledges and accepts the recommendation as contained in your audit

observation. Management will ensure that service providers are paid directly by checks

for service rendered.


3.1.1.11.6 We note your response and maintain our recommendation that the employees should

account for the checks written in their names which were intended for third parties;

failure to do so, the amounts should be refunded by those employees into the account of

the INCHR.



3.1.1.12 Inconsistencies Noted in Financial Records Presented for Palava Hut

Observation

3.1.1.12.1 Analysis of documents revealed that there were discrepancies between total amounts

reflected on bank statements, expenditure report and cashbook of the INCHR.

3.1.1.12.2 Examination of available bank statements for the National Palava Hut Program revealed

that the CBL made transfers totaling USD326, 892.43 and LD4, 111,100.00 in favor of

the INCHR. These transfers were made to the INCHR Ecobank accounts. APPENDIX 5A

& 5B

3.1.1.12.3 As observed, the Management of the INCHR made withdrawals from its United States

dollar account totaling USD210,073.33 including total bank charges of USD300.00. As,

the running balance as at June 29, 2012 should have been USD116,819.13 but the bank

statements reported a running balance of USD93,291.97 thus leaving a variance of

USD23,527.13 unexplained.

3.1.1.12.4 Additionally, analysis of the INCHR cashbook showed that the total expenditure made

was USD269,277.23 as opposed to the total withdrawal ofUSD210,073.33 as reflected in

the United States dollars bank statements of the INCHR. The variance between the total

withdrawal as per the bank statements and total expenditure as per the cash book was

calculated at USD59,204.00.

Table 2: Variance between Bank Statement and Cashbook

Withdrawals as per Bank

Statements Expenditure as per Cash Book Variance

USD210,073.33 USD269,277.23 USD59,204.00

3.1.1.12.5 Similarly, the income and expenditure report submitted by the Management of the

INCHR indicated a total cash receipt of USD376, 151.97 as opposed to USD326, 892.43

deposits reflected in the bank statements. The variance between the income and

expenditure report and the total bank deposits was calculated at USD49, 260.00.

Table 2B: Variance between Income & Expenditure Report and Bank Statement

Deposits

Bank Statement Deposits Income & Expenditure Report Variance

USD326,892.43 USD376,151.97 USD49,260.00

3.1.1.12.6 The discrepancies of figures reported in the expenditure report, cashbook and bank

statements and other underlying records denied assurance that the financial data

contained in the documents submitted for the periods under review were complete. The

omissions could undermine the truthfulness, fairness and the reliability of the financial

record availed for audit.



Risk

3.1.1.12.7 Understatement of funds received and deposited could undermine the work of the

Commission.

3.1.1.12.8 Funds could be diverted for purposes other than its intended ones thereby leading to

projects or programs not completed.

Recommendation

3.1.1.12.9 The Management of the INCHR should reconcile the bank statements of its accounts and

report on the factors giving rise to the differences in the reported income and

expenditure.



audit observation memorandum and will ensure that figures are accurately reconciled

and reported.


3.1.1.12.11 We note management’s response and we will validate management’s acceptance of our


3.1.1.13 Maintenance of Multiple Accounts for Single Program- Palava Hut Program

Observation

3.1.1.14 During the course of the audit, it was revealed that the Management of the INCHR

maintained and operated three separate accounts for its National Palava Hut program.

Two of the accounts, which included Liberian and United States dollar accounts were

maintained at Ecobank while another United States dollars account was maintained at

LBDI.

3.1.1.15 Though the INCHR’s Management asserted that it maintained two bank accounts for the

National Palava Hut program and that the account maintained at the LBDI was its

program account, the Management failed to provide the bank statements for the LBDI

account despite persistent request.

3.1.1.15.1 Also, we found no evidence to distinguish between the Palava Hut program accounts and

the INCHR (program) account as alluded to by the INCHR’s Management. Analysis of

payment vouchers revealed that funds were drawn from the LBDI’s account to support

Palava hut activities. Further, the only program undertaken by the Commission during

the periods under review as per records made available for audit was the National Palava

Hut Program.

Table 3: Three Separate Palava Hut Program Accounts

Bank Name Account Title Amt. Transferred

Ecobank Palava Hut Program USD326,892.43



Bank Name Account Title Amt. Transferred

LBDI INCHR (Program) N/A

Ecobank Palava Hut Program LD4,111,100.00

Risk

3.1.1.15.2 Multiple accounts for a single program could be used as a mean to divert and siphon

monies from the GOL and donors.

Recommendation

3.1.1.15.3 The Management of the INCHR should maintain a single United States dollar account

and a single Liberian dollar account for its National Palava Hut program.

3.1.1.15.4 Management should also provide bank statements for the Program account maintained

at LBDI for the periods under audit.


3.1.1.15.5 The management acknowledges your recommendation and clarifies points raised

reference three account for Palava hut. The Palava hut has only two accounts: LD a/c #

005-001147178-46-601, USD a/c #0051010147178-46-601. The account at LBDI is the

program account which was opened in conformative with the National Budget for

programs implementations. The title of the account is independent National Commission

on Human Rights (program) a/c#001USD21320999801.


3.1.1.15.6 We note your response and maintain that the INCHR’s Management should provide the

bank statements for the account maintained at the LBDI for the periods under audit.

3.1.1.16 Irregularities Noted with the INCHR Procurement of Good and Services

Observation

3.1.1.16.1 The Management of the INCHR did not adhere to provisions of the Public Procurement

and Concessions Act in the procurement of goods and services totaling USD661,086.98.

The procurement methods provided for, depending upon thresholds for goods and

services bought as stipulated in the PPC Act were not followed. APPENDIX 6A & 6B

3.1.1.16.2 Consequently, control procedures provided for under the various levels of competitive

bidding for efficient screening and selection of lowest responsive evaluated bidders were

not undertaken.

3.1.1.16.3 Payments were not supported by contract documents, as we did not observe any written

agreements. Accordingly, we were unable to determine compliance with terms and

conditions of any agreements made with the business entities and individuals dealt with,

in the absence of written contracts.



3.1.1.16.4 Besides the fact that there were no contract documents to support the payments, it was

also noted from our review of payment vouchers and other documents that the service

oriented contracts were without service completion report and certification of satisfactory

completion as required by Financial Rules 21&24.

3.1.1.16.5 It was also observed that management did not undertake procurement planning for

the periods under audit contrary to section 40(1)(2) of the PPC Act which requires all

procuring entities to undertake procurement planning with a view to achieve maximum

value for public expenditure and the other objects of the Act. As per the PPC Act, each

fiscal year the procurement unit is supposed to prepare a draft annual procurement plan

for goods, works, and services for use by the procuring entity in the procuring entity‘s

budgeting process.

3.1.1.16.6 Upon budget approval, the procurement unit prepares an annual procurement plan

for goods, works and services in accordance with the procuring entity‘s approved

programs and Budget. The annual procurement plan is then furnished to the

Procurement Committee. This function was not undertaken by the INCHR’s Management

during the periods under audit because of the absence of a procurement unit.

Risk

3.1.1.16.7 Non-adherence to the PPC Act and other existing laws relative to procurement of goods,

services and works could undermine the value for money and contract could be awarded

to bogus companies.

3.1.1.16.8 Failure to undertake procurement planning undermines value for money and could also

lead to unbudgeted spending.

Recommendation

3.1.1.16.9 The INCHR Management should adhere to the PPC Act of 2005 in its procurement of

goods, services and works and also provide and produce evidence of delivery of goods

and services, to indicate that USD661,086.98 worth of goods and services were actually

rendered to the Commission.

3.1.1.16.10 The Management of the INCHR should undertake procurement planning to maximize

the value for public money and avoid unbudgeted spending.


3.1.1.16.11 The commission acknowledges and accepts the recommendation as contained in your

audit observation. Management has been attending workshop and is in contact with the

PPCC in obtaining full understanding of its Act as regard to the procurement of goods

and services. All of the commission transactions were done on cash basis in 2013 fiscal

year. We are now liasing with the PPCC to provide us with training in the implementation

of its Act.



3.1.1.16.12 Referencing your audit query dated June 3,2013, which you outlined management’s

failure to adhere to section 53(1) (C) of the 2005 PPC Act regarding the awarding of

contracts for the acquisition services , I am pleased to inform you that management

is aware of the breach/violation of the above provision mentioned in the PPC Act , and

as such, management has taken into consideration the recommendation n contained in

your communication regarding the adherence to processes required by the PPC Act on

the purchases of goods and services. Furthermore, management is in the process of

recruiting a qualified procurement officer as of the date of the issuance of your

observation.


3.1.1.16.13 We note your response and maintain that the management should account for the

goods and services procured. Failure to do so, the unsupported expenditure is disallowed

and particularly, Cllr. R. Leroy Urey and Madam Victoria T. York, Chairman and Executive

Director of the INCHR respectively should be made to refund the amount.



4 ACKNOWLEDGEMENT 4.1 We acknowledge the cooperation and assistance provided to the GAC’s Engagement

Team by the Independent National Commission on Human Rights during the course of

the audit. The efforts and commitment of the GAC’s Audit Engagement Team in

conducting the audit and reporting thereon are also graciously acknowledged.

Monrovia, June 2014



5 Statement of Accountability

5.1 Overall, both financial and administrative activities undertaken by the INCHR’s

Management during the periods under audit were characterized by financial irregularities

and control deficiencies. The financial irregularities and control deficiencies noted

amounted to USD746,788.73.

5.2 These irregularities and control deficiencies included third party payments without

relevant supporting documents such as payment receipts from intended beneficiaries.

Also, payment for the purchase of petroleum product without payment vouchers as well

as other anomalies noted in the procurement of goods and services undertaken by the

INCHR’s Management which are yet to be accounted for. Details of these deviations are

provided via the Appendixes and Exhibits.



6 ACCOUNTABILITY SCHEDULE

No. INCHR Audit

Report Observation Amount USD

Amount

LD

Officers

Responsible

1. Absence of

Documents to

Support the

Procurement of

Fuel and

Gasoline. Page

30

Analysis of the INCHR bank

statement revealed that the

management of the INCHR

undertook the procurement of

petroleum products without

supporting documents

49,699.75 -0-

Cllr. R. Leroy Urey

Madam Victoria T.

York

2. Third Party

Payments. Page

31

Contrary to the requirement

of Financial Rule 23 of

Liberia, the management of

the INCHR made several

payments intended for

vendors/service providers in

the names of its employees 36,002 -0-

Momo S. Nyandibo

Arthur Smith

3. Irregularities

noted in the

procurement of

goods and

services. Page

32

Contrary to the requirements

of the PPC Act, PFM Act,

Financial Rules etc, several

purchases for goods and

services were made by the

management of the INCHR

without the relevant

supporting documents 661,086.98 -0-

Cllr. R. Leroy Urey

Madam Victoria

York

TOTAL USD746,788.73 -0-



7 APPENDIX

APPENDIX 1A: USD CASH RECEIPT FROM GOL AS PER CBL’S BANK STATEMENTS

USD Income In 2010/2011

DATE CHECKS # USD AMOUNT

10/20/2010 6400 327,585.00

12/3/2010 10252 56,.83436

12/16/2010 11860 53,540.83

1/19/2011 16340 20,000.00

2/2/2011 17014 65,925.95

2/25/2011 19136 57,878.05

3/18/2011 20634 25,000.00

3/29/2011 21878 58,714.12

4/5/2011 22841 300,000.00

5/11/2011 26781 66,153.70

6/6/2011 29412 57,617.29

6/29/2011 31218 55,501.34

Total USD Income for 2010/2011 USD1,144,750.64

USD Income In 2011/2012

DATE CHECKS # USD

8/10/2011 68148 48,832.64

8/19/2011 864 43,432.34

8/25/2011 995 5,177.20

9/28/2011 4227 7,667.60

10/3/2011 4345 43,432.34

10/24/2011 5975 43,446.42

10/27/2011 6349 9,112.00

11/24/2011 9003 31,735.20

11/28/2011 9285 43,856.22

12/15/2011 11253 43,180.18

12/23/2011 12493 11,495.20

1/20/2012 13913 43,772.32

1/20/2012 13914 12,172.00

2/17/2012 16352 9,751.80

3/21/2012 18733 3,352.00

4/19/2012 21591 43,352.00

4/24/2012 21737 47,452.33

5/4/2012 22643 50,000.00

5/22/2012 24355 19,879.67

5/22/2012 24476 43,746.22

5/28/2012 25222 90,392.43

6/19/2012 38049 20,077.00

6/21/2012 28099 43,681.96

Total USD Income In 2011/2012 USD758,997.07

Grand Total In USD for 2010/2011 & 2011/2012 USD1,903,747.71



APPENDIX 1B: LD CASH RECEIPT FROM GOL IN 2011/2012

Date CHECKS# LD Amount

8/10/2011 57 566,903.40

8/25/2011 1040 563,020.50

9/28/2011 3380 833,851.50

10/27/2012 706 164,015.40

11/24/2011 893 571,233.60

12/28/2011 1247 205,418.79

1/12/2012 10976 2,810,006.47

1/20/2012 1476 220,666.84

3/17/2012 12834 179,193.00

3/21/2012 2192 61,572.00

4/4/2012 2441 868,291.20

5/28/2012 2744 365,295.00

5/28/2012 2792 1,661,100.00

6/19/2012 3054 381,520.00

Total LD Income In 2011/2012 LD9,452,087.7

APPENDIX 2A: VEHICLES PURCHASED FROM CACTUS MOTOR WITHOUT BID

No. Vehicle name Cost(US) Assignee PLATE

No.

Delivery Note

date

1 Chevrolet ,Captiva SUV-4-

door standard 33,333.33

James D. Torh RL-62 October 12,2010

2 Chevrolet ,Tahoe SUV-5-

door (Automatic) 55,000.00

Cllr. Leroy Urey RL-60 October 14,2010

3 Chevrolet, Captiva SUV-4-

door (Standard) 33,333.33

Thomas A. Bureh RL-63 October 12,2010

4 Chevrolet, Captiva SUV-4-


Sunadaiwai E. N.

Amegashie

RL-64 October 12,2010



Ruby Morris Johnson RL-66 October 12,2010



Macdilla Howard RL-65 October 12,2010



Boakai Dukuly RL-61 October 12,2010

8 Chevrolet AVEO

(Automatic) 22,920.00

Executive Director,

Victoria T. York

RL-70 April 24, 2012

Sub-Total USD277,919.98

APPENDIX 2B: VEHICLES PURCHASED FROM AFRICA MOTOR

No. Vehicle Name Cost(US) Assignee PLATE No. Delivery

Note date

2 Hyundai bus

26,500.00

Utility N/A June

27,2012

Sub-Total USD 26,500.00



APPENDIX 3: QUANTITY OF FUEL IN USD VALUE UNACCOUNTED FOR

Date Payee AMT

9/6/2011 Total Liberia 3,850.00

5/4/2011 Total Liberia 5,505.25

10/4/2012 Total Liberia 2,436.50

11/7/2011 Total Liberia 3,675.00

6/6/2011 Total Liberia 4,005.00

5/10/2011 Total Liberia 2,992.50

12/12/2011 Total Liberia 3,675.00

8/5/2011 Total Liberia 3,916.00

7/11/2011 Total Liberia 3,916.00

10/5/2011 Total Liberia 3,850.00

4/14/2011 Total Liberia 2,920.00

6/7/2012 Total Liberia Inc. 8,212.25

12/15/2011 Total Liberia Inc. 3,675.00

5/8/2012 INCHR Total Liberia 5,505.25

12/17/2010 Total Liberia 3,157.00

11/19/2010 Total Liberia 4,282.00

11/1/2011 Mau-p Inc. 667.5

1/5/2012 Mau-p Inc. 3,785.00

20/12/11 Mau-p Inc. 920.00

9/6/2011 Mau-p Inc. 3,863.00

12/12/2011 Mau-p Inc. 4,475.00

6/04/25 Mau-p Inc. 1004.55

6/6/2011 Mau-p Inc. 4,094.00

6/2/2011 Mau-p Inc. 680.00

4/14/2011 Mau-p Inc. 2,768.00

4/23/2011 Mau-p Inc. 138.00

4/4/2011 Mau-p Inc. 270.00

12/22/2011 Mau-p. Inc. 699.75

12/17/2010 Mau-P. Inc. 3,050.00

12/14/2011 Man-P Inc. 4,475.00

11/1/2010 Mau-P Inc. 4,688.00

11/22/2010 Mau-P Inc. 1,000.00

6/6/2012 Super Petroleum 4,160.00

5/29/2012 INCHR Super Petroleum 714.00

5/4/2012 INCHR Super Petroleum 3,305.00

5/1/2012 INCHR Super Petroleum 461.00

4/30/2012 Super petroleum 461.00

12/3/2011 Super petroleum 2,650.00

9/30/2012 Super petroleum 230.00

10/3/2012 Super petroleum 2,670.00

Total USD116,801.55



APPENDIX 4: THIRD PARTY PAYMENTS MADE TO EMPLOYEES

Date Payee Description PV # Check

# AMT

June 21,2011

Momo S.

Nyandibo

Compensation for wage and

earners 171

N/a

600.00

Sept. 19,

Momo S.

Nyandibo

Compensation for wage and

earners 220

N/a

600.00

October

14,2011

Momo S.

Nyandibo

Payment to radio stations

for press release 444

N/a

200.00

October 28,

2011

Momo S.

Nyandibo

Payment to radio stations

for press release 492

N/a

120.00

Feb 23, 2012

Momo S.

Nyandibo Contractor Compensation 738

N/a

100.00

June 21, 2012

Momo S.

Nyandibo

Reimbursement fund used

to cover overdraft 827

N/a

1,200.00

June 13, 2012 Momo Nyandibo 2nd phase Palava Hut N/a 304764 24,140.00

7/23/2012 Arthur Smith Contractors’ compensation N/a 119 1,303.00

6/25/2012 Arthur Smith

Contractors compensation

for services rendered N/a 53619 375.00


Contractors compensation

for services rendered N/a 1115 1,004.00


Compensation for

contractors N/a 1071 981.00


compensation for wage

earners N/a 697298 430.00


Payment for contractors

compensation N/a 18945 345.00

01-25-1012 Arthur Smith Contractors compensation N/a 1096 988.00

8/28/2012 Arthur Smith Contractors compensation N/a 1126 1,275.00


Compensation for

Contractors N/a 0001085 995.00


Payment for contractor

compensation N/a 1110 971.00


Compensation for

Contractors N/a 18892 375.00

Total USD36,002.00

APPENDIX 5A: CBL’s USD TRANSFERS INTO THE INCHR’s PALAVA HUT ACCOUNT AT

ECOBANK

Date Payee Transaction Type Check

Number

Amount(USD)

13 September

2011

INCHR’s Palava Hut

Funds

Transfer to the Palava

Hut Funds to Separate

Account 0018573

205,000.00

7 May 2012 INCHR’s Palava Hut

Project


Hut Funds for the official

launch of the Hut 0018908

50,000.00



Date Payee Transaction Type Check

Number

Amount(USD)

Program

11 June 2012 INCHR’s Palava Hut

Project


Hut Account 0053575

71,892.4

TOTAL USD326,892.43

APPENDIX 5B: CBL’s LD TRANSFERS INTO THE INCHR’s PALAVA HUT ACCOUNT AT

ECOBANK

Date Payee Transaction Type Transfer Code Amount (LD)

8

December

2011


Project Transfer to Palava Hut

Account 1074

1,450,000.00

11 June

2012


Project

Transfer to Palava Hut

Account 1114

1,661,100.00

10 July

2012


Project Transfer to Palava Hut

Account 1117

1,000,000.00

TOTAL LD4,111,100.00

APPENDIX 6A: PROCUREMENT OF GOODS WITHOUT SUPPORTING DOCUMENTS

Bank Date Payee Amt.

12/30/2010 INCHR Cactus Motor 1,322.00

12/30/2010 INCHR Hadid 9,625.00

12/7/2010 INCHR Matter Trading 508.00

12/10/2010 INCHR Cactus Motor 80.00

12/14/2010 INCHR City Builder 1,500.00

12/15/2010 Liberty Trading 105.00

5/2/2012 INCHR Auto Spare part 165.00

5/2/2012 INCHR Computer Shop 570.00

5/21/2012 INCHR Payless superstore 600.00



5/31/2012 INCHR NSS&WC 4,463.61

5/31/2012 INCHR Technotech Inc. 16,500.00

12/7/2011 matter trading 290.00

12/7/2011 payless super store 152.45

12/7/2011 computer shop 125.00

12/21/2011 payless super store 143.35

12/21/2011 auto spare store 160.00

12/22/2011 Mau-p. Inc. 699.75

6/1/2012 Computer shop 675.00

6/4/2012 Cactus enterprise 350.00

6/4/2012 Office express 314.00

6/4/2012 Payless super store 286.48




6/4/2012 Cactus motor 275.00

6/4/2012 Technotech, Inc. 2,000.00

6/4/2012 Cactus Enterprise 350.00

6/7/2012 Shop & Save Hardware 275.00

6/14/2012 Crown Graphic Inc. 80.00

6/14/2012 computer Shop 1,530.00

6/20/2011 Computer Shop 1,530.00

6/26/2012 NSS&WC 6,543.00

6/27/2012 Office Express 185.00

6/28/2012 Cactus Motors 375.00

12/4/2012 Computer Shop 1,890.00

1/23/2012 Computer Shop 1,355.00

12/30/11 Computer Shop 1,560.00

15/12/11 Computer Shop 575,650

Total

USD632,552.64

APPENDIX 6B: PROCUREMENT OF SERVICES WITHOUT SUPPORTING DOCUMENTS


12/30/2011 Atlantic Life & General insurance Company 3,413.78

10/26/2011 Atlantic Life & General Insurance Company 6,827.00

12/14/2012 Atlantic Life & General Insurance Company 7,263.00

10/8/2012 Atlantic Life & General Company 254.8

6/16/2011 Cellcom Telecom 60.00

6/15/2011 Cellcom Telecom 49.00

8/10/2011 Pearl Brown- Bull 400.00

10/6/2011 Cllr. Pearl Brown-Bull 400.00




6/27/2012 Professional security service 600.00

6/18/2012 Cellcom Telecommunication 240.00



12/7/2010 INCHR Atlantic life 1,496.25

6/14/2012 C. Snetter 700.00

6/14/2012 Liberia Electricity Corporation 559.90

12/21/2013 Liberia Electricity Corporation 1,069.20

12/9/2011 Professional Security 600.00


5/28/2012 INCHR Auto Spare Services 165.00

5/8/2012 INCHR Cellcom Telecommunication 240.00

5/15/2012 INCHR Atlantic life & gen. 672.88

5/17/2012 INCHR L.E.C 1,034.72




5/22/2012 INCHR LWSC 456.95

5/22/2012 INCHR Professional Security 171.86

Total USD28,534.34



8 Exhibit

Exhibit 1A

Exhibit 1B

Exhibit 1C

Exhibit 2AExhibit 2BExhibit 2A

Exhibit 2B

Exhibit 2C

Exhibit 2D

Exhibit 2E

Exhibit 2F

Exhibit 2G

Exhibit 2H

Exhibit 2I

Exhibit 2J

Exhibit 2K

Exhibit 2L

Exhibit 2M

Exhibit 2N

Exhibit 2O

Exhibit 2P

Exhibit 2Q

Exhibit 2R