Auditing for probity in procurement 2 .pdf

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Nom original: Auditing for probity in procurement 2.pdf
Titre: UN RIAS presentation 30 Aug
Auteur: Ivan Foo

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Example 1
Ø Requirements
s Re-establishment of office in previously war torn
s Very limited suppliers working in difficult
s Small office, limited staff under pressure to get
the office ready for official opening by dignitaries
s Considered to be a straight forward procurement
Ø Admin assistant, previously who worked there
during the pre-war period, in charge of this
procurement action (and most of the administrative
functions), regarded as very competent

Procurement process
s Per procedures, she obtained 3 quotations as the value
was > $30k
s Since the value of procurement was < $100k, there was
no need for strategy or procurement plan
s She presented the 3 quotations to the Evaluation
committee chaired by Finance/Admin manager, who
recommended the supplier who met the requirements
with the lowest offer. Approved by the Head of Office
s Contract was awarded and office was satisfactorily
refurbished on time for the official opening
Everything seemed to be a success and in order,
or was it?

s The 3 quotations were provided by the one and
same supplier. He supplemented his quotation with
fabricated quotations from related and defunct
companies, one of which was his father’s
s Admin assistant under a lot of pressure to ‘get it
done’ and felt the need to maintain her reputation
as efficient and indispensable
s She told the supplier, her friend, she had to obtain 3
quotations per the rule and he offered to help her
s However there were hardly any suppliers working in
the area as it had been until recently a war torn

Ø Office had to be ready in time for the official opening
Ø Price and quality of the refurbishment was satisfactory
s In fact, Admin assistant:
s was not knowledgeable of the procurement P&P
s knew the conditions of the market but did not know
how to factor this in the procurement methodology
s Felt the need to maintain her reputation as a capable
woman especially in her society
s Felt she could not consult her managers for fear of
being considered incapable of conducting a ‘straight
forward procurement’

s Neither the Evaluation committee, the Finance
manager nor the Head of Office noticed anything
irregular. Each level depended on the previous level
to detect irregularities. Ultimately, they relied on
and trusted the Admin assistant
s Irregularity only came to light when staff
complained about seeing the supplier providing
goods and services for a contract that was given to a
different company
s Apparent compliance with the policies and
procedures did not rule out fraud in this instance
The question we have to ask is “Could audit
have picked it up?”

Example 2
s Organisation needed certain goods and services and
bundled its requirements in a way that is convenient
for the org in terms of contract management à only
1 supplier to manage
s Only 2 companies were prepared to bid to provide
the total bundle of goods and services
s Thought to be genuine competitors
s Significantly high value contract

s No analysis of supply chains to determine
s if there is a better way to approach the market
s to bundle or unbundle the requirements
s No effort to allow other suppliers (specialists in the
different elements of the supply chain?) to address
parts of the requirements à partial offers would not
be entertained
s Entity relied entirely on its procurement procedures
to secure value for money and ensure probity and
Entity had effectively created a self-imposed

s Suppliers that bid for the contract do so at a
premium to cover the risk of uncertainty in the
elements of the supply chain in which they are not
experts or that were carried risks
s Pricing offered would be inflated with risk premium
s What is not known is what the final price includes
because it is not transparent
The total amount paid could include
sforms of exploitative pricing
scorrupt transfers

Case Commonalities
s Fraud and corruption occurred in both complex and
straight forward procurement actions
s Conducted in accordance with the procurement
s No indication that organisation was dissatisfied
1) Contract considered great success
2) Satisfied until staff complained
3) No one has formally expressed any dissatisfaction
except occasionally lamenting the high cost

Case Commonalities
s No issues raised by internal or external audit
1) Alleged fraud detected in unrelated investigation
or triggered by staff complaint
2) No one sees there is a problem, continues as is
s No evidence gathered in planning stage that
s critically considered the way the need is expressed
s provided understanding of dynamics of supply mkts
s facilitated a suitable procurement strategy

s Procuring unit accepted the needs in the form they
were expressed without challenging them
s Procuring staff and end user (i.e. beneficiary) was
the one and same person
s Procuring staff did not have capability to undertake
research and analysis and tried to apply unsuitable
s Procuring unit does not see the need for such info

Black Box of Procurement

to guarantee integrity &


Black box of procedural
compliance – no transparency
of strategy and evidence from
which it is derived

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