Capital Transparency & Compliance Manager

Job Description

Job PurposeThe Transparency and Compliance Manager is a key member of the Management Team at country level. S/He is accountable for Acted audit management in-country under the authority of the Country T&CM.S/he is responsible for analysing risks, developing, and actively contributing to action plans to mitigate them.S/He provides technical support and capacity building to the Transparency & Compliance staff to implement the action plan and address their tasks.S/he provides technical support and works to build the capacity of the FLATS teams to identify difficulties, propose action plans and follow them up.S/He also leads on technical support for donor external audits and due diligences preparation and follow-up.S/He should comply and ensure compliance to the audit code of conduct.ObjectivesUnder the supervision of his/her direct supervisor, the Transparency and Compliance Manager must independently:1) Manage the FLATS compliance process and internal audit by :a) Using a risk-based audit approach, organizing and implementing controls on the implementation of Acted procedures in each bases in accordance with :- Acted manuals of procedures,- Donors? specific procedures,- Best practices- National legislationb) Developing and participating in action plans approved by T&CM and HQ;c) Consolidate monthly compliance tasks in accordance with the monthly compliance review plan and highlight the hot issues;d) Proactively document recommandations and lessons learnt in AUD-05 to improve current process implementation and cover identified risks.2) Coordinate the preparation, on-site visit (including travel) and follow-up of external audits of donors/third parties and due diligences;3) Training, lessons learned and best practices: provide training sessions to reinforce the level of compliance of the teams (and partners involved if required), raise alerts and propose improvements to Acteds current procedures, based on lessons learned and best practices.4) Facilitate internal coordination and communication in the T&C team : traveling and supervising the assigned T&C team to assist them in carrying out their tasks.Upon request, manage fraud cases Duties and Responsibilities1. Management of the FLATS and program compliance process The Transparency and Compliance Manager must know ACTEDs policies and procedures and must ensure that they are properly implemented on the mission. S/he must independently: Ensure planning and coordinating of the compliance tasks: monthly compliance reviews and relevant ad-hoc spotchecks of FLATS and program departments, including field visits; Ensure significant and relevant samples were chosen (including partners expenses) as a basis for monthly compliance reviews; Validate the recommandations based on lessons learned arising from the compliance reviews and ad-hoc spotchecks in order to share it with HQ; (AUD-05) Consolidate the monthly monitoring of the action plan for implementing the AUD-05 recommendations in collaboration with the relevant departments; Provide technical support and propose mitigation measures to address any difficulties encountered by each department in implementing Acted procedures and propose mitigation measures; Report risky compliance alerts or suspected fraud to the T&CM; Validate and coordinate the partner due diligences, vetting and monitoring of the implementation of risk reduction plans;

• Analyze and consolidate the information shared for the monthly compliance report and the related annexes (FLA-04, FLA-02, FLA-05, FLA-06, AUD-05 and lessons learnt);
• Consolidate the compliance report and ensure information in the related annexes are up to date (MCR) before sharing them with HQ;
• Ensure update of the shared T&C folder to ensure all the task performed and relevant information/documents shared are documented and archived.
• Consolidate information shared and planned upcoming internal, external audits, spotcheck and due diligences in the global audit plan. (AUD06)

S/he must also support the T&C team: Support the Compliance Team in identifying the compliance issues by filling the compliance checklists (FLA 02); Quotes & Invoices Investigation (FLA-05), FLA-06 Staff files checklist on a monthly basis Ensure the implementation of compliance tasks associated with expenditure as well as lessons learnt development (including supply chain traceability, market survey, review of FLATS and program documentation, etc.) ; Conduct the relevant ad-hoc spotchecks for the hub FLATS and program departments.2. Preparing, carrying out and monitoring external auditsThe Transparency and Compliance Manager must be familiar with the external audit procedures for each of the projects implemented and ensure that they are properly prepared, implemented and monitored. S/he must independently: Coordinate FLA03 update : Analyze Grant contracts with donors and donor guidelines in order to anticipate audit terms and conditions; Anticipate order form and provide technical support to Logistics Department to select external audit companies, review Terms of References and Service Agreements Ensure the preparation of external audits in close collaboration with the HQ Audit Department, the T&CM, the logistics, HR, finance teams and the partners; Coordinate communication with all HoD and coordination the external audit deadlines, sample and corrective action follow up; Validate answers to the internal control questionnaire and attach the appropriate documentation for HQ validation; Ensure the compliance and completeness of the ready for submission of supporting documents requested by the external auditors; Coordinate communication with auditors, organization and participate in kick off meeting and close out meeting of each external audit; Review (if required) the external audit follow-up files (AUD-01) and coordinate the preparation and dissemination of lessons learned and good practice; Analyze the identified risk during the preparation and external audit to anticipate mitigation actions and responses to be provided. Communicate those risk to T&CM, CD, CFM and HQ. Coordinate lessons learned and recommendations drafting to be incorporated into the management of the FLATS and program compliance process and followed on AUD-05 after T&CM validation ; Coordinate the audit report reception and review the responses to these reports; Coordinate the communication and follow-up of external audit recommendations implementation with the departments concerned (AUD02) Ensure update of the information of the relevant annexes of the MCR (FLA06, FLA03, AUD02, AUD05)S/he must also support the T&C team : Facilitate each external audit, by collecting, consolidating, and reviewing the selected supporting documents, identifying and rectifying any anomalies and sending the Compliance checklists (FLA-02) to his/her direct supervisor.3. Preparing, carrying out and monitoring internal auditsThe Transparency and Compliance Manager is responsible for assessing and strengthening the level of compliance of the various departments in each of the bases of the mission by implementing the internal audit plan once shared and validated by the T&CM. S/he must work independently on:

• Being involved in process mapping and risk assessment;
• Based on audit work, fraud risk, upcoming external audit, context of the mission and HoD feedback, consolidating the main compliance risks and issues inherent on the mission in order to propose the relevant reviews to be included in the internal audit plan (AUD-06);

Validate the Terms of Reference (AUD-03), prepared checklist (AUD-08) and testings tools and send them to HQ for validation prior to any internal audit; Validate the work (AUD08 and testing files), the action plan (AUD-04B) and the audit report (AUD-04A) for validation by HQ before sharing it with the departments concerned; Based on AUD-05, consolidate and analyze risks associated to each area, base, process, departments to report risks, propose relevant action plan, and share progress to coordination and HoD every 3 months

• Actively participate and coordinate with HoD so implementation of the AUD-05 recommendations are implemented;
• Ensure the recommandation implementation follow up on the internal audit and investigation recommendation making sure the tracking file is regularly updated (AUD-05);
• Coordinate the presentation of the internal audit results and recommandations to HoD and coordination

S/he must also be able to : Carry out internal audit in accordance with the audit plan (AUD-06), the validated Term of references (AUD-03) and the ACTED internal audit methodology;

• Based on implementation feedback from department, carry out appropriate testings to evaluate recommandation implementation;

4. Training sessions / lessons learn / best practicesThe Transparency and Compliance Officer will help to improve compliance competences by proposing training sessions on specific process in the procedures, based on internal and external audits compliance review conclusions. S/he will : Provide practical training on specific aspects of ACTED procedures; Provide technical support to the FLATS and program department to mitigate the risk identified; To contribute to the proactive dissemination and use of lessons learned and recommandations during audit activities (internal and external audits) and investigation among national and international staff;

• Process improvement : In collaboration with the departement involved, reinforce current procedures and the quality of ACTED internal control, based on international best practices, donors? requirements, and results of internal & external audits.
• Upon request, provide technical support to the drafting of specific policies.
• Draft the lessons learnt, recommandations, specific donor?s rules, donor?s requirements, and others relevant information to share them during project kick of meetings, PBM, close out meetings and SMT meeting.

Also, contribute to train the partners to the T&C tasks and bring the technical support.5. Internal Coordination

• Supervise and be accountable of the T&C team?s tasks by monitoring action plans and day-to-day activities;

Review the work of the T&C team and provide full written feedback on their work;

• Ensure training and capacity building for the Compliance team members to increase the technical ability and skills within the department.
• Update the organization chart and ToRs of the Compliance team according to the mission development;
• Plan & conduct Audit and Compliance recruitments & appraisals; train & build capacities of the Compliance staff in country; identify staff with potential, and contribute to internal mobility strategy;
• Actively participate in country level coordination meetings by reporting on progress, and risks.

6. Transparency

• Participate in minimizing risk of fraud and corruption by ensuring adherence to Acted FLATS procedures, Acted Code of Conduct and ACTED Policies;
• Upon request of the T&C manager, participate in Fraud cases investigations;
• Upon request of the T&C manager, participate in updating the cases follow up;
• Actively promote Acted?s anti-fraud and whistle blowing policy within all Acted offices of the mission.

7. Other

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

Key Performance Indicators- of good quality (based on number of feedback) deliverables (internal audit ToRs and reports, MCR, internal control questionnaire, external audit reports, due diligence, RMP?) submitted- % of risks identified during external audits already flagged during monthly review- # of risk flagged and # cleared during external audit visit- % of timely and well completed submission of the hub?s monthly compliance reports.- % of ongoing project with external audit risk covered by an accurate sample for the monthly review- % of implementation of external, internal audit and investigation recommendations or reported as difficult to implement with mitigation measure- Frequency of sharing and follow-up of recommendations with relevant departments- Regularity of analyses on risks and recommandation shared with CD and HoD- # of monthly contributions to the planning of the country audit plan.- # of targeted program spot checks proposed and conducted on a bi-annual basis.- # of targeted FLATS spot checks proposed and conducted on a bi-annual basis.- Frequency of updating tracking tools (MCR annexes)- # and quality of trainings provided to the T&C team s/he is responsible for.- Regularity and quality of feedback to the T&C team for whom s/he is responsible- Quality and relevance of the lessons learned validated based on the work carried out/reviewed and anomalies identified- # of testing tools developed for specific ad-hoc spot checks- # of meeting conducted with the partners for RMP follow up- Quality of planning for the next 6 months*Acteds proposed monthly salary: 1976 JODs

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