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CRM action plan and implementation status as of April 2012
S
N
Risk
Current measures
Detailed plan/activity
Charge
Status
Details of
implementation
Time line 2011‐2012
S O N D J F M A M J J A
1. Risk of preferential treatment to cases/complai nts by the Commission.The Complaints Evaluation Committee (CEC) consisting of Chief Investigation Officer, Follow‐up section officers and the director (chairman) screens and recommends action against all complaints for further review and decision by the Commission (CM).
In the event of major discrepancy in the views of the latter, Commission clarifies the variation to the CEC.
Strengthen the existing internal control measures within the complaints management framework by developing clear Rules of Procedures for both CEC and CM – to ensure transparent system of dealing with complaints.
Review and strengthen the pursueability test of complaints/cases along with the inclusion of provision for prioritization of cases. CEC & Commission CEC Done Done
Rules of Procedure developed for ensuring transparent system of dealing with complaints. Reviewed and strengthened the pursuability provision while evaluating complaints.
While there is a system of ensuring transparency between the CEC and the CM on differing views and decision on complaints, there is no oversight body of formal mechanism to
ensure that the
Commission is not biased.
Document the role of CEC as a check and balance with respect to risks of preferential treatment of cases and complaints by the Commission members in the ACC annual report for public information. Commission Not Done
Since the internal complaints
management system
has been
strengthened,
documenting the same in the annual report did not seem to be relevant.
Check and balance is not only for the
Commission alone but also for the CEC. 2. Risk of misusing office resources by the employees of the Commission. ACC Code of Ethics. Ethics Committee to explore the possibility of undertaking proactive studies in vulnerable areas of functioning (vehicles, funds, office equipments etc).
Also develop clear Rules of Procedure for Ethics Committee – outlining the frequency of meetings to be conducted including their functions and mandates. Ethics Committee Done
Rules of Procedure outlining the
frequency of
meetings, functions and mandates for Ethics Committee have been developed.
Integrate a system of annual internal auditing in the management system.
The Commission should constitute and command for internal auditing for at least once in a financial year at appropriate time. AFD Commission Not Done
Internal auditing as a
part of the
management system not in place yet. 2011 internal auditing was not necessary as RAA audited both LC and PLC accounts of the Commission.
Develop Terms of Reference (ToR) for Internal Auditors with some accountability mechanism. AFD Not Done General user guide for auditing is followed while auditing.
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Strictly implement the existing system of managing and maintaining the inventory/supply of stocks including office stationeries.
OR
Develop an inventory system to check on the receipt and issues of stock including office equipments. AFD IT Done Implementing the existing system of filling requisition forms and maintaining records in stock register. 3. Risk of abusing authority by Investigation Officers during Investigation. Operations Manual provides a general guideline for investigators.
The manual may have to be enriched with provision of detailed do’s and don’ts to prevent the risk of abuse of authority.
In addition to the operational manual, develop standard do’s and don’ts for IOs and standardize those procedures/standards.
Also include a provision on debt checking in the dos and don’ts of the IOs – to do away with the risk of IOs getting bribed during the course of investigations. ID Ongoing
Draft standard do’s and don’ts for IOs are in place and is yet to be finalized.
Institute a system of reminding the investigators on the core values and competencies periodically. ID Done
Done as and when required.
Strictly implement the system of assigning a team
ID Done
Every case is assigned
Currently, in order to avoid this particular risk, an investigation team consists of minimum two members.
of not less than 2 officials for every case.
Also educate the general public on the appropriate procedure for reporting such incidences including the functions and roles of Ethics Committee during such situations. PED Done to a team of minimum 2 officials.
Done as and when there is a public education program. 4. Risk of trading privileged information by employees of the Commission both while in and out of ACC.
Institute a mandatory system of signing confidentiality agreement by all officials leaving the ACC. AFD & HRD Done
A form has been designed, which is signed by anyone leaving the ACC.
Enhance information (both hard and soft) management system. Study and see how information can be shared on a need‐to know basis. AFD with ID Ongoing Office Procedure Automation (OPA) instituted.
IT officer is in the process of developing Document Management System (DMS) for enhancing information (soft copy) management.
Study and see how to bring the issue of post employment of ACC
LD Done Although the provision was included in the Anti‐ Corruption Bill, it was
Page 5 of 14 employees within the
purview of legal jurisdiction.
Incorporate in the amended AC Act.
rejected by the Parliament (while enacting the Anti‐ Corruption Act 2011).
Currently, LD is in the process of proposing the provision for post employment
restriction through Public Service Model Code of Conduct. 5. Risk of investigators being bribed during the course of Investigation including all kind of gratifications. Ensure strict
implementation of the system of assigning a team of not less than 2 investigators for all cases. ID Done
Every case is assigned to a team of minimum 2 officials.
Establish a system of counseling the investigators on a quarterly basis. Core values and competencies can be reminded to all investigators periodically. ID Done
Done as and when required.
Institute a system of periodic checking on the indebtedness of the
investigators –
crosschecking and validating the investigators’ financial status while approving loan requests. Secretariat Done Validating and crosschecking of financial status of IOs are done as and when there are loan requests.
Institute a system of maintaining and updating personal information including the loans and liabilities of all employees annually – obtain information from individual employees, AD and other relevant sources. HRM Done
Basic information of all employees is regularly updated in the Civil Service Information System (CSIS). However, it is not feasible to maintain personal information on loans and liabilities.
It will be developed as a part of integrity vetting system. 6. Risk of recruiting wrong people
ACC follows standard recruitment and selection procedure within the broad framework of BCSR 2010.
Continue following the standard recruitment and selection procedure within the framework of BCSR.
Also discuss the matter/issue with the RCSC. HRM Done
All recruitments done as per the general framework of BCSR 2010.
The issue of recruitment was discussed with the RCSC. In view of the nature of the organization, it needs to build a more robust system of recruitment and selection, particularly, integrity vetting.
Develop a standard recruitment system for all divisions with specific
questions and
institutionalize the system.
Include reference system and background vetting through letter of reference. Also explore outsourcing the HRM Done
A standard criterion for recruitment has been developed within the broad framework of BCSR and is strictly implemented.
Cross referencing and background vetting
Page 7 of 14 recruitment function on as
and ‐ when necessary basis.
(only partial) of applicants are done as and when required.
Implement and manage system of declaring Conflict of Interest. HRM Done
Conflict of Interest declaration system implemented in all decision making processes including investigation of cases. 7. Risk of complaints manipulation by the Complaints Evaluation Committee (CEC). Majority of the current CEC members are investigation officers. Reconstitute the
membership of CEC by including 2 chiefs of the PD and PED (issue office order). AFD Done
Chief of PD and PED included as members of CEC.
Enrich conflict of interest system through the maintenance of family data and enforce it strictly. (Study and enrich the system of operating Conflict of Interest.) HRM Done Direct family members details are maintained in the online CSIS system.
Conflict of Interest declaration system enforced whenever necessary.
Develop and ensure strict implementation of the Rules of Procedure for CEC and its functions and mandates. CEC Done
CEC conducted as per the Rules of Procedure developed.
Include a provision in ACC
Review of ACC Ethical Code of Conduct (CoC) had to be based on the model Public Service Code of
8. Risk of employees using ACC’s name (scare tactics) to gain preferential treatment.
Ethical Code of Conduct during the review of the ACC Ethical Code of Conduct.
Strictly implement the Ethical Code of Conduct. PD Not Done Conduct (developed by LD). PD and relevant officials (who have attended the related course) will review the Ethical Code of Conduct based on the model Public Service Code of Conduct within 2012.
Ethics Committee to also proactively monitor the employees in special areas of vulnerability and functioning – employees using ACC’s name to gain preferential treatment
Values of self respect and consciousness to be reminded periodically to all employees. Ethics Committee Ongoing Ethics Committee monitors the
employees as and when necessary. However, needs to be more effective.
Design and develop employee identity cards with adequate security features – integrated security features (identity details) for entering the ACC office premises. ADM and Project Manager Not done Automated entry access control system through biometrics and security featured employee identity cards to be instituted upon completion of ACC office building.
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Educate and advocate the general public on the need to insist on production of such identity cards by any ACC official. PED Done
General public are educated as and when there is a public education program. 9.
Risk of siding a particular political party while undertaking anticorruption education program and risk of Commissioner s being politicized. Currently, objectives/education materials are discussed and
endorsed by the
Commission prior to
undertaking any
educational and awareness programs.
Add a provision and emphasize the need to be apolitical for all ACC employees while reviewing the ACC Ethical Code of Conduct. PD Not Done
Review of ACC Ethical Code of Conduct (CoC) had to be based on the model Public Service Code of Conduct.
PD and relevant officials (who have attended the related course) will review the Ethical Code of Conduct based on the model Public Service Code of Conduct within 2012.
Formulate clear rules of engagement for the Commission. AFD Done Commissioners’ Disciplinary Enquiry rules formulated.
Enforce existing system of seeking clearance for any anti‐corruption education programs. Draft proper protocol on the preparation
PED Done Implementing the existing system of seeking approval from the Commission for undertaking anti‐
and clearance of education and advocacy materials. corruption education programs. 10 . Risk of collusion and embezzlemen t in the procurement function.
Procurement Rules is strictly followed. However,
the procurement
committee does not involve in ascertaining goods during subsequent deliveries.
Appoint or engage different officers on random basis to check on the goods vis‐à‐vis the sample during the delivery process. Director and AFD Done
Done as and when required.
All employees to report any suspected or spurious supply of goods during its use in offices. All employees Done
All employees report as and when they notice or detect the use of spurious goods to AFD.
Integrate internal audit in the management system.
The Commission should constitute and command for internal auditing for at least once in a financial year at appropriate time. AFD Commission Not Done
Yet to be instituted. Internal auditing for 2011 not done because of RAA’s auditing of both LC and PLC accounts.
Include in ACC Ethical Code that officials cannot borrow money other than from legitimate financial institutions. Also include a provision on having to declare debt other than from legitimate financial institutions if any to enable authorities to check on the
PD Not Done
Review of ACC Ethical Code of Conduct (CoC) had to be based on the model Public Service Code of Conduct (developed by LD).
PD and relevant officials (who have attended the related
Page 11 of 14 vulnerabilities of
procurement/finance officers, during the review of ACC Ethical Code of Conduct.
course) will review the Ethical Code of Conduct based on the model Public Service Code of Conduct within 2012. 11 . Risk of Commission/C hairperson being unfair to a particular employee for vindictive reasons.
Generally, employees are responsible for and accountable to their respective division heads. Thus, their performance evaluation, based on pre‐ determined work target, is also rated by the heads. Commission’s direct
supervision and
performance assessment is limited to division heads. It, however, gets to
understand other
employees through its direct interactions with them.
Explore possibilities of redressing such issues through the Ethics Committee, which is also the HR Committee to give the victim a fair chance to prove that he/she is actually a victim of reprisal from the Commission. AFD Done
No such cases as of now. HR committee would intervene if such cases occur.
Unsolved cases/issues by the Ethics committee/HR Committee should be further directed to the Administrative Tribunal which is to be established under the RCSC. Ethics Committee Done All cases are first dealt by the HR Committee/Ethics Committee and those unsolved cases are automatically
forwarded to the RCSC. 12 . Risk of leaking/manip ulating asset and liability information by the Asset
ACC Code of Ethics governs the conduct of the Asset Administrator.
Develop clear Guidelines and TOR for Asset Administrators which should include the provision for maintaining confidentiality as well. Asset Administrato r, PD Done
TOR for Asset Administrators and Guidelines developed. Will have to keep improving – dynamic process
Strictly implement the existing system of AD
Asset Done
Asset Declaration log and audit trail system
Administrator. submission, receipt and sharing of any AD related information to the declarants – concerned chief to monitor periodically (check and balance) Administrato r, PD instituted.
Head of the division regularly monitors the activities of the Asset Administrator. 13 . Risk of misleading the management during systems study and while providing recommendat ions.
Prevention Division seeks guidance or approval of the commission on any system studies. However, there is no standard procedure for undertaking system studies including selection of fields/area.
Finalize the system study protocol for undertaking system study. PD Done System Study Protocol developed.
Strictly implement the system study protocol while conducting any system related studies in agencies/departments/divisi ons and services – Commission to ensure the same PD & Commission Done
All system studies are conducted based on the System Study Protocol. 14 . Risk of misinforming the media by ACC staff.
There is a designated spokesperson
(commissioner) for media. All employees are aware of the system. ACC officers share information with
media only when
commission authorizes to do so.
Develop clear rules of
engagement on
disseminating information to media (Media and Communication Strategy) and restrict all from engaging in providing information outside the framework of the rules of engagement. PED Not Done Currently a
commissioner is the designate
spokesperson of ACC. Proposed for technical assistance (ADB consultants) in developing Media and Communication Strategy and should be completed by December 2012.
Page 13 of 14 15 . Risk of complaints being dropped/destr oyed either at dispatch section or at the level where the complaint is addressed.
All written complaints are jointly opened by receptionist and Director for entry in the complaint register.
All walk‐in complaints are received by Follow‐Up section; and
All electronic complaints are received by director, chief investigation officer and follow‐up section. Compilation of such complaints is based on the emails received by follow‐ up section.
Complaints through fax are received by PA to the commission since there is only one fax machine.
Draw up a proper system of receiving and managing complaints and clearly lay down the roles and responsibilities of the complaint registration officer including the detailed process of handling complaints. ID Done Investigation Management System (IMS) developed.
Although there exists ToR for complaint registration, roles and responsibilities of complaint Registration Officer have to be developed. Further improvement
expected through the revision of the operational manual.
Also educate the general public on the process of complaints handling and management. PED Done
General public are educated on the complaints management system as and when there is a public education program. Devise comprehensive security measures to protect electronic complaint emails
from being dropped/destroyed. IT Officer Done Security measures like log system and audit trails put in place in the ACC web domain.
Acquire dedicated fax and photo copier machines for classified documents. AFD Done A separate photocopier machine has been purchased
for use of
photocopying
classified documents‐
to prevent leakage of information. 16 .
Risk of fuel and spare parts pilferage by drivers.
An officer accompanies respective drivers to fuel vehicles.
All maintenance and replacement of spare parts are done on work‐order basis.
Vehicle log book is also strictly maintained by AFD. Strict implementation of the code of ethics. AFD Done
All employees are reminded on the need to implement the Ethical Code of Conduct.
Standardize a system on vehicle mileage and cost of maintenance of vehicles based on all factors, viz. mileage, types of vehicles, etc.
Ensure drivers to be responsible for mileage and minor maintenance of the vehicles. AFD Done
System of calculating vehicle mileage based on average mileage, type of vehicle, weather conditions etc. has been standardized and implemented.
Compact signed with the drivers – accountability fixed (fuel and minor spare parts maintenance)
The concerned division to monitor and manage all major replacements and maintenance including repair of vehicle equipments/spare parts. AFD Done Administration section monitors and manages major replacement and repair of vehicle equipments/spare parts. Note: Next review will be conducted in October 2012.