90. 89

91. 90

1. 0 REVIEW OF THE PRACTICES AND PROCEDURES OF THE NATIONAL TELECOMMUNICATION (NATCOM) SIERRA LEONE

4. 3 8.0 BUDGET AND BUDGETARY MANAGEMENT.....................................................4 0 8.1 Budget Participation..................................................................................... .40 8.2 Budget Committee........................................................................................41 8.3 Budget Variance...........................................................................................42 8.4 Variance in Budgeted line Activities/ Expenditures......... ......................................45 9.0 HUMAN RESOURCES MANAGEMENT..............................................................48 9.1 Human Resources and Administration................................................... ............48 9.2 Job Description.............................................................................................49 9.3 Records Management.....................................................................................50 9.3 Staff List.......................................................................................................51 9.4 Staff Attendance Register........................................................................... ......52 9.5 Performance Appraisal.................................................................................... 53 9.7 Staff Personal Files /Records.................................................................. ..........54 9.9 Staff Qualification.......................................................................................... ..55 9.10 Canteen Services.......................................................................................... 56 10.0 FLEET AND FUEL MANAGEMENT....................................................................5 7 10.1 Fleet...........................................................................................................57 10.2 Fuel Management..........................................................................................5 8 11.0 PROCUREMENT MANAGEMENT......................................................................59 11.1 Procurement Plan..........................................................................................59 11.2 Procurement Committee................................................................................. .60 11.3 Procurement Unit...........................................................................................6 2 11.4 Staff Capacity................................................................................................63 11.5 Records Management (Filing System)................................................ .................64 11.6 Debriefing to | Unsuccessful Bidder................................................ .....................65 11.8 List of Supplier/ Vendors........................................................................... ........66 11.9 Sale of Bidding Documents........................................................................... ....67 11.10 Payables to supplies.................................................................................... ..67 11.10.1 Goods....................................................................................................68 11.10.2 Works....................................................................................................70 11.10.3 Services.................................................................................................70 11.10.4 Air Ticket/Travel Agencies............................................................ ..............71 12.0 STORES MANAGEMENT..................................................................................74 12.1 Store Environment..........................................................................................7 4 12.2 Staffing.........................................................................................................75 12.3 Qualification of Storekeeper............................................................... ...............76 12.4 Monitoring and Supervision..................................................................... ..........76 12.5 Store Bin Card................................................................................................7 8 13.0 UNIVERSAL ACCESS DEVELOPMENT FUND (UADF)................................. ..........79 14.0 PROJECT MANAGEMNT...................................................................................82

5. 4 15.0 REGIONAL OFFICES.......................................................................................84 15.1 Staff Composition and Functionalities....................................... ..........................84 15.2 Budgetary Support to the Regions......................................................... ............86 15.3 Monitoring, Surveillance and Outreach Activities....... ............................................86 15.4 Regional Office Fuel and Petty Cash................................................... ...............87

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3. 2 TABLE OF CONTENTS List of Acronyms..................................................................................................5 Executive Summary.............................................................................................6 INTERNAL AUDIT AND RISK MANAGEMENT..........................................................6 BUDGET AND BUDGETARY MANAGEMENT..........................................................8 1.0 INTRODUCTION...........................................................................................14 2.0 OBJECTIVES...............................................................................................14 3.0 SCOPE AND METHODOLOGY........................................................................15 FINDINGS AND RECOMMENDATIONS.................................................................15 4.0 INTERNAL AUDIT AND RISK MANAGEMENT...................................................1 5 4.1 Audit Manual.............................................................................................15 4.2 Audit Committee.........................................................................................17 4.3 Annual Audit Plan.......................................................................................17 4.4 Internal Audit Queries................................................................................ ..18 4.5 External Audit............................................................................................19 4.6 Staffing.....................................................................................................20 4.7 Reporting Line of the Internal Auditor............................................. .................21 5.0 CORPORATE GOVERNANCE........................................................................22 5.1 Handing Over Notes/Status Report......................................................... ........22 5.2 Due Deligence on Natcom by the Current Management.................. ....................22 5.3 Strategic Plan.............................................................................................23 5.4 Board of Directors.......................................................................................2 4 5.5 Organizational Structure........................................................................... ....24 5.6 Board Structure..........................................................................................25 5.7 Board Remuneration/Expenses.................................................................. ...26 5.8 Development of Regulatory tool............................................................... ......26 5.9 Legal Department.......................................................................................27 5.10 Policy and Governance..............................................................................29 5.10.1 Annual Work Plan.................................................................................30 5.10.2 Annual Activities Report..................................................................... ....30 5.10.3 Policy /Regulation Development................................................. ..............31 6.0 FINANCIAL MANAGEMENT...........................................................................31 6.1 Financial Policy and Procedural Manual.......................................... .................31 6.2 Area of Focus: Petty Cash............................................................................. 32 6.3 Area of Focus: Revenue Generation......................................................... .......33 6.4 Cheque Withdrawals....................................................................................35 6.5 Withholding Tax Payment (WHT), NASSIT Contribution &PA YE ........................37 6.6 Fixed Assets Register................................................................................... 38 7.0 DEBT MANAGEMENT....................................................................................39

92. 91 Vision: A corrupt free Sierra Leone which will ensure that the Socio- economic needs of its citizens are met. Mission: Leading the fight against corruption through Public Educat ion, Prevention, Enforcement and compliance for the benefit of all citizens. Core Values: Ø Integrity Ø Professionalism Ø Coalition building and partnership

14. 13 The Review Team observed that the loan repayment agreement was prepared by UADF instead of NATCOM. The Review Team could not identify any member NATCOM being part of the agreement as signatory. The amount stated as monthly repayment was too small because it would take UAFD over five years before the loan was fully repaid, even if they had honored their agreement. No evidence was provided to show approval from the Board for the granting of the loan and the writing off of the loan as bad debt. • The Management of NATCOM should stop treating the item as expense but rather a long-term loan as there was an agreement of repayment. • There should be a comprehensive loan policy • The Internal Audit Department should conduct a full- blown investigation on the entire loan process.

16. 15 3.0 SCOPE AND METHODOLOGY The review period was between the periods 2018-2020 (inclus ive), a three-year period. All areas of operations were examined. The review process commenced with an inception meeting with management of NATCOM. At the inception meeting commitment was made by the manageme nt to collaborate with the Review Team and the workplan and activity schedule was ad opted. In conducting the review, desk-based reviews of relevant do cuments were conducted and research on similar reviews in Telecommunication. Accordingly, the team conducted interviews with key staff o f the organization and its related agencies in line with the review objectives. The Review Team observed existing practices and procedures in order to determine their weaknesses and strength. Field visits were conducted which involved physically obse rving service delivery; and Additionally, the team researched other studies done on sim ilar institutions to inform the conclusions. The input of end-users was also invariably con sidered, and critical to the outcome of this review. FINDINGS AND RECOMMENDATIONS 4.0 INTERNAL AUDIT AND RISK MANAGEMENT According to the Institute of Internal Auditor (IIA), " Internal auditing is an independent, objective assurance and consulting activity designed to ad d value and improve an organization’s operations. It helps an organization accom plish its objectives by bringing a systematic, disciplined approach to evaluate and improve t he effectiveness of risk management, control, and governance processes. " In assessing the internal audit function, the following are a of focus was examined. 4.1 Audit Manual An audit manual outlines the authority and scope of the inter nal audit function, documents standards, and provides cohesive guidelines and procedure s. These guidelines promote consistency, stability, continuity, acceptable performa nce standards, and a means of coordinating the efforts of audit staff effectively.

19. 18 Findings Audit plans were provided for the periods under review. Howe ver, the material content of the plans was focused on repetitive transactions (transact ional auditing) rather than comprehensive and/or holistic audit of the Commission. For instance, the plans do not entail auditing of Financial Management, Procurement, Sto res, Assets, Fuel and Fleet, Personnel/HR, etc. Implications This implied that activities were not implemented as planne d for the periods under review and as such it provided a fertile ground for other department s of the Commission to execute their activities and mandate without checks and bal ances. Recommendations The Audit Plan should include the auditing of all department s and operational areas of the Commission. Subsequently the audit plans should be present ed to the Audit Committee for approval. The Director of Internal Audit and Risk Management should ca refully ensure that all activities are implemented as planned to improve efficienc y and effectiveness in carrying out their duties. Management Response Recommendation noted. 4.4 Internal Audit Queries An Audit Query is an explanation that is required by the Audit team on certain points that they may have identified during an audit. These may be used to gather information to come to a conclusion in the audit. All audit clients are required to provide a written response to audit findings. The response represents Management's plan for correcting or im proving the findings. All responses are included in the final audit report that is dist ributed to Senior Management, the Board, and the External Auditors. Section 151 (1) of the PFM-regulation 2018 states that “ An auditee shall respond within ten working days after an Internal Auditor has issued a draft audit report in writing.”

77. 76 12.3 Qualification of Storekeeper Storekeeping is a delicate job that required trained and qua lified personnel to undertake such tasks. However, the Team observed that the Storekeeper had no knowledge or the pre-requisite qualification for discharging his duties. Implication Lack of a trained and qualified storekeeper would hinder eff icient and effective service delivery in storekeeping. Recommendation Management should ensure that the storekeeper be provided w ith the required training in the discharge of his functions for effective and efficient s ervice delivery. Management Response Management has already identified a training and developme nt plan for the Storekeeper to enhance his skills and competence to perform his duties effe ctive. Additionally, a succession planning for the said position has been establis hed in an event when the staff is ill, on leave or retired etc. 12.4 Monitoring and Supervision Findings The Review Team observed that there was less and/or no superv ision on the activities of the storekeeper. At the time of the review, documents relati ng to the review scope were not provided, so the Team took samples of store documents for 202 1. The following irregularities were captured from samples of store voucher s inspected as follows: • Items supplied that were never approved by both the requesti ng department and the issuing department as shown below: .

79. 78 The above tables show poor monitoring and irregularities in store requisition and issuing procedures. It was evident that the storekeeper had been iss uing out goods from the store without approval from his supervisor in one instance or appr oval by the head of department in another. Moreover, there were series of contr aventions from modern day’s stores management on the sides of the Commission as items req uested were dealt in directly with the storekeeper who then made the issue withou t following the due procedures. The Team also observed that all requisition vouchers inspec ted bore the same serial number of 01349 , which implied that the requisition and issue vouchers were not sequentially numbered and /or the same voucher was used to re quest for multitude of heterogeneous items from the store. Furthermore, there was no policy on store management proced ures Implication Lack of proper monitoring and supervision in stores managem ent can lead to poor performance and would create opportunities for pilferage o r wrong handling of items. Additionally, using different requisition vouchers beari ng the same serial numbers of 01349 for multiple requests was tantamount to misappropriation, and waste of the Commission’s resource Recommendation The Management of NATCOM should ensure that the storekeeper follows the due processes on store requisition and issues. Moreover, the Commission should develop a policy on stores m anagement and ensure it strict adherence. Also, Management should investigate the consistency in the serial number to prevent fraud. Management Response Recommendation noted for appropriate action 12.5 Store Bin Card The Team observed that the storekeeper never maintained and / or worked with a store Bin Card. Even though there was a store requisition and issui ng voucher, yet stocks were inaccurately recorded and distributed. This tool enabled the storekeeper to be accountable and main tain records on every item in store for ease of reference.

30. 29 • The Commission as such, cannot give independent advice unli ke Retainers, who can devoid of political interference and are bound by such ad vice. NATCON cannot take its in-house lawyers to court in the event of giving misg uided opinion, but can do so in the case of Retainers. Only Le75,000,000.00 (Sevent y-Five Million Leones) was paid to Retained lawyers last year. It is a known fact that lawyers can charge up to Le200,000,000.00 (Two Hundred Million Leones) for adv ice and/or for giving an opinion in a given case, unlike what Retainers are paid yea rly. • There are currently four (4) pending matters in the High Cour t for the Commission and our Retained lawyers have been actively attending on eac h hearing. Thus, if put on a case-by-case basis, the litigation cost will amount to or exceeds Le200,000,000.00 (Two Hundred Million Leones) per case, si nce these are High Court matters. Furthermore, Retainers can be called upon an ytime within twenty- four (24) hours for advice by NATCOM and shall be readily avai lable for that purpose. • To reiterate, NACTOM currently has four pending matters in t he High Court all attended to by our Retainers. • The Legal Department was never visited for verification/cl arification of certain issues since the Team’s attendance at the Commission. Such, we find this amazing as to where this perception derived from. There is an existing ret ainership agreement between NATCOM and our Retained lawyers and available for vi ew on request. • There are amendable options for the department to increase i ts staff level to five (5) and above. But this is not viable without consideration of Re tained lawyers. There will also be cost implications as these staff will be employe d at senior management level (deputy directors), with salaries and associated ben efits of deputies, costing over Le1.5 billion Leones per year. This is the reason for the retention of Retainers as cost of Retained lawyers on yearly contracts is far less th an fortifying the department with more staff. The current staff act as a backup and liaison officers between the Commission and the Retainers. • There are existing annual review reports for years 2020/202 1 respectively but never requested for by your Team. 5.10 Policy and Governance This directorate was established in June 2019 to replicate w hat other sister regulators in the sub-regions of West Africa were doing in terms of policy a nd governance relations. The major mandate of the Unit are to liaise with Ministries, D epartments and Agencies (MDAs), mobile network operators and District/City Counci ls to resolve issues relating to

40. 39 Implications
The accountant would be unable to estimate the value of the as sets of the Commission. Tracking of the Commission’s assets will be dif ficult as there were no records to follow.
Failing to code assets would lead to theft, exchange and loss of the Commission’s property. Recommendations • A Fixed Asset Register must be maintained so that assets are t racked, recorded for proper reporting and audit purposes. • The assets can also be coded for ease of identification. Management Response We now have a comprehensive fixed asset register which inclu des all the fields mentioned above and the assets have been coded and its availa ble for inspection. Land and building are also part of fixed asset register. 7.0 DEBT MANAGEMENT Section 4(a)(1) of the Finance Act 2009 states that: a) to take over ‘The collection of the revenues or other monie s, not derived from taxation, raised or received for the purpose of, or on behalf of the government, hereafter referred to as non-tax revenue and required by subsection (1 ) of section 111 of the constitution to be paid into the Consolidated Fund, includi ng but not limited to fees, royalties payable under the enactments...’ The above provision was further amended under section 12(e) and (f) of the Finance Act 2019 as follows: e). “Collect all non-tax revenue debts owing to the governme nt of Sierra Leone including License payments that are due on a yearly basis, as they becom e due’ f). ‘seal the premises of a non-tax revenue debtor, and g) ‘order a third-party including banks holding money for a n on-tax revenue debtor to pay to the national Revenue Authority all of the debt of non-t ax revenue debtor or any amount that is sufficient to discharge the non-tax revenue d ebt’ NATCOM was in full control of collecting all debts from Mobil e Network Operators. The above provisions have prevented them from performing such f unctions and are required

12. 11 7 PROCUREMENT MANAGEMENT Procurement Plan It was observed that the 2019 and 2020 plans were exactly the same. It was highly unlikely that an institution of this nature would have the same procurement plan for two consecutive years. The Procurement Officer should prepare a standardize procurement plan as prescribed by the Act. Procurement Committee The review Team observed that there was an existing Procurement Committee but not functional on regular basis. Furthermore, the Team further observed that certain procurement activities were not under the control of the Procurement Unit and those activities did not follow due diligence as well as compliance mechanisms. The Management of NATCOM should ensure that the Procurement Committee restore full commitment in discharging their duties and ensure that all procurement activities follow the due processes as demanded by law to promote transparency and accountability in public procurement of goods, services and works. Procurement Unit The Review Team observed that there was a Procurement Unit established at NATCOM but attached to the Administration and Human Resources Department. However, the Team realized that the Procurement Unit report was supervised directly by the Director of Human Resources and Administration, who happened to be an active member in the Procurement Committee. • The Management of NATCOM should ensure that the Procurement Unit is detached from the Administration and Human Resources department and be a standalone unit. • Also, Management must ensure that the Procurement Unit is directly supervised by and/or reports to the vote controller, rather than to the Director of Human Resources and Administration. Records Management The Team also observed that procurement documents were all bungled up in files rather than it being separated and filed as Works, Services and Goods. The Procurement Unit must retain and maintain appropriate filing systems and/or records management to ensure effective storage, retrieval and use of records with due regards to security, integrity and confidentiality. 8. STORES MANAGEMENT Store Environment The Store is not tidily kept and / or spacious as most of the items are obsolete. The Team found it very uncomfortable to work in the store as it was unsightly and the atmosphere was conducive for the Storekeeper to execute his duties. Management should ensure that a secured, conducive location is provided as storage to enable free movement and documentation of materials. This would enable materials to be easily traced.

13. 12 Qualification of Storekeeper The Team observed that the Storekeeper had no knowledge or the pre-requisite qualification for discharging his duties. Management should ensure that the storekeeper be provided with the required training in the discharge of his functions for effective and efficient service delivery. Monitoring and Supervision The Review Team observed that there was less and/or no supervision on the activities of the storekeeper • The Management of NATCOM should ensure that the storekeeper follows the due processes on store requisition and issues. • Moreover, the Commission should develop a policy on stores management and ensure it strict adherence. 9. LEGAL DEPARTMENT The Review Team observed that the Commission had both a Legal retainer and a Legal Department which comprised lawyers. Furthermore, a budget was provided for the Legal retainers and the legal services; both of which performed the same role No contract agreement was provided to the Team with respect to the legal retainers and they were paid on an annual basis. The legal department was under staff with only three personnel of whom two are lawyers and a secretary. • The Management of NATCOM should ensure that best practice was implemented by ensuring that the legal team was mandated to represent the Company in litigation processes (if any). • Also, the legal department should be fortified with additional legal practitioners thereby eliminating the functions of the retainers. 10 UNIVERSAL ACCESS DEVELOPMENT FUND (UADF) NATCOM had given out Le2,931,612,800 (two billion nine hundred and thirty-one million six hundred and twelve thousand eight hundred Leones) as accumulated loan amount to UADF for the period December 2018 - December 2020 inclusive. Also, the Management of UADF should effect a penalty clause on defaulters as stated by Section 7(3a) of the regulation

26. 25 Finding The Review Team observed that the Organogram was incomprehe nsive and limited to few departmental heads. There were a number of departments o r offices that were not captured in the Organogram. Some of the reporting lines and l ine of authority on the chart were not clearly defined and erroneous. It clearly sho wed a possible need for expansion and editing. For example, the Human Resources and Administrative Depart ments is clustered with many Units which were supposedly to be a stand -alone and /or s eparated but they report to the Director of Human Resources and Administratio n. Implication It would lead to conflicts in reporting. Recommendation The Commission should immediately review its Organization al structure by separating clustered departments distinctly showing reporting lines . Management Response Recommendation is noted and action will be taken accordingl y . 5.6 Board Structure Findings The Board lacked the necessarily structures (Board Committ ees) such as Audit Committee, Board Appointment Committee and Remuneration C ommittee which are relevant for an independent and a strategically focused Boa rd. Implications Without these structures the Board’s ability to make an inde pendent, reliable, expert and professional decision will be undermined. Recommendations We recommend that these structures which enhanced corporat e governance be established and are given the free hand to advice on decision making processes which are related to the relevant structures.

46. 45 8.4 Variance in Budgeted line Activities/ Expenditures The Team took samples of Actual expenditures as outlined in t he budget analysis and income and expenditure statement and verified them with pay ment vouchers to ascertain whether the actual amount stated on the income statement ref lects that of the vouchers. The following were the expenditure items upon which the surv ey was undertaken. • Workshop and seminar • Support to National Development • Public Relations and outreach • Fraud management and cyber security • License and insurance • Professional fees The table below shows comparative analysis of budget line it ems as compared with actual and total amount on payment vouchers to ascertain the variances for FY 2019 .

41. 40 to terminate all Revenue Collection Agreement they have ent ered into with Mobile Network Operators; and redirect all such actions and activi ties to the NRA with immediate effect. A cumulative total debt of Le145,226,028,479.32 is still in the books of NATCOM as debt. The collections done by the NRA is slow and/or not robus t. The team could not get any reconciliation statement from the stationed NRA officer with respect to the payment plan made. The NRA officer could not provide the team any further inform ation requested from him as he referred us to his supervisor. Implication Failing to provide or withholding information contravenes the ACC Act Recommendation The NRA should embark on a robust debt collection so as to mini mize and/or get a zero- balance debt. Management Response No response 8.0 BUDGET AND BUDGETARY MANAGEMENT Section 20(1) of the Government Budget and Accountability A ct (GBAA)of 2005 states that “ There shall continue to exist within the Ministry, a unit to b e known as the Budget Bureau which shall, under the supervision of the Fina ncial Secretary, be responsible for the preparation and monitoring of the budge t in collaboration with the Budgetary Agencies ”. 8.1 Budget Participation Participative budgeting is a budgeting process in which the people who are in the lower levels of management are involved in the budget preparation process. Unlike the imposed budgeting process, participative budgeting sh ares the responsibility with lower-level Managers to give them a sense of ownership in the work of the organization.

31. 30 royalties at community level and ensure coordination and su pervision of regulatory services. Additionally, this Unit leads the formulation of Memorandu m of Understanding (MoU) and work with mobile operators, television operators, MDAs esp ecially the Environmental Protection Agency (EPA) to develop policy that would guide t he security and operations of all activities of the Commission. 5.10.1 Annual Work Plan Findings During the period under review, it was observed by the Team th at, the Unit had never developed an Annual Work Plan. Implications Lack of an Annual Work Plan may not provide clear directions b y the Unit and that will automatically impede achievement of the Commission’s goal . Also, it signified that all activities were implemented based on need and in a haphazard manner. Recommendation It is recommended by the Review Team that, an Annual Work Plan be formulated by the Unit indicating list of activities, timelines and budget co nsideration. Management response The unit has developed an annual work plan which is now effect ively in use. 5.10.2 Annual Activities Report Findings In the course of the review, the Team clearly found out that th ere had not been a single annual report prepared by the Unit illustrating yearly succ esses. Implication Failure to provide an annual activity report can make it very difficult to map out progress made by the Unit at a given period. Recommendation It is recommended by the Review Team that going forward; the U nit should prepare an annual activity report that would capture trends of activit ies implemented according to the Annual Work Plan.

62. 61 as well as on supplier, contractor or consultant performanc e is reported to the procurement committee’. Moreover, Section 12 of the Public Procurement Regulation 2020 states that “A Procurement Committee may in addition to the structure and f unctions specified in section 18 of the Act” Furthermore, Section 15(1) of the Public Procurement Regulation 2020 stipulates that “Procurement Committee meetings shall be attended by a ll members of the Committee and a quorum for meetings of a Procurement Committ ee shall be the Chairman and at least 2 members.” Sub Section (2) of the regulation states that “A decision of a Procurement Committee shall be unanimous and where unanimity cannot be achieved, t he decision shall be deferred for further consultation and clarification to ens ure that unanimous decision can be made at the next meeting.” Also Sub (3) states that “Where a member of a Procurement Comm ittee has an interest in a submission, he shall - (a) declare his interest in the submission; (b) leave the meeting while the matter is considered; and (c) not participate in the deliberations or decision-makin g process of the committee in relation to that submission. Finding(s) • The review Team observed that there was an existing Procurem ent Committee but not functional on regular basis. Furthermore, the Team furt her observed that certain procurement activities were not under the control of the Pro curement Unit and those activities did not follow due diligence as well as complianc e mechanisms. • Additionally, available document indicated that the Procu rement Committee used to hold meetings but most of the Minutes and attendance list wer e not signed by the committee members. Implication(s) • Lack of commitment of the Procurement Committee may not prov ide the needed oversight required; ensuring best procurement practices a nd that has utmost tendency for corruption to drive safely in a convenient vehi cle because, it created room for conflict of interest and compromise decision makin g. • Failing to sign an official document by the Procurement Comm ittee members automatically nullified the process and questioned the aut henticity of the process.

64. 63 • Also, Management must ensure that the Procurement Unit is di rectly supervised by and/or reports to the vote controller, rather than to the Dir ector of Human Resources and Administration. Management Responses • The Director General, summoned the Procurement unit togeth er with Members of the Procurement Committee insisting and reiterating the provi sions of the public Procurement Act 2016 as amended that stipulates that the Pro curement unit reports to the vote controller. • The Recommendation is noted that Procurement unit should be a standalone unit as stipulated by the PPP Act 2016 as amended. 11.4 Staff Capacity Section 16 (1) of the Procurement Regulation 2020 states tha t “A Procurement Unit and a subsidiary Procurement Unit shall report to a subsidia ry Procurement Committee or to a Procurement Committee through the main Procurement U nit.” Also, sub section (4) states that “A Procurement Unit shall i nclude staff with appropriate technical skills and where a procuring entity has significa nt volume of specialized procurement or procurement activity requires significant technical input.” Additionally, sub section (5) stipulates that “Staff of a pr ocurement unit shall be appointed in accordance with the normal procedures applica ble to a procuring entity, taking into account the certification and approval require ments issued by the Authority.” Section 17(1) of the National Public Procurement Act (NPPA) 2016 states that “Procurement-related functions shall be carried out by pro curement persons, trained, and knowledgeable in accordance with the guidelines, and qu alification requirements established by the Authority.” Also, Section 19 (1) of the Public Procurement Act 2016 states that “A Procure ment Unit shall be established in each procuring entity, staffed with persons trained and knowledgeable in procurement and charged with carrying out , on a continuous basis, functions related to procurement”. Finding(s) The Team observed that of the three (3) staff in the Unit, only the Procurement Officer has vast and experienced in Procurement while the other two ( 2) staff acquired their Procurement training from NPPA. Implication(s)

6. 5 LIST OF ACRONYMS ACC Anti-Corruption Commission GoSL Government of Sierra Leone NATCOM National Telecommunication Commission IIA Institute of Internal Auditor PFM Public Financial Management GBBA Government Budget and Accountability IAS International Audit Standards ASL Audit Service Sierra Leone WHT Withholding Tax Payment GBAA Government Budget and Accountability Act MoF Ministry of Finance NPPA National Public Procurement Authority Act UADF Universal Access Development Fund NRA National Revenue Authority

75. 74 Furthermore, a total of Le3,194,693,000 (three billion one hundred and ninety four million six hundred and ninety three thousand Leones) were also amou nts owed by NATCOM to various airline agencies. Finally, the cumulative total amount is Le 7,013,255,317.84 (Seven Billion and thirteen million two hundred and fifty-five thousand three hundred a nd seventeen Leones eighty- four cents). Implication Failure by the Commission to pay suppliers on time after deli vering services, goods and works may lead to mistrust and would undermine the image of th e Commission. However, it may also create an opportunity of filing litigation again st the Commission by suppliers and service providers. Recommendation It is recommended that the Commission designs a payment plan and offset the liabilities forthwith to restore confidence of suppliers and service pr oviders. Management Responses The Procurement Committee During a procurement Committee m eeting had unanimously decided that all debts should be paid and the Finance Departm ent should come up with a payment plan for all debtors. 12.0 STORES MANAGEMENT Section 178(1) of the Public Financial Management Regulati ons, 2018 states that “ the acquisition, receipt, custody, control, issue and disposa l of Government stores shall be in accordance with the Act and these Regulations.” Also sub-section (2) Subject to sub-regulation (1) says tha t “ the Minister may give general directions in writing to the Procurement Board on matters re lating to Government stores under the Act.” 12.1 Store Environment The Store is not tidily kept and / or spacious as most of the ite ms are obsolete. The Team found it very uncomfortable to work in the store as it was unsi ghtly and the atmosphere was conducive for the Storekeeper to execute his duties. Due to these factors, the Storekeeper spent most of his time in the HR and Admin office r ather than, the store.

76. 75 The Team also realized that most items procured did not go thr ough stores as they were delivered directly to the end user(s) and the store keeper to ok charge later. Limitation • As a result of the limited storage space, items stored may bec ome damaged, destroyed or cause stored items to deteriorate. • By passing the normal store procedure affects the entire inv entory process as there were all indications and /or possibilities that the store ke eper will not take accurate records of items. Recommendation Management should ensure that a secured, conducive locatio n is provided as storage to enable free movement and documentation of materials. This w ould enable materials to be easily traced. Management Response Management has already made provision for bigger storage sp ace in the new Commission building to enable free movement and documentation of mater ials. All other recommendations are highly noted. 12.2 Staffing Storekeeping is a delicate job and required more than one per sonnel to undertake such task. However, it was realized that the Storekeeper had no de puty and /or assistant in discharging his duties. Implication The absence of an Assistant storekeeper would stall the enti re work process as there will be no assistance to help in that direction. Recommendation Management should ensure that the Storekeeper is provided w ith store clerks to assist the store keeper in the discharge of his/her functions for effec tive and efficient delivery of service. Management Response Recommendation noted for appropriate action

7. 6 EXECUTIVE SUMMARY NO. FINDINGS RECOMMENDATIONS 1. INTERNAL AUDIT AND RISK MANAGEMENT Audit Manual Internal audit manual presented not exhaustive and detailed in line with professional standards and best practices. The Management of NATCOM should ensure that a comprehensive and adequate Internal Audit Manual is produced to facilitate the smooth functioning of the department Audit Committee For the periods under review, the team observed that the Commission had no established Audit Committee to which the Internal Auditors should report to. Rather, they were reporting to a Finance and Audit Committee established by the Board. • Management must immediately constitute an independent Audit Committee as prescribed by the aforementioned sections and also in line with professional standards and best practices. • The Audit Committee should be made up of independent non-executive Directors. Staffing The Audit Unit is understaffed with only four (4) personnel, inclusive of the Director and the Deputy Director. Given the enormity of the mandate of the Commission, it was not practicable for two staff to handle the Internal Audit processes of the Commission. The team also identified the vacant position(s) at the Audit Department. • The Human Resource Department must ensure that adequate staff are recruited for the Audit Department with the prerequisite qualifications and experience. • Additionally, it is recommended that capacity building should be extended to the two-support staff of the Audit Department to enhance their productivity in discharging their duties 2. CORPORATE GOVERNANCE Handing Over Notes/Status Report No detailed handover notes / status reports from the previous Management were presented to the Review Team. The previous Management failed to properly give an account of its stewardship and the status of the company at the time of leaving office. On the other hand, the current Management was complacent in ensuring that there was a proper handover process. A mechanism should be put in place for a detailed handing over note to be provided to the Internal Audit Department by any administration in the event of a transition.

22. 21 Implication Understaffing in the Audit Department will lead to ineffici ency, and ineffectiveness in the discharge of audit duties. Recommendation • The Human Resource Department must ensure that adequate sta ff are recruited for the Audit Department with the prerequisite qualifications and experience. • Additionally, it is recommended that capacity building sho uld be extended to the two-support staff of the Audit Department to enhance their p roductivity in discharging their duties. Management Response With the Commission becoming an Authority which will eventu ally lead to expansion of it functions. The recommendation is welcoming as the depart ment will need additional staff more especially Senior Audit Manager and Audit Manage r to meet the expansion needs by the Authority. 4.7 Reporting Line of the Internal Auditor Internal Auditors are required to report functionally dire ctly to the Board, or a sub- committee of the Board (the Audit Committee), and not to Mana gement except for administrative purposes. However, there are certain things that Internal Audit shoul d report to Senior Management of an entity on performance evaluation for insta nce staff annual increment. Finding(s) The team observed that the Internal Audit Department report ed to the Audit and Finance Committee, and Management. Implication • If Internal Auditors should report directly to the head of en tity, it would affect their independence and objectivity of their work. • Failing to report directly to the Audit Committee makes the w ork of the Internal Audit Department becomes meaningless as it would be compromised b y Management.

23. 22 Recommendation The Director of Internal Audit and Risk Management should en sure they report directly to the Audit Committee so as to avoid conflict of Interest, ma intain objectivity and their independence in the discharge of their duty. Management Response The Internal Audit Department functionally report directl y to the Board and administratively to management. 5.0 CORPORATE GOVERNANCE 5.1 Handing Over Notes/Status Report Findings The current Management was appointed in 2018 after the natio nal Presidential and Parliamentary elections. The Review Team enquired about th e handover process by the previous Management. No detailed handover notes / status re ports from the previous Management were presented to the Review Team. The previous Management failed to properly give an account o f its stewardship and the status of the company at the time of leaving office. On the oth er hand, the current Management was complacent in ensuring that there was a prope r handover process. Implications Handing over ensures ease of transition. Without a proper tr ansition, the Commission is vulnerable to misappropriation. Recommendations A mechanism should be put in place for a detailed handing over note to be provided to the Internal Audit Department by any administration in the e vent of a transition. Management Responses Recommendation noted and the Commission will follow the due process. 5.2 Due Deligence on Natcom by the Current Management Findings The current Management failed to perform due diligence or st ock taking on NATCOM when taking over from the previous management.

52. 51 Management Response • The Admin and HR department have and has maintained a proper f illing system in which we have filling cabinets within the Department that ha s stored and maintained hardcopies document in a much more secured and safer way. • However, due to insufficient space within the department an d the HQ office as a whole, the Commission does not currently have specific archive roo m to store hardcopies documents for the entire office. • Nevertheless, the Commission has already made provision fo r archive room in the new NATCOM building. The Admin and HR management team is current ly working to develop policy on Records Management which will cover both s oft copies and hard copies document and the period at which they are to be kept wit hin the office and the achieve room. 9.4 Staff List Finding Examination of the payroll and staff list showed variances b etween the two documents. The table below shows names of staff that are on the payroll bu t not on staff list Staff Khadijatu Haja Abdul-Tejan Mustapha Kawa Hassanatu Kanneh Furthermore, the under mentioned names were on the staff lis t but not on the payroll provided to the team. Staff Marian N. Yarjah Magdalene Williams There were also observed discrepancies in the way names were spelt and recorded as illustrated in the table below .

80. 79 Implication Failing to maintain a store records voucher may lead to poor a ccountability and the possibility of corruption. Recommendation The Management of NATCOM should ensure that the storekeeper followed the due processes on store requisition and issues. Moreover, the Commission should develop a policy on stores m anagement and ensure it strict adherence. Also, the storekeeper should ensure that a store card was mai ntained and displayed on every item stored. Management Response Recommendation noted for appropriate action 13.0 UNIVERSAL ACCESS DEVELOPMENT FUND (UADF ) Section13; Subject to subsection (2) of section 16 of the Tel ecommunication Act 2006 states that “ there is hereby established a fund to be known as the Universa l Access Development Fund which shall consist of a percentage of the g ross income of service providers as declared for income tax purposes determined by the Minister by statutory instrument.” A secretariat was established to manage the fu nd. The fund was meant for the construction of telecommunication infrastructures ac ross the country to ensure access. Findings The following were observed: • Examination of relevant documents revealed that NATCOM had given out Le 2,931,612,800 (two billion nine hundred and thirty-one million six hundre d and twelve thousand eight hundred Leones) as accumulated loan a mount to UADF for the period December 2018- December 2020 inclusive. Additional ly, the Audited Financial Statement of UADF 2019 stated the loan amount from NATCOM as L e2,359,475,000 (Two billion, three hundred and fifty-nine million four hun dred and seventy-five thousand Leones). The difference of Le572,137,800 (Five hundred and seventy-two million, one hundred and thirty seven thousand eight hundre d Leones) represent the loaned amount for 2020 by NATCOM to UADF.

67. 66 The inconsistencies were occurred when Request for quotati ons were used on several occasions but presently the Commission debriefs all unluck y suppliers respectively in writing upon conclusion of the process. 11.7 List of Supplier/ Vendors Supplier’s evaluation is the process of evaluating (scanni ng) and approving potential suppliers by quantitative assessment. This is to ensure a portfolio / or data of best-in-class suppliers are available for use. Choosing th e right supplier depends on a wide range of factors such as value for money, quality, relia bility, and service. Finding(s) • The Procurement Unit has a Suppliers’ Data, or Vendors List, which is an acceptable practice in procurement. • The Team however observed that the Procurement Unit at NATCO M had supplier database but that a chunk of the vendors that made up the list w ere supplied to the Commission by NPPA. Implication(s) The Procurement Unit of NATCOM may not have profound supervi sion and control over the suppliers acquired from NPPA. Also, it may not help the Co mmission in structuring the supplier base and improving the efficiency of the supply cha in. Issues of conflict of interest may arise in these kinds of arrangements. Recommendation The Procurement Unit should have an effective supplier data base for ease of reference for the procurement of goods and services. Also, the Procuremen t Unit should advertise and recruit their own vendors based on technical qualification s. Management Responses • On a yearly basis the Commission disseminates advertisemen t sourcing suppliers for goods works and service but at the end the turnout is unusuall y very low. • The Public Procurement Manual 2020 2 ND edition states that NPPA should have a masters Supplier database and secondly it also states that y ou can acquire a supplier’s database from any established institution. eg Nassit ,NRA

43. 42 • Furthermore, there was no evidence to show that there was an a ssigned and/or stationed budget officer from the Budget Bureau of the MoF to guide the budget process. Implication Without a functional Budget Committee, the budget process w ill be difficult to achieve and there maybe challenges in aligning and/or incorporatin g activities from the Strategic Plan. Recommendation The Commission should immediately constitute a Budget Comm ittee comprising of all heads of departments and representative of the Board. The Co mmittee should be given freehand to guide the budget process. Management Response • A budget committee will be established representing all hea ds of departments. • There is an assigned staff from MoF who guides the budget proc ess whenever there is a budget call but not stationed at the commission. 8.3 Budget Variance Section 30 (1) of the public financial management regulatio ns, 2018 states that “ A vote controller of a budgetary agency shall not incur or settle an y commitment for which public money has not been provided by the State budget or auth orized to be charged on the Consolidated Fund .” Moreover, sub (2) states that “ When a budgetary agency has overspent a head or subhead of expenditures under the State budget or made unbud geted expenditure, the Minister shall require the head of the budgetary or sub-vent ed agency to submit an action plan under paragraph (b) of subsection (2) of section 120 of the Act, as soon as practicable after the end of a financial year ”. Findings The table below shows comparative analysis between the Budg eted income and expenditures as against the Actual for financial year 2019.

50. 49 • Admin: • Fleet and fuel • Stores • Canteen As result, it was observed that there was no clear descriptio n of tasks, segregation of duties and time lines associated with the activities amongs t staff in the department as there were overlapping and conflicting responsibilities amongs t staff. Implication Combining these two specialized Management functions part icularly within a large establishment with diversified functions will affect the s mooth running of the department. It also undermined accountability and created room for conf lict of interest. Recommendation As a best practice and for effective checks and balances, the MoF and NATCOM must ensure that the Human Resources and Administrative departm ent are divided into two independent departments (i.e., the Human Resources (HR) De partment and the Administrative Department). In this regard, the HR departm ent should handle human resource issues and the canteen whilst the Administrative D epartment will comprise of the Procurement Unit, Fleet and Fuel Management Unit, Stores Un it, Security Unit and the general administrative matters. • There should be clear segregation of duties. For example, th e person or persons in charge of procurement should be different from those in char ge of stores or fleet and fuel management. Management Response The Admin and HR Department have a clear description of task/ separation of duties and function for each unit within the department. Employees wit hin the HR and Admin Department are assigned to perform specific tasks/roles ba sed on their respective unit they represent and areas of expertise as stated in their job descr iption to avoid overlapping and conflicting responsibilities. 9.2 Job Description Findings Job description is fundamental to good employment practice s. It was observed that some of the staff files inspected do not have job descriptions.

27. 26 Management Response Recommendation accepted in good faith. The Board already ha s sub-committees and will put into practice in setting up the necessary committee s as prescribed. 5.7 Board Remuneration/Expenses Findings • The Board Remuneration was determined by State House. There was no given format or policy on how the remunerations were determined. F urther it was unclear as to what constituted legitimate expenses of the Board that sh ould be funded by the Commission. • Consequently, the Review Team observed that there were no bu dget line for the Board activities and it was also observed that most of the fun ded Board activities had no bearing to the work of the Commission. Implications Without proper guidelines on Board remunerations and expen ses, funding of Board activities was open to abuse. Recommendations • A policy on Board remuneration and what constituted legitim ate expenses of the Board should be developed and strictly implemented by the Co mmission. • Management should ensure that Board activities were proper ly planned and budgeted for and should be related to their function and the C ommission. Management Response The issue of remuneration is beyond the Board’s control but a ll other recommendations will be strictly adhered to. 5.8 Development of Regulatory tool Findings The Act mandates the Commission to develop a number of regula tions in order to effectively regulate the telecommunication industry. The Review Team observed that the Commission failed to provide any evidence that this had been done.

28. 27 Implications Failure to develop the necessary regulations as provided by Section 9 of the NATCOM Act created a situation where discretionary decisions are m ade in Regulating the Industry. This is Prone to Corruption. Recommendations • Management should ensure that all regulations are develope d and published in order to effectively regulate the industry. • NATCOM should ensure strict adherence to these regulations by all stakeholders. Management Response • The Board has ensured that effective regulations are promul gated for the effective and efficient running of the Commission. • Furthermore, the Board has ensured that numbers of regulati ons are now in place as currently a draft has been table in Parliament to become an Ac t that will address the challenges stated. 5.9 Legal Department NATCOM has a legal department. The American Bar Association states that “the broad general function of the law department is to delineate legal boundaries within which the management of the corporation is free to exercise its ingenu ity in successfully managing the corporate enterprise. Its function is not to cover up or c onceal illegal activities. It is the responsibility of the corporate lawyer, however, to att empt to find ways legally to achieve proper corporate objectives.” A company law department has to administer consistent with t he company’s legal activities in such a way as to ensure: • Maximum protection of the legal rights of the company consis tent with the performance of the company’s other responsibilities ; • Proper discharge of the company’s legal obligations and • Oversees a firm’s litigation and compliance with internal a nd external regulations and laws. Retainer fees can often lead to unexpected bills for work NAT COM did not know was needed, but when a company pays a fixed monthly fee for legal s ervices, there would be little or no room for misunderstanding what the company owes each much.

24. 23 Even the assets of the Commission were not verified and detai ls of cash and bank balances at the time of taking over were not made available to the Review Team. Implications • Failure to conduct a due diligence correctly in the commence ment of its Management can be a violation of the fiduciary duty of Manage ment to the Government. • There were strong indications that the transition period cr eated conducive environment for misappropriation of funds. Recommendations • The current Management should conduct a thorough stock taki ng of the Commission and present a detailed report on the transition detailing ca sh and bank balances, debtors and creditors, assets and their net worth. • Any instance of misappropriation or corruption during the t ransition should be investigated by ACC. Management Response Recommendation noted for appropriate action 5.3 Strategic Plan Findings The Review Team observed that was an existing five year strat egic plan (2017- 2021) and that the Commission had already commenced the developme nt of the (2022 to 2027) Strategic Plan which was currently in the draft stage. Implication Having a strategic plan in place enabled and/or provided a se nse of direction to the Commission to outlined measurable goals and for the Commiss ion to track progress towards goals. Recommendation The Management of the Commission should ensure that activit ies in the strategic plan (2017-2021) are exhaustive and attained within the time fra me. Also, the draft Strategic Plan should only be operational in the prescribed year.

85. 84 The table above illustrates the payment on various dates to I CC. There has been a delay in the project implementation as the sc hedule above shows that the final disbursement Le10,809,000 (ten million eight hun dred and nine thousand leones) of the loan amounts was made on the 22 nd September 2021. Implication Failing to meet monthly obligation as stated in the standing order could trigger a default rate or penalty interest rate which will increase payment. Recommendation • Management of NATCOM to seat with the Management of SLCB and B SL to review the loan repayment and by extension the standing order date. • Also, ICC should give an update as to the finalization of the n ew office. Management Response Recommendation noted 15.0 REGIONAL OFFICES The Regional Offices were established to implement NATCOM’ s mandates at regional and/or district level. The Review Team visited the Port Loko , Makeni, Moyamba, Kono, Bo, Kenema and Pujehun offices of NATCOM to get firsthand inform ation about the functioning of these offices. Below are the findings and rec ommendations. 15.1 Staff Composition and Functionalities • It was observed that Kenema and Bo were headed by Managers and the others by Supervisors. The overall functioning of these offices were centered on the Managers or Supervisors who performed multiple and conflicting roles. The Managers/Supervisors were in charge of the day to day activities of the offices and t hey embodied the entire Administration, Finance and HR functions. It was further ob served that most of the regional heads do not possess the required qualifications f or such position. • There were assigned General Services Officers and General S ervices Assistants to these offices. The General Services Officers (GSOs) and Gen eral Service Assistant (GSAs) were not proportionately distributed in the regions as they were more than required in some offices whilst few in others. Most of the GSO s were not provided with a job description.

82. 81 • The basis on which the loan was written off as bad debt was not p rovided. The amount was so significant for it to be treated as an expense (b ad debt). In fact, UADF was a going concern and has never been liquidated or pronounc ed insolvent for its loan to be treated as a bad debt. The loan period had just run fo r almost two years for it to be considered as bad. • Furthermore, there was no evidence that NATCOM had positive ly engaged UADF on the loan repayment. • With regards to revenue generation by UADF Secretariat, it w as observed that a Cabinet Resolution Paper had been past and Section 7(1) of th e Universal Access Development Fund Statutory Regulation Instrument 2019 sta tes that “ there shall be charged on a service provider, in accordance with Section 13 of the Act, a Universal Access and Service levy of 0.75% of his gross incom e as declared for income tax purposes.”  The Review Team could not be provided with the total revenue g enerated from the GSM and ISPs as a result of the 0.75% deductions from their pro fits. The Team was also informed that some of these GSMs were refusing to pay .  Section 7(3a) of the regulation purported that “ A licensee who fails to pay a universal access and service levy under subsection1 commit s an offence and is liable to a penalty not exceeding 25% of the levy and an i nterest of 5% thereon.” The Team was not provided with any penalty charge on licensee s who failed to pay. • Pertaining to the fulfillment of its mandate of building tel ecommunication infrastructures, it was observed that the UADF Secretariat had failed to undertake any such project. All the funds received so far had been spent on salaries and other administrative matters. • The Team was also informed that UADF was not obliged to report to NATCOM despite the fact that the Secretariat was supposed to be a sub set of NATCOM. It now reports directly to the Ministry of Information and Communi cation with no supervision or collaboration with the Commission. • The Team realized that public education on the work of UADF wa s not done enough.

21. 20 Findings • The review team noted that there was evidence that the Commis sion had never been audited by an External Audit firm and/or Audit Service Sierr a Leone. • However, the review team was informed that Audit Service Sie rra Leone (ASL) will undertake an external audit for the financial years (FYs) 20 17, 2018 and 2019. Implications • Delay in External Audit process will affect the credibility of a company's financial statements and compliance with regulations. • The External Auditors will not be able to assess the objectiv ity and/or evaluate the effectiveness of internal controls within the company. Recommendations As prescribed by the sections above, the Management of NATCO M should ensure that External Audit is adhered to by the provisions of the Acts, so that an assessment of their financial statement complies with regulations. Management Response External Audit for the years stated have all been conducted a nd concluded by the Audit Service Sierra Leone. 4.6 Staffing Staffing is an operation of recruiting employees by evaluat ing their skills, knowledge, and then offering them specific job roles accordingly. Finding • The Audit Unit is understaffed with only four (4) personnel, inclusive of the Director and the Deputy Director with two support staff with no audit e xperience. Given the enormity of the mandate of the Commission, it was not practic able for two staff to handle the internal audit processes of the Commission. • The team also identified the vacant position(s) at the Audit Department.

59. 58 Implication Proper monitoring, evaluation and control of fleet cannot b e carried out effectively and efficiently as it should be the case when there is no yardstic k and standards for comparison, regulating and making informed judgment on fle et management procedures. Recommendation(s) • Accountable tools such as Logbooks, Vehicle Movement Regis ter/Tracking System, Vehicle Request Form, Maintenance Reporting Template etc. should be developed by the Fleet officer and be operational at all levels of the Comm ission. • The fleet officer should ensure that files are maintained fo r vehicles • A credible data base of all automobiles under the purview of C ommission should be developed, and regularly updated. • The Commission should ensure that a policy and/or contract b e established with garage(s) through the Legal Department. • The Senior Driver and Supervisor Transport and Estates should establish a movement book/or form for drivers for monitoring. • Proper monitoring and control procedures including checkl ist, Standard Operating Procedures and where possible the use of GPS for tracking all assets and fuel management should be incorporated and implemented going fo rward. Management Response Recommendation is noted and action will be taken accordingl y. 10.2 Fuel Management The Commission stock level 21,000 liters fuel was supplied b y NP Wilberforce on a monthly basis. Payment was either made in advance or at a late r date. The Team observed that, there was no formal agreement betwee n the supplier and the Commission. With respect to fuel request procedures, it was observed tha t no technical knowledge was used to determine the quantum of fuel a vehicle or motorbi ke can consume per kilometer covered. We noted that there was no fuel reconciliation report with fu el suppliers on fuel allocation to the Commission. Also, no fuel reconciliation report was provided to the Team with regards the usage of fuel by the Commission. There was no policy on fuel allocation.

66. 65 Management Responses • The Procurement unit has employed strategic filling as was a dvised by the Anti- Corruption Commission during the several interviews we had during the Period under review. • Presently, we file categorically using Goods Works and serv ices and using procurement methods. • The procurement unit has been provided with a multi-purpose printer and three double door cabinets for the purpose of appropriateness. 11.6 Debriefing to | Unsuccessful Bidder Section 27 of the NPPA state that procuring entity shall immediately, a fter a successful bidder has been identified, inform the unsuccessful bidder (s) of the reason for which their respective bids were unsuccessful. By the provisions of Sec 28(1) , , Subject to this Act, documents, notifications, decision s and other communication referred to in this Act to be submitt ed by the procuring entity to a bidder, or by a bidder to the procuring entity, shall be in wri ting Subsection 3 of section 56 of the NPPA act of 2016 stated that, notice of award shall be gi ven to other bidders at the same time the successful bidder is notified, specifying the name and address of the proposed bidder and the price of the contract Finding(s) The Review Team observed that most of the notifications sent to suppliers were not signed. Therefore, it was by no mistake to conclude that most of these unsigned documents were prepared upon request. Implication(s) Failure to sign suppliers’ notification letter may not prov ide credence to best procurement practice and feedback mechanism. Recommendation(s) The Review Team recommends that for proper accountability a nd transparency, the Procurement Unit should always communicate in writing to al l bidders whether successful or not which must be filed to ensure appropriate documentati on process. Management Responses The Procurement unit always debriefed unfortunate supplie rs on all major procurement issues especially when NCB and ICB are used.

89. 88 Implications • Delay in replenishment would undermine the effective runni ng of the office. • A single individual controlling petty cash without a Financ e Officer would lead to abuse or corruption. • Five million Leones (Le5,000,000) for fuel was not sufficie nt for the effective running of the offices especially against the backdrop of current fuel price rise and the distribution quota particularly for districts without electricity or th ose seriously challenged for electricity was not realistic.. • Lack of contractual agreement leaves both parties vulnerab le to abuse . • Unsigned sheets were indications of dubious acts. This also went for sheets that were intact while the supplies had been delivered . Recommendations All petty cash should be properly managed and accounted for. The petty cash fund should undergo periodic reconciliations, with transactions also recorded on the financial statements. Management Response • Recommendation is noted and action will be taken accordingl y. • Nonetheless, it is mandatory by the Zonal offices to submit m onthly reconciliation report on the usage of the petty cash and fuel for replenishment. • The said Finance Reconciliation Report is mostly done by the General Service Office (GSO) who is assigned to provide financial assistance to the zonal office respectively.

9. 8 presented was a listing of assets which did not reflect fixed assets registered. purposes. The assets can also be coded for ease of identification. 4. BUDGET AND BUDGETARY MANAGEMENT Budget Participation The Review Team verified that the budget preparation was participatory by all heads of department upon which submissions were incorporated into the Commission’s annual budget. The Management of the Commission must ensure that the budgetary participatory process is inclusive of both Management and lower-level staff. Budget Committee There was no evidence to show that an independent Budget Committee to guide and regulate the budget process for the periods under review. A Minute of a Finance and Budget Committee was presented to the Review Team to show that such Committee existed. The Commission should immediately constitute a Budget Committee comprising of all Heads of Departments and representative of the Board. The Committee should be given freehand to guide the budget process 5. HUMAN RESOURCES MANAGEMENT Human Resources and Administration The Review Team observed that the Human Resources and Administrative Department was one and the same. Department. As a best practice and for effective checks and balances, the MoF and NATCOM must ensure that the Human Resources and Administrative department are divided into two independent departments (i.e., the Human Resources (HR) Department and the Administrative Department). Job Description Job description is fundamental to good employment practices. It was observed that some of the staff files inspected do not have job descriptions. • The Human Resources Department should ensure that there are properly drafted job descriptions for every position in the Commission. • The Department should further ensure that all staff members of the Commission are issued with the appropriate job description. Records Management It was observed that records were mostly maintained in soft copies. Hard copies were difficult to come by or access. There was no observed back up mechanism for digitized records. • Management should develop a records management policy for the Commission. • Whilst it is laudable for the Commission to attempt to digitized its records management, however it must be properly done taking in consideration fraud and security concerns, preservation and authenticity of records

49. 48 The above table reveals variances with respect to budget and actual alongside percentages and payment vouchers of respective sample transactions. With reference to Support to National Development, it showe d that only 50% of the budget was utilized and a variance 30% of the supporting documents c ould not be found. Moreover, Public Relations and Outreach showed that 31% of t he budget was actualized leaving variance of 69%. Also, the table shows that 81% of the budget was over spent on S ecurity Service, while 20% was the variance between the actual and payment vouchers . Additionally, 48% excess was utilized from the budget givin g a variance of Le383,050,000 and equilibrium payment vouchers verification. Management Response • The budget against actual report will now be prepared, varia nces investigated and corrective actions implemented quarterly. • The actual report will also be compared to both hard and soft c opies of payment vouchers to ascertain any variance in documentation • For Public Relations, the payments vouchers exceeded the ac tual payments because there was re-classification of the expenses. 9.0 HUMAN RESOURCES MANAGEMENT According to Eric Flamholtz, “ Human Resource Audit is a systematic assessment of the strengths, limitations, and developmental needs of its exi sting human resources in the context of organizational performance .” Also Gary Dessler stated that, “ Human Resource Management is the process of acquiring, training, appraising, and compensating employees, and att ending to their labour relations, health, safety and fairness concerns .” 9.1 Human Resources and Administration Findings The Review Team observed that the Human Resources and Admini strative Department was one and the same Department. This merged department cove red the following Units: • Procurement • HR

54. 53 • The Review Team was not provided with printed copies of the Bi ometric registration and the manual method (ledger) to ascertain recording of sta ff attendance, punctuality and movement. • The Review Team was not presented with any evidence that ther e was a mechanism in place to generate reports from the ledger or the biometric registration for monitoring purposes that would ensure appropriate actions were taken w here necessary. Implications Without an effective system to monitor staff regularity, st aff will be paid for work not done. Recommendations • Management should ensure that they establish an effective s ystem of staff attendance register. Monthly reports should be generated a nd monitored. • The Human Resources Department should ensure that staff mov ements are captured in the Biometric system and not just limited to clocking in wh en reporting for duty. • Management should also consider reinstituting the biometr ic registration systems as covid 19 restrictions are gradually lifted Management Response During the peak of Covid19 pandemic in Sierra Leone, the Comm ission’s senior management team made a resolution to stop the use of the Biome tric registration during the peak of Covid19 pandemic to avoid physical contract. Nevertheless, a manual method (ledger) was adopted as an alt ernative to record staff attendance as well as to determine punctuality and staff mov ement. Evidence of staff attendance book is available for the said period for further assessment. The Commission has reinstated the use of biometric registra tion system immediately after the lifting of Covid19 restrictions. The departmental quarterly report covers staff attendance . As recommended, forthcoming, a monthly notification will b e provided to all employees who constantly report to duty late without reasonable justi fication. 9.6 Performance Appraisal Findings • According to the Performance Management Policy of NATCOM , “The Commission shall conduct a Performance Review twice per year for each em ployee. A review may

42. 41 Finding
The Review Team verified that the budget preparation was par ticipatory by all heads of department upon which submissions were incorporated int o the Commission’s annual budget.
Annual departmental budget is prepared in consolidation wi th the Commission’s annual budget which is in line with the Budget Call from the Mi nistry of Finance. Implication Limited or no input of lower cadre staff of all departments in the budgetary process may lead to unrealistic budget. Recommendation The Management of the Commission must ensure that the budget ary participatory process is inclusive of both Management and lower-level sta ff. Management Response The Commission noted the concern of ACC Recommendation and w e shall adhere to it. 8.2 Budget Committee A Budget Committee is an official group that creates and over sees the standards and best practices to implement and update an organization's sp ending and resource allocation plans while maintaining fiscal responsibility . Budget Committees play a key role in the success or demise of a company or other entities that rely on generating and spending cash flows in o rder to remain operational. Findings
There was no evidence to show that an independent Budget Comm ittee to guide and regulate the budget process for the periods under review.
A Minute of a Finance and Budget Committee was presented to th e Review Team to show that such Committee existed.
However, the effectiveness of the Committee was not guarant eed as no policy or terms of reference with regards it operations were presente d to the Review Team.

18. 17 4.2 Audit Committee Section 76(1) of Public Financial Management (PFM) Act of 2016 states that “ The Director of the Internal Audit Department of the Ministry ma y require the vote controller of a Budgetary Agency, Sub-vented Agency, other entity in the c entral government, Local Council, social security fund, or public enterprise to esta blish an Audit Committee of the entity, after consultation with the vote controller of the e ntity.” Findings For the periods under review, the team observed that the Comm ission had no established Audit Committee to which the Internal Auditors should repor t to. Rather, they were reporting to a Finance and Audit Committee established by th e Board. Implications The non-existence of an independent Audit Committee impede s the oversight of the financial reporting process, the audit process, the compan y's system of internal controls and compliance with laws and regulations. Additionally, it undermines the authority and weights of th e internal audit reports as there will be no structure within the management hierarchy to ensu re that the findings and recommendations are acted upon by Management. It is also a co mplete violation of Section 76(1) as stipulated above. There was no oversight ro le. Recommendations Management must immediately constitute an independent Aud it Committee as prescribed by the aforementioned sections and also in line with profess ional standards and best practices. The Audit Committee should be made up of independent non-exe cutive directors. Management Response An Audit Committee has been established by the Commission. 4.3 Annual Audit Plan According to International Audit Standards (IAS) 300 –“ In planning an Audit of Financial Statement, the Auditor should plan the audit so that the enga gement will be performed in an effective manner. The objective is for the Auditor to deve lop an Audit Plan in order to reduce audit risk to an acceptably low level .”

32. 31 Management response Recommendation noted. 5.10.3 Policy /Regulation Development Findings • The Team was informed that five (5) policies/ regulations ha d been developed by the Unit together with other department in 2020 It went through P arliamentary approval and became statutory instrument so that, the Unit can regula te mobile network operators and guide their daily operations in providing qua lity telecommunication services for the masses. • However, these policies were not presented for verificatio n and there were no indications that they were being implemented. Implication Lack of full implementation of most of these policies may und ermine quality telecommunication services. Recommendation The Review Team recommends that, all the policies developed and enacted through Parliament should be fully implemented to regulate mobile n etwork operators and boost quality telecommunication services. Management response Recommendation noted. 6.0 FINANCIAL MANAGEMENT Section 17 (1) of the Telecommunications Act 2006 states that “The Commission shall keep proper books of account and proper records in relation t o them in a form approved by the Auditor-General.” 6.1 Financial Policy and Procedural Manual Findings The Review Team was not provided with any financial manual of the Commission for the period under review despite the fact that, they work in line w ith the statutory financial instruments in carrying out their duties. The team was infor med of a financial manual which was in a draft stage commencing 2021, but yet to be verif ied by the team.

33. 32 Implication • In the absence of a financial policy and procedural manual ad opted, Management and Board members likely to operate under a set of assumption s and discretions that may or may not be accurate or productive. • The financial management, risk the mitigation and the align ment of financial operation with the overall mission of the organization will be distort ed. Recommendation The Management of NATCOM should ensure that a financial manu al policy and Procedural manual is established and if so, the draft financ ial manual should be finalized and effected. Management Response The draft Finance manual has been approved, implemented and available for inspection. 6.2 Area of Focus: Petty Cash Findings • The team observed that petty cash float was allocated to the v arious departments at the head quarter in the tune of ten million (Le10,000,000) Le ones and five million (Le5,000,000) Leones to each regional office on a replenish ment basis and /or impress system. • Nevertheless, no policy on petty cash disbursement was pres ented to the team, though monthly reconciliation and/or retirement are done b efore a float was given. There were also delays in reimbursement of floats. Implication
The absence of a petty cash policy would prevent the Finance D epartment to balance the need for effective control over acquisition of g oods and services of low value.
Delay in reimbursement affected timely implementation of a ctivities. Recommendation The Management of NATCOM should ensure a policy on petty cash is effective and reimbursement should be timely.

68. 67 11.8 Sale of Bidding Documents Section 58(4) of Procurement Regulation2020 states that “a procuring entity may charge a fee for the bidding documents, which shall be calcul ated to cover the costs related to printing, copying and distribution of the docume nts only and shall not include any element of profit. Subsection (5) states that “Payment from the sale of standard bidding documents shall be made into the Consolidated Funds ”. Also, subsection (6) stipulates that “The Authority shall receive on a regular ba sis a percentage of the fees for each standard bidding document pa id by bidders.” Findings The Team could not see any evidence of such payments being mad e as prescribed by the sections of the law and regulations quoted above. Implication There a breach of regulation Recommendation Management should ensure that the Procurement Unit abide by the provisions stated above as a best practice Management Responses
The Sale of Bidding Document is being done by the Commission’ s Finance Department. • Sequel to the Memo from the NPPA providing accounts for sale o f bid documents, the commission had been 100% compliant with the regulation a nd have never flouted any regulations of such nature. 11.9 Payables to supplies A liability is typically an amount owed by an institution to a supplier, bank, lender or other provider of goods, services or loans. In this context, procurement liabilities are an amount owed by the Commission to various suppliers for under taking the full provision of goods, services and works. Finding The Review Team observed that the Commission owed enormous s ums of money to various suppliers for various goods, services and works, su pplied to the Commission

55. 54 also be conducted in the event of a promotion or change in duti es and responsibilities.” • The team observed that performance reviews have not been con ducted regularly as prescribed in the policy. Implications • There is a Breach of company’s policy. • Employees subject to ineffective systems and performance r eview practices are likely to feel upset, demoralized, and demotivated. This may lead t o employees becoming dissatisfied and burnt out in their roles Recommendations Performance appraisals must be done regularly as prescribe d in the Performance Management Policy to improve staff performance and product ivity. Management Response • There is evidence to show that employees’ performances were appraised in 2019 and 2021 respectively. However, in the year 2020 due to the natio nal Covid19 restriction policy which recommend employees to work from home in the que st to avoid physical contract, resulted to the cancelation of 2020 performance a ppraisal process. • Management is aware of the implications of ineffective Perf ormance appraisal system, as such; we have and have maintained a structured appraisal s ystem. • Currently, performance appraisal is done yearly; also, app raisal is conducted after probationary period for new staff before confirmation as we ll as for promotion or change in duties and responsibilities.” Nonetheless, as re commended, management will ensure we adopt mid-year and end of year appraisal syste m in the future. 9.7 Staff Personal Files /Records Finding The Team observed that most of the staff files examined were w ithout certificates and/or not updated with the necessary information and/or do cuments Implication Failure to update personal files of employees of relevant do cuments would limit information on that employee for staff development

61. 60 they are required. A good procurement plan will describe the process in the identification and selection of suppliers/contractors/consultants. According to Section 29 (1) of the NPPA 2016, all procuring entities shall undertake procurement planning, with a view to achieving maximum valu e for public expenditures and the other objects of this Act. Finding(s) • The Review Team was presented with the Procurement Plans 201 8, 2019 and 2021 as prescribed by S29 (2) above. • However, it was observed that the 2019 and 2020 plans were exa ctly the same. It was highly unlikely that an institution of this nature would have the same procurement plan for two consecutive years. It suggests that much effort has not been placed in preparing the annual procurement plan. Implication The absence of a well thought out Procurement Plan would prev ent the Commission from prioritizing its procurement needs and achieving valu e for money. Recommendation(s) The Procurement Officer should prepare a standardize procu rement plan as prescribed by the Act. Management Responses • There is an existing annual procurement plan of which the Pro curement unit which it uses to execute the Commission Procurement Activities. • The procurement plan for 2019 and 2020 are totaling differen t, the activities might appear the same for goods and services but with different amo unts, procurement methods and threshold are attached 11.2 Procurement Committee Section 18 (1) of NPPA 2016 states that “a Procurement Committee shall be established in every procuring entity”. Also, according to S18(8) ‘a Procurement Committee shall make necessary arrangements to ensure that timely information on the execution, and conclusion of contracts by a Department or Di vision of a procuring entity,

65. 64 Without the requisite skills effectiveness and efficiency will be adversely affected. Recommendation(s) Staff in the Procurement Unit needs to be trained (upgraded) by Management in procurement processes. Management Responses • Staff of the Procurement unit together with a staff from Admi n and Finance Department underwent a training session organized by NPPA. • However, the Procurement unit staff really needs contempor ary upgrade on processes and procedures, ethics, Project Management, Con temporary procedures and approaches, negotiation skills and many more. 11.5 Records Management (Filing System) Section 32 (1) of NPPA 2016 states that the procuring entity shall preserve all documentation relating to the procurement processes, in ac cordance with applicable rules concerning archiving of government documentation, b ut at a minimum for a period of six years following the date of final completion of the pro curement contract, or from the date of rejection of all bids or cancellation of the proce eding, as the case may be. Finding(s) • The Team observed in relation to the above section that prope r filing system of procurement documents were not maintained. The Team also ob served that procurement documents were all bungled up in files rather th an it being separated and filed as Works, Services and Goods. • Additionally, the Team observed that the Procurement Unit d id not keep copies of procurement documents as they relied on the file copies at th e Finance Department. Implication(s) Inappropriate and incomplete filing of procurement docume nts may lead to cumbersome retrieval of documents with maximum tendency to encourage u nauthorized access to records by other officials which can subject the institutio n to security breach, physical damage, loss of credibility and confidentiality. Recommendation(s) The Procurement Unit must retain and maintain appropriate f iling systems and/or records management to ensure effective storage, retrieval and use o f records with due regards to security, integrity and confidentiality.

8. 7 Board of Directors We observed that their appointment letters did not specify how involved they would be in the day to day running of the company i.e., whether they are executive or non-executive Board Members. • The Act should be reviewed in order to clarify the role of the board as supervising body and the Director General as head of administration. • The appointment Letter must state whether the Board is a non-executive or executive board. If it a non-executive a written terms of engagement include job description should be given and if it is executive a service agreement setting out the terms of the directorship should be given. Board Remuneration/Expenses The Board Remuneration was determined by State House. There was no given format or policy on how the remunerations were determined. Further it was unclear as to what constituted legitimate expenses of the Board that should be funded by the Commission. • A policy on Board remuneration and what constituted legitimate expenses of the Board should be developed and strictly implemented by the Commission. • Management should ensure that Board activities were properly planned and budgeted for and should be related to their function and the Commission. 3. FINANCIAL MANAGEMENT Financial Policy and Procedural Manual The Review Team was not provided with any financial manual of the Commission for the period under review despite the fact that, they work in line with the statutory financial instruments in carrying out their duties. The team was informed of a financial manual which was in a draft stage commencing 2021, but yet to be verified by the team The Management of NATCOM should ensure that a financial manual policy and Procedural manual is established and if so, the draft financial manual should be finalized and effected. Petty Cash No policy on petty cash disbursement was presented to the team, though monthly reconciliation and/or retirement are done before a float was given. There were also delays in reimbursement of floats. The Management of NATCOM should ensure a policy on petty cash is effective and reimbursement should be timely. Cheque Withdrawals The team observed that numerous cheques were drawn in the names of lower cadre workers of the Commission who were not members of the Finance Department . All payments should be done in line with best practices and also laws and regulations Fixed Assets Register The team observed that the Commission does not maintain a fixed Assets Register as the document A Fixed Asset Register must be maintained so that assets are tracked, recorded for proper reporting and audit

25. 24 Management Response Recommendation is noted. 5.4 Board of Directors Findings • Board members are appointed and removed by the Government. W e observed that their appointment letters did not specify how involved they would be in the day to day running of the company i.e., whether they are executive o r non-executive board members. • The independence and diversity to ensure and effective boar d are also questionable as the board does not include members with dive rse and relevant professional background and experience necessary for an ef fective board. Implications • Failure to specify whether there is an executive or non-exec utive is a source of conflict between the Managing Director and Board Members. • Without diverse and relevant professional background and r equired experience, the board will be unable to effectively steer the management of t he Company. Recommendations • It is recommended that all Board appointments should be done in line with the Commission’s Act with consideration given to qualificatio ns and experience. • The Act should be reviewed in order to clarify the role of the b oard as supervising body and the Director General as head of administration. • The appointment Letter must state whether the Board is a non- executive or executive board. If it a non-executive a written terms of eng agement include job description should be given and if it is executive a service a greement setting out the terms of the directorship should be given. Management Response Recommendation noted for action 5.5 Organizational Structure

29. 28 Findings • The Review Team observed that the Commission had both a Legal retainer and a Legal Department which comprised lawyers. Furthermore, a b udget was provided for the Legal retainers and the legal services; both of which performed the same role. • Additionally, litigation on behalf of the Commission was se ldom and/or none in a year as a result payments were being made for no service. • No contract agreement was provided to the Team with respect t o the legal retainers and they were paid on an annual basis. • The legal department was under staff with only three personn el of whom two are lawyers and a secretary. • The legal department could not provide annual work plan for p eriods under review to the Team. Implication Having a legal department and hiring a private retainer is an extra cost on the Commission. Recommendation • The Management of NATCOM should ensure that best practice wa s implemented by ensuring that the legal team was mandated to represent the Company in litigation processes (if any). • Also, the legal department should be fortified with additio nal legal practitioners thereby eliminating the functions of the retainers. Management Response • Any established Institution should have Retained Lawyers ( Retainership) acting for and on behalf of the Commission on complex issues and give ind ependent advice and address all legal issues on behalf of the Institution. NA TCOM is no exception in that regard. The Director and his team are often busy and inun dated with other matters such as; drafting of legal instruments, contracts, agreements and responding to letters, enquiries/queries addressed to the Commission. • In addition to attending external meetings and conferences nationally and internationally on behalf of the Commission.

56. 55 Recommendation The Human Resources Manager must ensure all staff files were regularly updated and all gaps identified by the team are regularized. Management Response Recommendation is noted and action will be taken accordingl y . 9.8 Staff Qualification Finding • In the process of comparing staff prerequisite and/or quali fications to their positions, the Team observed that most staff did not have the required qu alification(s) that best suited their positions. • The Team also observed that some staff qualifications did no t match with the work designated. Implication • Inequalities between job designed and qualification would affect the growth of the organization and hence marginalization, policy breach and demonization will be on the rise. • Also, hiring unqualified staff would affect the company’s g oodwill, market value, work system and would lead to poor decision-making skills. Recommendation • The Management and the Board should ensure a comprehensive H uman Resource Audit is conducted by the Internal Audit Department. Moreov er, the HR should ensure that all staff should submit their original qualifications for verification. • Also, the HR Unit should ensure, employees whom are without t he prerequisite qualifications for their respective positions are to be tra ined on the job and/or provided trainings. Management Response Recommendation is noted and action will be taken accordingl y. Nonetheless, a comprehensive training and development plan for all staff h as been developed to ensure employees skills and competences are set to achieve the aims and objectives of the Commission.

60. 59 Recommendation(s) • The Management of NATCOM should ensure that a policy of fuel m anagement is established. • There should also be a framework Contract agreement between the supplier and the Commission With regards the supply of fuel and that should be in line with the procurement regulations. • The Commission should ensure that there is a regular reconci liation of fuel so as to establish the reorder level of stock, usage and balance. • The officer is charge of fuel should be trained. • Management should embark on the modern-day fuel dispensati on by initiating the electronic chit system (Tom Card) for staff and the Commissi on at large. Management Response • Recommendation is noted and action will be taken accordingl y. However, fuel reconciliation report is done monthly and submitted to Inte rnal Audit and Risk Management Team for verification before the approval of mon thly fuel replenishment. • Additionally, the use of electronic chit system (Tom Card) h as currently been implemented/executed for employees that are eligible to fu el allocation and the Commission at large. 11.0 PROCUREMENT MANAGEMENT Procurement Management is the systematic approach used for buying all the goods and services needed for a company to stay sustainable. When proc urement is managed well, it would add value to all business practices, and save both ti me and money. Furthermore, the goals of the procurement cycle are to: i. Manage spending; ii. Support operations; and iii. Protect the organization from risk. 11.1 Procurement Plan Procurement planning is the process of identifying and cons olidating requirements and determining the timeframe for procurement with the aim of ha ving them as and when

63. 62 Recommendation • The Management of NATCOM should ensure that the Procurement Committee restore full commitment in discharging their duties and ens ure that all procurement activities follow the due processes as demanded by law to pro mote transparency and accountability in public procurement of goods, services an d works. • Furthermore, Management should certify that the Procureme nt Committee members sign attendance list and Minutes accordingly in respect of a ny bid opening and/or evaluation process. Management Responses • The Commission’s Procurement Committee is Functional and i t does meet whenever there a major Procurement decision to be made. • We will ensure that all Minutes and attendance of Procuremen t Committee meetings are signed accordingly. 11.3 Procurement Unit Section 19 of the National Public Procurement Authority Act of 2016 stated that, “a Procurement Unit shall be established in each procuring ent ity, staffed with persons trained and knowledgeable in procurement and charged with c arrying out, on a continuous basis, functions related to procurement.” Finding • The Review Team observed that there was a Procurement Unit es tablished at NATCOM but attached to the Administration and Human Resourc es Department. • However, the Team realized that the Procurement Unit report was supervised directly by the Director of Human Resources and Administration, who h appened to be an active member in the Procurement Committee. Implication Since the Procurement Unit is directly under the supervisio n of the Administration and Human Resources department, it meant that the Unit did not ha ve total control over its mandate and there was possibility of influence. Recommendation • The Management of NATCOM should ensure that the Procurement Unit is detached from the Administration and Human Resources depar tment and be a standalone unit.

36. 35 From the data above, we observed that revenue generated in 20 19 was higher than revenue generated in 2018 and 2020. It was further observed t hat there was a sharp increase in revenue from 2018 to 2019 by Le23,124,883,326, w hich is about 16% increase in revenue generated between the two years. The Com mission experienced a deep fall in revenue between 2019 and 2020 of about Le21,722, 202,221.0 (13%) from 2019 revenue generation. Implications A drop in revenue showed weaknesses in the Commission’s reve nue drive. Furthermore, the failure by Management to examine and/or investigate thi s sharp fall in revenue made it impossible for Management to determine the cause and take corrective measures to ensure sustainable revenue generation. Recommendation
The Management of NATCOM should conduct a financial assessm ent and/or evaluation on its revenue generation drive during this peri od to maximize future revenue generating potentials. Such evaluation should be r egularly conducted when preparing the annual budget.
Any drop in revenue generation should be critically examine and/or investigated in order to determine the cause and necessary corrective measu res taken. Management Response • In the first instance, the fall in revenue in 2020 was due to th e impact of Covid 19 pandemic, which affected many businesses as they closed dow n and some customers did not start up their business. • Additionally, there was an improvement in technology as man y VSAT customers decommissioned their VSATs licenses. • Furthermore, the income stream, Local Interconnect was dis continued in order to satisfy users for mobile networks. • Moreover, we are not charging surcharge on data. • NRA was also responsible for collecting debts instead of NAT COM. • Finally, there was an increase in Over The Top (OTT) calls exa mples WhatsApp calls, Facebook, face time etc. which affected our local and intern ational calls. 6.4. Cheque Withdrawals The team observed that numerous cheques were drawn in the nam es of lower cadre workers of the Commission who were not members of the Finance Department. For

45. 44 The table also shows that the actual expenditure was lower th an anticipated. There was a favorable variance of Le67,418,475,677. i.e. 30% less of pr ojected Expenditure. Column three of the table reveals that the actual expenditure was hi gher than the actual income for the year for the second consecutive year. There was a gross loss of Le8,172,268,514 (eight billion one hundred and seventy-two million, two hundred and sixty-eight thousand five hundred and fourteen Leones. This was a greater loss than that of 2019. From all indications, the above tables illustrate the progr essive loss in the Commission’s income statements from 2019 ( Le2,880,250,599) to 2020 (Le8,172,268,514.98); an increase of Le11,052,519,116.98 (Eleven billion and fifty -two million five hundred and nineteen thousand one hundred and sixteen Leones ninety-ei ght cents). Furthermore, no data was provided to the team with respect to FY 2018. Implication • Weak revenue generation. • Weak cost control. • Possible under reporting of revenue. • A negative gross margin is an indication that the Commission was unavailable to cover its operating costs and inability to control expenditures. Forecasters are unable to predict future costs and revenue with complete accuracy. Recommendation In order to maintain a favorable profit, the Management of Ne tcom should ensure that the Commission’s costs/expenditures are reduced; turnover an d efficiency are increased. Management Response Management will ensure that the Commission’s expenditures are reduce; turnover and efficiency are increase in the future. • The actual figures were receipts and payments or cash based, not income and expenditure whilst the budgeted figures are on accruals basis (inclusiv e of debtors) and as result will not be consistent. In the Future we ensure budgets are prepared o n cash bases. • In addition, the reason for unfavorable variance in income f or 2019 and 2020, was as a result of businesses closing down, and some service providers deco mmissioned their equipment • Lastly, the Covid 19 pandemic was again a major cause of incom e deduction.

34. 33 Management Response
The policy on petty cash disbursement is included in the fina nce manual and its implementation has been operational prior to the manual’s a pproval. Training has also been done on petty cash management
The delays on the disbursement process have been minimized a nd the finance department will ensure that reimbursement will be timely in due course. 6.3 Area of Focus: Revenue Generation Section16 (1) of the Telecommunications Act of 2006 states that “ The activities of the Commission shall be financed by a fund consisting of – (a) mon eys appropriated by Parliament for the purposes of the Commission; (b) moneys ac cruing to the Commission in the course of its operations, including license fees, fin es and other monetary sanctions imposed by the Commission; and (c) loans obtained from reputable financial institutions .” Furthermore, Section 11A (f) of the Telecommunications Act (Amended) of 2009 states “ by the insertion after subsection (3) of Section 16 of the fol lowing subsection (4) the moneys accruing to the Commission under paragraph (b) of subsection (1) shall be divided as follows: a) One- third for the financing of the activities of the Commiss ion b) One- third for the purchase of equipment and other capital ex penditures, and c) One-third to be collected by the National Revenue Authority and paid into the Consolidated Fund. Therefore, in assessing the implementation of the above pro vision, the following were observed: Findings The table below shows the various revenue streams and respec tive revenue generated for the period according to Commission’s Financial Stateme nt and Budget Analysis:

10. 9 Performance Appraisal The team observed that performance reviews have not been conducted regularly as prescribed in the policy. Performance appraisals must be done regularly as prescribed in the Performance Management Policy to improve staff performance and productivity. Strategic Plan The Review Team observed that was an existing five year strategic plan (2017- 2021) and that the Commission had already commenced the development of the (2022 to 2027) Strategic Plan which was currently in the draft stage. • The Management of the Commission should ensure that activities in the strategic plan (2017-2021) are exhaustive and attained within the time frame. • Also, the draft Strategic Plan should only be operational in the prescribed year. Staff Personal Files /Records The Team observed that most of the staff files examined were without certificates and/or not updated with the necessary information and/or documents The Human Resources Manager must ensure all staff files were regularly updated and all gaps identified by the team are regularized. Organizational Structure The Review Team observed that the Organogram was incomprehensive and limited to few departmental heads. There were a number of departments or offices that were not captured in the Organogram The Commission should immediately review its Organizational structure by separating clustered departments distinctly showing reporting lines. Staff Qualification The Team observed that most staff did not have the required qualification(s) that best suited their position s. The Team also observed that some staff qualifications did not match with the work designated. • The Management and the Board should ensure a comprehensive Human Resource Audit is conducted by the Internal Audit Department. • Moreover, the HR should ensure that all staff should submit their original qualifications for verification. Canteen Services The Team was not provided with any information on the sourcing of contractor for the canteen. More so the Team observed that there was no contract or rather signed MoU between the Canteen Contractor and the Commission. • Management should ensure that the proper procurement procedure in the sourcing out of contractors for the canteen is applicable. • Furthermore, a MoU and/or contract must be prepared and signed by both parties (The Commission and the Canteen Management) to ensure smooth running of business.

11. 10 6 FLEET AND FUEL MANAGEMENT Fleet Lack of comprehensive Fleet Data and Database Management Accountable tools such as logbooks, Vehicle Movement Register, Vehicles Request Form etc, were not maintained. The Senior Driver and Supervisor Transport and Estates had no control on the movement of drivers and vehicles. Also, he had no formal training in Fleet Management • Accountable tools such as Logbooks, Vehicle Movement Register/Tracking System, Vehicle Request Form, Maintenance Reporting Template etc. should be developed by the Fleet officer and be operational at all levels of the Commission. • The fleet officer should ensure that files are maintained for vehicles. • A credible data base of all automobiles under the purview of Commission should be developed, and regularly updated. • The Commission should ensure that a policy and/or contract be established with garage(s) through the Legal Department. Fuel Management it was observed that no technical knowledge was used to determine the quantum of fuel a vehicle or motorbike can consume per kilometer covered We noted that there was no fuel reconciliation report with fuel suppliers on fuel allocation to the Commission. Also, no fuel reconciliation report was provided to the Team with regards the usage of fuel by the Commission. There was no policy on fuel allocation. • The Management of NATCOM should ensure that a policy of fuel management is established. • There should also be a framework Contract agreement between the supplier and the Commission With regards the supply of fuel and that should be in line with the procurement regulations. • The Commission should ensure that there is a regular reconciliation of fuel so as to establish the reorder level of stock, usage and balance. • The officer is charge of fuel should be trained. • Management should embark on the modern-day fuel dispensation by initiating the electronic chit system (Tom Card) for staff and the Commission at large.

20. 19 Findings • The review team was provided with the internal audit reports for some provincial offices. • We observed that whilst these reports contained findings, w e did not see any correspondence requesting officers /department to respon d to the findings in the report. They failed to answer queries, in addition no holistic and/o r comprehensive annual internal audit report of NATCOM for the periods under review was provided for examination. Implications • Failing to conduct internal audit and provide internal audi t reports will render the Commission to be unable to assess controls and risks and take corrective measures. • Also, failure to provide responses to queries will undermin e efforts to ensure internal controls measure as a result, weaknesses will remain unreso lved. Recommendations • The Management of NATCOM should ensure that regular and/or h olistic (quarterly, annually) audit of the Commission are conducted. Moreover, the Internal Audit department should conduct comprehensive audit inclusive o f all operational areas for a better Internal Control and risk mitigation. • The Management should also, ensure that all audit reports an d audit queries therein are acted upon and addressed. Management Response Noted. 4.5 External Audit An External Audit is an independent examination of the finan cial records prepared by an organization. The main objective of an External Audit is to v erify that the accounting records for a company provide a true and accurate picture of t he organization’s finances and financial statements are prepared in accordance to the s et laws and accounting standards. External Audits also add value by identifying ar eas where efficiency in the business can be improved and where controls and processes ma y be made more effective. Section 17(2) of the Telecommunications Act 2006 states that “ The books of account kept under subsection (1) shall within t hree months after the end of each financial year, be audited by the Auditor-General or an auditor appointed by him .”

57. 56 9.9 Canteen Services A canteen is a restaurant provided by an organization for its staff. Findings • The Review Team observed that the Canteen started operation s in the early years of the existence of the Commission. The first contractor that m anaged the Canteen services left and a new one was contracted. • However, the Team was not provided with any information on th e sourcing of contractor for the canteen. More so the Team observed that th ere was no contract or rather signed MoU between the Canteen Contractor and the Com mission. • The Review Team also observed that food and drinks were sold t o staff at the Canteen yet; the Canteen Management never paid any overhead cost for usage (rent) and/or energy supply. • There were also reports of delay in making payments (debtors ) to the canteen Management for food supplied to staff members. Implications • Not having a legally binding document and/or MoU specifying detailed responsibilities and obligations could lead to misunderstanding and /or poss ible disruption in the operation of the canteen services. • Either party can abruptly resort to taking any action that wo uld not be convenient to the other party at any time without notice. Recommendations • Management should ensure that the proper procurement proce dure in the sourcing out of contractors for the canteen is applicable. • Furthermore, a MoU and/or contract must be prepared and sign ed by both parties (The Commission and the Canteen Management) to ensure smoot h running of business. • Finally, Management should ensure that debtors (staff) pay on time and /or amount owed be deducted at source and paid to the management of cante en. Management Response Recommendation is noted and action will be taken accordingl y.

37. 36 example, cheques were drawn in the names of Office Assistant s and /or a dispatch for withdrawals from the Bank of Sierra Leone for payment for wor kshops and honorarium. The table below gives example of cheques drawn in the names of dispatcher(s): The Review Team further observed that cheques for the paymen t of suppliers were drawn in the names of staff also. Some payment vouchers inspe cted, showed cheques were drawn in the name of the dispatcher rather than in the nam e of the contractor, supplier or Individual. Implication The risk involves in writing chegues in the name of a person wh o have no bearing with that transaction is very high and there could be a tendency of cheque fraud. This will involve breach of financial laws and regulations and hence t he tendency of implied fictitious transactions or shady deals. Recommendation
All payments should be done in line with best practices and al so financial laws and regulations.
For activities which would require cash disbursement such a s retreat or honorarium, cheques should be writing in the name of the Contractor and de posited in his/her account. If payment should be made cash, then an officer from the Finance Department should be bearer of the cheque. • Furthermore, the Finance Department should desist from wri ting cheque in huge sums payable to an office assistant and/or dispatch. Date Payment Voucher Number Description Cheque drawn in the Name Cheque Number Amount Le 31/1/19 14595 Payment IRO retreat/honorarium in BO at J & E Hotel Dispatcher 00098778 37,400,000 31/1/19 14594 Payment iro Retreat/honorarium Dispatcher 00098777 50,000,000 12/12/19 13329 Payment for the use of Miatta Conference Centre for the launching of regional free roaming service. Dispatcher 00118692 6,000,0000

39. 38 may result in additional cost to the Commission as these accr uals may attract penalties and fines. • The observed weakness to properly account for withholding t axes deducted from suppliers raises corruption concerns. Recommendation(s) • The Management should establish an effective tax managemen t mechanism by having a designated person within the Account Department to conduct monthly analysis and ensure prompt payment of all taxes and statutor y contributions. • This person should also ensure that all withholding taxes ar e properly accounted for and paid. Subsequently all suppliers should be provided wit h proof of payment to enable them to set off their withheld tax against their annua l tax obligations. Management Response • All the liabilities NATCOM owed to NRA and NASSIT has been pai d in full for 2019 & 2020 and the receipts are available for inspection. Proper records are kept and analyzed monthly for PAYE, withholding tax and NASSIT are th ey are available both on excel and QuickBooks. • We have an effective tax management system and designated st aff members assigned to perform this function. • We have printed withholding tax receipt books and we have bee n issuing them out to suppliers. In the future, we will ensure prompt payment of the tax liability. 6.6 Fixed Assets Register Finding • The Fixed Asset Register should contain list of Fixed Assets of the Commission recorded by name, Asset serial number, description, locati on, purchased date, price, Asset code etc. • The team observed that the Commission does not maintain a fix ed Assets Register as the document presented was a listing of assets which did no t reflect fixed assets registered. • The listing provided was not exhaustive as tangible assets s uch as land and buildings were not stated on the list. • The Review Team also observed that most of the assets of the Co mmission were not coded.

81. 80 • A letter dated 3 rd December 2018 from the Permanent Secretary of the Ministry o f Information and Communications referencing UADF request f or a loan of Le545,772,535.12 (five hundred and forty-five million sev en hundred and seventy two thousand five hundred and thirty five Leones twelve cents) f rom NATCOM. • According to the letter, it was stated that “ the Ministry’s no objection to provide the said soft loan to augment their operations. Furthermore, th e Ministry will be repaid by UADF with a payment plan as soon as modalities have been put in place for service provider to commence payment to the funds pursuant Sector 13 of the Telecommunications Act 2006.” • On the 18 th December 2018, a loan repayment agreement was signed by UADF ’s management, undertaking to make a monthly payment of Le20,0 00,000 (Twenty Million Leones) to NATCOM effective February 2019.  The Review Team observed that the loan repayment agreement w as prepared by UADF instead of NATCOM.  The Review Team could not identify any member NATCOM being pa rt of the agreement as signatory.  The amount stated as monthly repayment was too small because it would take UAFD over five years before the loan was fully repaid, even if they had honored their agreement. • On the 17 th January 2019, another letter was sent by UADF notifying NATC OM stating that “ due to the delay in the processing of the Cabinet Resolution P aper, to determine the percentage of payment to be levied on the Globa l Systems for Mobiles Operators (GSM) and ISPs (Internet Service Providers), we w ill not be able to meet the terms of the payment agreed until there is a Cabinet resol ution on the percentage to be paid.” • It was observed that in the books of NATCOM, the amount had bee n initially treated as long-term loan in their Balance sheet but due to the non-pa yment of the loan by UADF, the loan amount was now treated as an expense. The Revie w Team did not set eyes on any correspondence from NATCOM reminding UADF of their obligations as it was a debt. • No evidence was provided to show approval from the Board for t he granting of the loan and the writing off of the loan as bad debt.

88. 87 • There were no qualified Engineers to lead the monitoring or s urveillance process in all the zonal office. • Monitoring or outreach activities were conducted using eit her petty cash or own resources of staff. Implication • Lack of mobility limits full coverage as well as pose serious strain on staff including the associated risk of useful commercial motorbikes • Lack of equipment that leads to sub official output and leave s the office at the mercy of those who may not want to be with the system. • Diverting petty cash from its intended use to core budgeted a ctivities is an unhealthy financial practice. It is even worse when staff to use their o wn resources to fund the office activities. Recommendations • Management should ensure that Regional Offices are adequat ely funded and staff. • Regional Offices should provide comprehensive reports on a ctivities and funds utilized. Management Response Recommendation is noted and action will be taken accordingl y. 15.4 Regional Office Fuel and Petty Cash Findings • A flat sum of Le5,000,000 was given as petty cash to every Regi onal Office and was supposed to be replenished after 85% being utilized. The Tea m observed that there were delays in the replenishment by HQ. The petty cash were mo stly managed or controlled by the zonal heads or appointees as there were no a ccount officers deployed in these offices. • The sum of Le5,000,000 was also provided to the zonal heads fo r onwards, transfer to fuel dealers of their choice who would then supply the fuel fo r the official quota of 36/45 liters per person per week and 45 liters for generators. No fr amework contractual agreement between the fuel dealers and NATCOM. There was als o a reported delay in the replenishment process. • Fuel chits of fuel supplied shown to the Review Team were not s igned and all copies including the duplicates were kept by the offices.

51. 50 Implications Without a good job description, it becomes very difficult fo r an employee to know what is expected of him and for a manager or supervisor to provide an a ccurate and effective job performance evaluation or appraisal. Recommendations • The Human Resources Department should ensure that there are properly drafted job descriptions for every position in the Commission. • The Department should further ensure that all staff members of the Commission are issued with the appropriate job description. Management Response Recommendation is noted and action will be taken accordingl y. 9.3 Records Management Findings • It was observed that records were mostly maintained in soft c opies. Hard copies were difficult to come by or access. There was no observed back up m echanism for digitized records. • It was observed that there was no approved records managemen t policy or mechanism in place. Implications • In the absence of hard documentations to support the records management system, there was a greater risk of fraud and system failure or crash. • The Commission should also note that there were statutory re quirements to maintain certain documents over a certain period of time. Recommendations • Management should develop a records management policy for t he Commission. • Whilst it is laudable for the Commission to attempt to digiti zed its records management, however it must be properly done taking in consideration fra ud and security concerns, preservation and authenticity of records • Records Management Policy of NATCOM should clearly include the retention of hard copy documentation over a certain period of time and also to e nsure that the hard copy documentations are consistent with the soft copies.

87. 86 • Management should develop dispute resolution mechanism fo r staff members. All disputes amongst staff members that affect operations of th e Commission should be investigated and appropriate actions taken. • Management should ensure all employees possess the requisi te skills and qualifications for the positions held. • Contractual staff contract terms are addressed as prescrib ed in the contract. • Staff movement are properly monitored and communicated. Management Response Recommendation is noted and action will be taken accordingl y . 15.2 Budgetary Support to the Regions It was observed that even though Regional Offices periodica lly submitted activity plans and cost to Head Quarter, these plans were not funded. The work of these zonal/ district offices required extensiv e mobility but there were no means for official mobility because there were no motorbike or vehicles to undertake activities such as monitoring and public education. Implication Lack of funding for activities militate against the actuali zation of an organization’s overall objectives. Recommendations • Management should ensure that regional offices are adequat ely funded. • Regional offices should provide comprehensive reports on a ctivities and funds utilized. Management Response Recommendation is noted and action will be taken accordingl y. 15.3 Monitoring, Surveillance and Outreach Activities Monitoring, Surveillance and outreach are the key operatio nal activities of the regional offices. The essence of these offices hinges on successfull y undertaking these activities. Findings • The Team observed that the zonal offices had no equipment to b e able to surveillance the air waves.

15. 14 1.0 INTRODUCTION The Anti-Corruption Commission (ACC) was established with the primary aim to prevent, investigate and prosecute corrupt offenders and to also pro vide accurate information to the general public on the dangers of corruption in our society. T he preventive aspect of the ACC is provided for in Section 7 and 8 of the Anti-Corruption Act o f 2008 as amended. The ACC secured funding from the Open Society Initiative for West Africa (OSIWA) to support the operations of the Commission. Part of the suppor t was used to conduct the systems review of the National Telecommunication Commissi on (NATCOM) Sierra Leone. The review conducted identified areas of weaknesses in the m anagement and operations of NATCOM. However the review proffered recommendations that is geared towards preventing corruption and improving on service delivery. The National Telecommunications Commission (NATCOM) was e stablished by an Act of Parliament in 2006 to regulate the Sierra Leone telecoms sec tor, protect consumer interest and ensure fair competition among service providers. Since its establishment, the Commission crafted a strategi c direction/plan that clearly stated its Mission and Vision to surmount the various challenges in the telecoms industry. The major policy direction of the Commission was the establi shment of an effective, sound and dynamic licensing regime that was responsive to the indu stry’s demands; and the regulation of the activities of telecoms operators aiming a t promoting efficiency and fair competition; ensuring expansion in investment in the secto r; and adopting rules and procedures that guarantee and protect the rights of users of telecoms services. The report of the review highlights findings, recommendati ons and management responses. The recommendations contained therein will be monitored fo r implementation compliance. 2.0 OBJECTIVES The following are the objectives of the review: • To promote efficiency and improve service delivery; • To improve ethical behavior in the organization; • To improve performance measurement and create good governa nce in the Organization; • To ensure that management policies, procedures, practices , and processes are followed; • To strengthen the Internal Controls System of the Commissio n; and • To monitor the implementation of the review recommendation s.

38. 37 Management Response The finance unit will desist from such practice going forwar d. 6.5 Withholding Tax Payment (WHT), NASSIT Contribution & PA YE Section 117 of the Income Tax Act 2018 mandates a 5.5% withhol ding Tax Payments to contractors/ or suppliers to be deducted at source of income . Findings • It was observed that withholding tax deduction of 5.5% was ma de from payments to various suppliers as prescribed by Law. • However, the Review Team were not presented with any evidenc e of monthly analysis of withholding tax payments made to NRA and receipt or certificate of payment presented to suppliers. • It was observed that an accrued amount of Le1,849,704,567.06 (One Billion Eight Hundred and forty-Nine million, seven hundred and four thou sand, five hundred and sixty-seven Leone and six cents) of Withholding tax deducti ons had not been paid to NRA. • It was also observed that there were also accruals for NASSIT contribution of Le2,648,819,970.18 (two billion six hundred and forty-eight million eight hund red and nineteen thousand nine hundred and seventy Leone eighteen c ents), and PAYE Le12,057,460,130 (twelve billion and fifty-seven million four hundred and si xty thousand one hundred and thirty Leones). • However reviewed document showed that on the 16 th of June 2020, the Ministry of Finance (MoF) agreed to pay all debts owed by the government o f Sierra Leone to NATCOM totaling Twenty-nine Billion and Fifty-Two Million Two Hundred and Forty- Seven Thousand One Hundred and Seven-Five Leones Sixty-Thr ee Cents ( Le29,052,247,175.63 ) for services rendered to the GoSL. In this agreement, the MoF was to pay (set off) the liabilities of NATCOM with respec t to NASSIT and NRA against government’s debts. Implications • The huge amount of accrual of tax liabilities and other statu tory payment indicated weaknesses in the way the Commission managed its tax liabili ties. Such weaknesses

17. 16 Section 143(2) of the PFM-regulation 2018 stipulates that “ The Internal Audit Unit established within a Budgetary Agen cy, Sub-vented Agency, other entities of government, Local Councils, social secur ity fund, or public enterprise shall operate in accordance with the operational procedure s outlined within the Internal Audit Manual and other guidance provided by the Internal Aud it Department of the Ministry ”. Findings The team was provided with an Internal Audit Manual which was not comprehensive and detailed in line with Professional Standards and Best Pract ices. The following were some of missing contents within the manual: • Objective • Mandate • Audit Planning • Audit Framework • Responsibilities of Audit Staff • Internal Controls to Risk Management • Audit Committee, Composition and tenure • Template on Audit report, risk alert form, assignment sheet , annual audit plan etc. Implications • A non-comprehensive Internal Audit Manual will affect the p rofessional guidance, tools and information for managing, planning, conducting and rep orting on internal audit work. • Also, the non-comprehensiveness of the Internal Audit Manu al affects the quality and usefulness of the Internal Audit Department by preventing t hem from adopting practices, procedures and processes that would help them conform to pro fessional standards and best practices. Recommendations The Management of NATCOM should ensure that a comprehensive and adequate Internal Audit Manual is produced to facilitate the smooth functioni ng of the department. Management Response A comprehensive Internal Audit Manual will be instituted as its on working progress.

53. 52 STAFF NAMES STAFF LIST PAYROLL Abdul Dumbuya Abdulai Dumbuya Mamadi K Kamara Mamadie F Kamara Yankuba Nyallay Yankubu Nyallay Sheikh Swaray Deen Sheikh Alieu Swaray-Deen Kalilu Massaquoi Kalilu P. B. Massaquoi Ruth Konah Feika Ruth Feika Amiru K. Dabor Amiru Dabor Salamatu T. Chakanda Salamatu Tutu Fonti-Kanu Foday Kanu Foday Thomas Kanu The Review Team observed that there were no mechanisms in pla ce to ensure regular audit and reconciliation of pay roll and staff list of the Com mission. Implications Variances and discrepancies of such nature may be an indicat ion of payroll fraud and also misuse and /or misappropriation of company’s resources. Recommendations There should be regular review and reconciliation of pay rol l and staff list by the HR Department. The Internal Audit should conduct an audit on Human Resource s and payroll. The variances or inconsistencies should be regularized in orde r to save cost. Management Response The inconsistency between the payroll and staff list has bee n regularized. The internal audit on HR and Payroll exercise/activity has now been incor porated into the Admin and HR departmental yearly activity plan as this will ensure pro per compliance with SOP. 9.5 Staff Attendance Register Findings • The Commission was operating a Biometric system of staff att endance which was a good endeavor as it prevented human interference. Due to the Covid outbreak, the system was put on hold and manual recording was reintroduced .

58. 57 10.0 FLEET AND FUEL MANAGEMENT 10.1 Fleet According to NATCOM’s policy on the “Procedures and pattern s on the use of Commission vehicles” it states “During normal working days and hours within, any official wishing to use a Commission vehicle must fill out a v ehicle form which is in the custody of the Senior Driver and Supervisor Transport and Es tates”. The review exercise revealed the following: • Lack of comprehensive Fleet Data and Database Management. T he document provided to the Team could not speak of the status and locatio ns of fleet. • Accountable tools such as logbooks, Vehicle Movement Regis ter, Vehicles Request Form etc, were not maintained. In fact, the vehicle movement register maintained at the security post only records outward movement of vehicles and no record of return. Most of the audio meters on the vehicles were out of order. • Accountability tools such as Maintenance Forms, Reporting Template and routine maintenance schedule for each automobile were not availabl e at the time of the review. Vehicles were repaired at Petco Garage and Abu Marg G arage. No contract document and/or policy were provided to the Team with regard s maintenance of the Commissions’ fleets. • The Senior Driver and Supervisor Transport and Estates had no control on the movement of drivers and vehicles. Also, he had no formal trai ning in Fleet Management. • The entire fleet of the Commission are as follows: • No information was provided to the Team with regard boarding vehicles. • No fleet inspections check list or Standard Operating Proce dures was provided. The Review Team observed that there was no vehicle request form. Requests were made verbally to the Transport Officer without any document ation (vehicle request form) of the movement to be made. Fleet Number Status Vehicles 16 Road worthy Motor bikes 1 Road worthy Generator 9 Working Vehicle 5 Faulty

83. 82 Implications • Converting the loan into an expense (bad debt), without just ification was a bad economic/financial practice which had the tendency to impa ct negatively on the company’s financial status. • Additionally, the manner in which the transaction took plac e looked very shady. It would be considered as an insider dealing and/or related par ty’s transaction. Recommendation • The Management of UADF should embark on a nationwide public e ducation. • Moreover, since a percentage has been determined as stipula ted in the Regulation, the legal department of NATCOM should prepare a payment plan in addendum to the previous payment plan prepared by UADF. The contract sho uld be inclusive of both parties. • Also, the Management of UADF should effect a penalty clause o n defaulters as stated by Section 7(3a) of the regulation. • The Management of NATCOM should stop treating the item as exp ense but rather a long-term loan as there was an agreement of repayment. • There should be a comprehensive loan policy • The Internal Audit department should conduct a full-blown i nvestigation on the entire loan process. Management Response • NATCOM will encourage UADF to engage the public more effecti vely. • A payment plan will be prepared by NATCOM with (inclusive par ties) to address this issue. • NATCOM will ensure a penalty clause be included in the contra ct to enforce payment. • NATCOM will review the loan agreement and revise treatment o f this as an expense and considered treating it as a long-term loan. • NATCOM will develop a loan policy • The Internal Audit department will conduct a comprehensive investigation on the loan process and will revert to Management for appropriate actio n. 14.0 PROJECT MANAGEMNT NATCOM commenced a building project situated at South Ridge – IMATT in February 2016 and consulted TS & Co. Consortium and contracted Intern ational Construction Company.

86. 85 • There were Regional /District Outreach Coordinators on con tracts. We observed that the contracts agreements for most have expired for over six mont hs without it being renewed or extended. However, these individuals continued to work without any proper employment contract. • We observed poor working relationships between some staff m embers which had affected checks and balances and the smooth running of the of fice. For example, at the Makeni office rift between the supervisor and GSO resulted i n the supervisor refusing to sign petty vouchers. • We also observed weak supervision of staff by the HR Departme nt. For example, in Kono, the Review Team could not track particular personnel. • The Review Team was told that this person was supposed to reli eve the supervisor at Port Loko between the periods of 21 st October 2021 – 24 th November 2021. • However, he neither reported for duty in Port Loko nor in Kono nor receives salary for such periods. Implication • The risk of abuse of office was high in situations where a sing le individual was in charge of everything especially financial control. • Lack of specific job descriptions would create the avenue fo r some staff to be overused while others idle by particularly those favoured by the boss . • Square peg in round holes breed poor performance for the admi nistration. • Working without a binding contract and getting paid was cont rary to law and could also lead to demotivation. • Absenting from duty showed lack of disciplinary measures to ensure effective human resource control over staff. Recommendations The Management of NATCOM should ensure that: • Adequate administrative structures are established at pro vincial offices to ensure adequate checks and balances. • Job descriptions are given to all staff inclusive of GSO. • Staff members should be proportionately distributed to the regions depending on work load and area covered.

48. 47 2020 Activity Budget Le A Actual Le B Variance Le C = (A-B) % Variance D = (C/A)*100 % Budget E = 100-D Payment vouchers verification F Variance between Actual and payment vouchers G = B - F % difference actual and payment vouchers H= (G/B)*100 Support to National Development 5,828,428,782.84 2,907,575,900.00 2,920,852,882.84 50% 50% 2,046,242,070.00 861,315,830 30% Public Relations and Outreach 1,195,726,833.15 375,110,000.00 820,616,833.15 69% 31% 375,110,000.00 0 0% Security services 131,117,739.84 717,870,000.00 (586,752,260.16) -81% 181% 577,220,875.00 140,649,125 20% Fraud management and cyber security 801,750,000.00 1,184,800,000.00 (383,050,000.00) -48% 148% 1,184,800,000 0 0

84. 83 Section 2(1) Public Debt Management Act 2011 states that” Su bject to section 118 of the Constitution, the Minister shall have sole authority to bor row money on behalf of Government by concluding loan agreements, issuing Governm ent securities, or entering into supplier’s credit agreements and to issue Government g uarantees, both in Sierra Leone and elsewhere and in local and foreign currencies”. On 25 th March, 2020 NATCOM applied for the loan of Le50bn (fifty bill ion Leones) from Sierra Leone Commercial Bank (SLCB) through the Ministry of Information and Communications and the Ministry of Finance for the primary p urpose for the completion of the NATCOM building. On 27 th March, 2020, the board of Commissioners unanimously resolved to secure funds in order to complete the project as a matter of priority. NATCOM Capital Development Account was opened at SLCB and a l oan of Le50bn was approved and subsequently credited into the account on five installment payments from September 2020 to September 2021 with an interest of 18% for a period of 36 months. NATCOM issued a standing order to the BSL to debit its disburs ement account and credit the NATCOM Capital Dev. Account on a monthly basis with Le 1,5 00,000,000 (One Billion, Five Hundred Million Leones) to meet the required debt servi ce payment until the loan is amortized. Standing Order is to be credited to NATCOM Capita l Development Account on or before 24 th of every month. There has been delay and as a result interest i s levied on the loan amount. Due to the delay, interest on Loan has accrue d into billions. Moreover, BSL could not honour such due to insufficient funds to meet th e standing order. Below is the breakdown of the schedule of payment to internat ional construction company (ICC): Type Date Memo AMOUNT Deposit 10/09/2020 Loan IRO Building Project from SLCB 9,868,610,000 Deposit 30/10/2020 Loan iro of new building 2nd installment 9,868,610,000 Deposit 24/12/2020 Loan iro of Building project 9,868,610,000 Deposit 30/04/2021 payment in respect of building project 9,585,170,000 Deposit 22/09/2021 Long term loan iro building project final credit 10,809,000,000 TOTAL 50,000,000,000

44. 43 Activity Budget Le Actual Le Variance Le % Variance Income 182,886,631,000.00 165,191,546,155.53 17,695,084,845 10% Expenditure 190,795,737,176.60 168,071,795,754.19 22,723,941,423 1 2% Gross profit/(Loss) (7,909,106,176) (2,880,250,599) (10,789,356,775) -36% The table above shows summary of budgeted income and expendi ture as against actual income and expenditure for the FY 2019. Actual income was low er than planned. There was an unfavorable income variance of Le7,695,084,845 i.e. 10 % shortfall of the budgeted income. The table also shows that the actual expenditure was lower th an anticipated. There was a favorable variance of Le22,723,941,423. i.e.12% less of p rojected expenditure. Column three of the table reveals that the actual expenditur e was higher than the actual income for the year. There was a gross loss of Le2,880,250,599 (two billion eight hundred and eighty million two hundred and fifty thousand five hundred and ninety-nine Leones Additionally, a comparative analysis between the Budgeted income and expenditures as against the Actuals for financial year 2020 is shown thus: Activity Budget Le Actual Le Variance Le % Variance Income 250,413,929,165.41 148,583,288,059.53 101,830,641,105.88 41% Expenditure 224,174,032,252.33 156,755,556,574.51 67,418,475,677. 82 30% Gross profit/(Loss) 26,239,896,913.08 (8,172,268,514.98) 34,412,165,427 31% The above shows a comparative analysis of budgeted income an d expenditure as to actual income and expenditure. Like 2019, Actual income generated in 2020 was lower than pla nned. There was an unfavorable income variance of Le101,830,641,105 i.e. 41 % shortfall of the budgeted income. The variance was greater than the variance in 2019.

47. 46 The above table shows the irregularities and/or inconsiste ncies in reporting actual amounts of expenditures as compar ed to total amounts on vouchers with respect to each activity stated. The differen ces in column (G) show the unaccounted amounts (variances) b etween the actuals and the payment vouchers. Also, column H shows the percentag e differences of the unaccounted amount. In essence, the tot al amounts in the vouchers could not match up with the actual amounts recorded in the Income statement . Activity Budget Le A Actual Le B Variance Le C = (A-B) % Variance D=(C/B)*100 % Budget E = 100-D Payment vouchers verification F Variance between Actual and payment vouchers G = B - F % difference actual and payment vouchers H= (G/B)*100 Support to National Development 6,500,000,000.04 7,005,057,604.38 - 505,057,604.34 -8% 108% 6,071,845,971.53 933,211,632.77 13% Workshop and seminar 1,809,699,999.96 1,683,494,591.30 126,205,408.66 7% 93% 1,683,494,591.30 0 0% Public Relations and outreach 2,082,999,999.96 1,856,697,592.00 226,302,407.96 11% 89% 615,920,000 1,240,777,592 69% Fraud management and cyber security 1,536,000,000.00 1,385,606,500.00 150,393,500 10% 90% 1,389,206,500.00 -996,400,000 26%

70. 69 21 Procurement of Football Kits 40,813,500 RFQ 3rd December, 2019 22 Drilling of borehole at Kenema Government Hospital 176,500,000 RFQ 12 December, 2019 23 Procurement of computers, printers and accessories 981,557,732 NCB 20 November, 2019 24 Insurance 261,231,282.84 6 December, 2019 25 Procurement of Goods (Assorted Office Equipment for NATCOM HQ 81,730,500 RFQ 26November 2019 26 Procurement of Good (Assorted Items Needed for Precautionary Health Measures for NATCOM HQ and Zonal Offices) 7,475,000 RFQ 20 February, 2019 27 Procurement of Goods (Replacement of AC Unit at Drives Offices 14,728,500 RFQ 25 March, 2020 28 Procurement of Goods (Door Tags for the Commission) 36,500,000 RFQ 21 February, 2020 29 Procurement of Goods (Laptop for PA to DG & Assistant Manager PRA NATCOM) 64,400,000 RFQ 12 February, 2020 30 Procurement of Goods (Toners Ink Cartridge for DDG, Finance & Engineering 29,440,000 RFQ 10 January, 2020 31 Procurement of Goods (Laptops for Strategic Communications Unit at State House, office of the President) 128,800,000 RFQ 12 February, 2020 32 Procurement of Goods (Toners for Finance Department for the Printing of Budget & Invoices 48,300,000 RFQ 18 November, 2019 33 Procurement of Toners for DG's Printer, Secretary to DG, Procurement Unit Regulatory Affairs and Board Room & Legal Dept. 48,300,000 RFQ 15 November, 2019 34 Procurement of Goods 15 Tire and 1 Battery for the Commission Vehicles 35,535,000 RFQ 29 November, 2019 35 Procurement of Goods Additional Tyres and Batteries 72,162,000 RFQ 12 November, 2019 Grand Total 3,266,283,814.84

71. 70 11.10.1 Works 11.10.2 Services NO CONTRACT DISCRIPTION CONTRACT AMOUNT (Le) PROCUREMENT METHOD RFQ Issue Date 1 Procurement of Services (Clearing of Septic Tanks) 5,700,000 RFQ 1 -10- 2019 2 Procurement of Services (Corporate Ringtone for Media Outreach Events & Staff Caller Ring Back) 6,000,000 RFQ 1-11-2019 3 Procurement of Services Quick Books Accountancy Service for 3 Months 31,800,000 RFQ 15-10- 2019 4 Procurement of Services (Printing of Assorted Office Items) 38,100,000 RFQ 4-11-2019 5 Procurement of Services T Shirt and Caps for the Reopening of Moyamba Zonal Office 10,500,000 RFQ 26 -09-2019 6 Procurement of Services (Printing of T-Shirt, Brochure and Invitation for Regional Free Roaming Workshop 56,500,000 RFQ 20 -11- 2019 7 Procurement of Services (Transportation and Assembling of Goods at the Commission's Zonal Offices 81,007,003 RFQ 4 -11- 2019 8 Procurement of Services Staff Party 97,531,500 RFQ 29 -11- 2019 9 Procurement of Services Washing of the Commission Vehicles for January - March 2020 104,640,000 RFQ 10 Procurement of Services (Décor Services for Cyber Security Workshop 4,600,000 RFQ 6 -12- 2019 11 Procurement of Services (Building of 2 Zinc Structure and Brushing of 21 acres of land at bigwata 110,200,000 RFQ 16 -12- 2019 Grand Total 546,578,503 NO CONTRACT DISCRIPTION CONTRACT AMOUNT (Le) PROCUREMENT METHOD RFQ Issue Date 1 Procurement of Services (Clearing of Septic Tanks) 5,700,000 RFQ 1 October, 2019

35. 34 Revenue Streams 2018 Le 2019 Le 2020 Le GSM Licenses 12,049,298,414.11 35,750,907,847.09 31,808,671,342.83 ISP WIMAX 340,467,408.42 599,261,389.33 1,564,885,667.66 2 Way Radio Amateur/VHF 68,250,000.00 105,299,663.00 95,160,288.00 FM Licenses 124,807,863.15 632,761,729.99 555,063,903.10 VSAT 956,262,168.19 1,158,303,269.86 553,175,141.04 TV Licenses 952,110,351.58 989,649,569.47 675,638,390.00 CDMA International Gateway 32,784,556,998.21 50,139,558,024.85 52,837,868,228.12 Others 379,137,566.26 124,118,750.00 Type Approval 168,027,800.95 365,102,307.08 293,455,202.45 Microwave Link 129,259,899.43 0 207,349,354.40 Fines 0 16,500,000.00 1,362,300,000.00 Local Interconnect 15,248,247,460.29 26,067,622,873.75 1,490,698,218.72 Ship station and Amateur Radio 3,415,603.50 19,229,410.00 2G, 3G and 4G Licenses 66,830,604,154.41 48,697,303,083.61 48,521,843,541.73 Uncategorized Income 1,291,197,571.47 37,556,665.00 42,646,868.00 VHF 135,518,440.60 236,778,634.50 588,102,323.10 Special Numbering Resource 59,200,000.00 2,697,258,380.20 Dealer licensees 9,750,000.00 Call sign 29,260,488.14 Spectrum Resources 3,444,943,734.16 Satellite Phone 4,041,068.00 Royalty Licenses and Resource fees – Others 7,091,607,394.44 251,592,938.00 141,925,529.50 Totals 142,066,662,829.17 165,191,546,155.53 143,469,343,934.99

69. 68 and the greatest chunk of the debts were on the procurement of Air Tickets. The Team further categorized the liabilities of the Commission into four categories (goods, services, works and air tickets) for clarity. Please see list below: 11.10 Goods NO CONTRACT DISCRIPTION CONTRACT AMOUNT (Le) PROCUREMENT METHOD RFQ Issue Date 1 Procurement of Goods Outer Tires for NATCOM Vehicles 58,707,500 RFQ June, 2019 2 Procurement Goods of Electricals Fittings for NATCOM HQ 42,320,000 RFQ 11 October, 2019 3 Procurement of Goods Venetian Blind for Moyamba Zonal Office 30,360,000 RFQ 19November,2019 4 Procurement of Air Conditions (Conference Room) 109,710,000 RFQ 5th April, 2019 5 Procurement of Goods (NATCOM Caps, T- shirts, Teacup & Water Bottle ) 96,000,000 RFQ 15th November, 2019 6 Procurement of Goods Assorted Furniture for the Office of the Director General 28,175,000 RFQ 18th November, 2019 7 Procurement of Goods Christmas Hamper (Super Premium) 197,830,000 RFQ 12November, 2019 8 Procurement of Battery, Outer Tyres, Seat Cover, Floor Mat and Steering gloves 72,162,000 RFQ 12 November, 2019 9 Procurement of Heavy Duty Extension Cable, LG DVD Player and Wireless 9,430,000 RFQ 13 November, 2019 10 Procurement of Goods (Replacement of Air Conditioners) 20,500,000 RFQ 8 November, 2019 11 Procurement of Goods Venetian Blind Moyamba Zonal Office 30,360,000 RFQ 1 November, 2019 12 Procurement of Goods (Calendars’ for 2020) 193,000,000 RFQ 1 November, 2019 13 Procurement of Goods (Office Stationery for NATCOM HQ 25,405,800 RFQ 28 October, 2019 14 Procurement of Goods (Assorted Goods for CTO Conference 76,705,000 RFQ 15 November, 2019 15 Procurement of Goods (Assorted Goods for Recruitment Purpose at NATCOM HQ 73,600,000 RFQ 16 October, 2019 16 Procurement of Goods (Assorted Goods for NATCOM HQ) 45,770,000 RFQ 15 November, 2019 17 Procurement of Goods (10KVA UPS for Saver 51,700,000 RFQ 30 September, 2019 18 Procurement of Goods (3) 6KVA Generators for Newly Opened Zonal Offices Moyamba, Pujehun and Matru Jong 55,200,000 RFQ 7 October, 2019 19 Procurement of Goods for PA System Accessories 9,430,000 RFQ 19 September, 2019 20 Procurement of Drinking water for January to December 2020 for NATCOM HQ 17,620,000 RFQ 16 January, 2020

74. 73 11.10.5 Leone Wing Travel & Tours No Company Amount Le Date Route 1 Leone Wing Travel & Tours 14,900,000 28/8/2019 FnaLfwFna 2 Leone Wing Travel & Tours 34,500,000 18/10/2019 FnaDxbFna 3 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna- Abj-Fna 4 Leone Wing Travel & Tours 14,900,000 28/8/2019 FnaLfwFna 5 Leone Wing Travel & Tours 34,500,000 18/10/2019 FnaDxbFna 6 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna- Abj-Fna 7 Leone Wing Travel & Tours 14,900,000 28/8/2019 FnaLfwFna 8 Leone Wing Travel & Tours 18,300,000 26/11/2019 CkyAbjFna 9 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna- Abj-Fna 10 Leone Wing Travel & Tours 93,730,000 29/8/2019 FnaLhrFna 11 Leone Wing Travel & Tours 107,680,000 28/11/2019 FnaAtlFna 12 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna- Abj-Fna 13 Leone Wing Travel & Tours 6,000,000 1/9/2019 Date Change 14 Leone Wing Travel & Tours 10,000,000 30/11/2019 Date Change 15 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna- Abj-Fna 16 Leone Wing Travel & Tours 93,970,000 8/9/2019 FnaLhrFna 17 Leone Wing Travel & Tours 14,770,000 22/3/2019 Fna- Abv-Fna 18 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna- Abj-Fna 19 Leone Wing Travel & Tours 34,500,000 18/10/2019 Fna Add Fna 20 Leone Wing Travel & Tours 27,000,000 22/3/2019 Fna- Abv-Fna 21 Leone Wing Travel & Tours 28,250,000 20/08/2019 Fna- Abj-Fna 22 Leone Wing Travel & Tours 6,000,000 26/8/2019 Date Change 24 Leone Wing Travel & Tours 6,000,000 26/8/2019 Date Change 25 Leone Wing Travel & Tours 6,000,000 26/8/2019 Date Change 26 Leone Wing Travel & Tours 28,250,000 20/8/2019 Fna- Abj-Fna 27 Leone Wing Travel & Tours 28,250,000 20/8/2019 Fna- Abj-Fna 28 Leone Wing Travel & Tours 28,250,000 20/8/2019 Fna- Abj-Fna Total 743,650,000 The tables above show the various suppliers to whom NATCOM is indebted to, for various services done varying from goods, works and service s inclusive of Airlines tickets. A total of Le3,818,562,317.84 (three billion eight hundred and eighteen million five hundred and sixty two thousand three hundred and sevent een Leones eighty four cents) was indebted by NATCOM to various suppliers for Works , Goods and Services.

72. 71 11.10.3 Air Ticket/Travel Agencies No Company Amount Date Route 1 Angelco Company (Sl)Limited 20,850,000 26/7/2019 LhrCdgLhr 2 Angelco Company (Sl)Limited 54,700,000 8/6/2019 Fna Add Fna 4 Angelco Company (Sl)Limited 20,550,000 13/7/2019 FnaKglFna 5 Angelco Company (Sl)Limited 57,590,000 24/9/2019 Fna Ebb Fna 6 Angelco Company (Sl)Limited 16,170,000 11/6/2019 FnaOuaFna 7 Angelco Company (Sl)Limited 20,550,000 14/07/2019 FnaKglFna 8 Angelco Company (Sl)Limited 29,890,000 24/09/2019 Fna Ebb Fna 9 Angelco Company (Sl)Limited 33,000,000 13/6/2019 FnaLfwFna 11 Angelco Company (Sl)Limited 52,700,000 17/7/2019 LhrFnaLhr 12 Angelco Company (Sl)Limited 57,590,000 2/10/2019 Fna Ebb Fna 13 Angelco Company (Sl)Limited 12,200,000 14/6/2019 FnaDssFna 14 Angelco Company (Sl)Limited 28,700,000 18/7/2019 FnaIadFna 15 Angelco Company (Sl)Limited 26,980,000 6/10/2019 Date Change 16 Angelco Company (Sl)Limited 41,500,000 13/7/2019 FnaKglFna 17 Angelco Company (Sl)Limited 20,850,000 26/7/2019 LhrCdgLhr 18 Angelco Company (Sl)Limited 9,500,000 7/10/2019 Date Change 19 Angelco Company (Sl)Limited 20,550,000 13/7/2019 FnaKglFna Total 23,870,000 11.10.4 Company Amount Date Route 1 Blue Whale Travel Agency 79,890,000.00 31/10/2019 FnaTllFna Total 79,890,000.00 Cinderella Travel & Tours No Company Amount Date Route 1 Cinderella Travel & Tours 34,300,000.00 16/11/2019 FnaDssFna 2 Cinderella Travel & Tours 24,500,000.00 22/11/2019 FnaMpmFna 3 Cinderella Travel & Tours 3,700,000.00 27/11/2019 Date Change 4 Cinderella Travel & Tours 18,750,000.00 16/11/2019 FnaCaiFna 5 Cinderella Travel & Tours 46,500,000.00 22/11/2019 FnaMpmFna 6 Cinderella Travel & Tours 24,500,000.00 27/11/2019 Date Change 7 Cinderella Travel & Tours 18,750,000.00 16/11/2019 FnaCaiFna 8 Cinderella Travel & Tours 67,000,000.00 22/11/2019 FnaSshFna 9 Cinderella Travel & Tours 37,500,000.00 8/12/2019 FnaTunFna 10 Cinderella Travel & Tours 2,000,000.00 21/11/2019 Date Change 11 Cinderella Travel & Tours 12,700,000.00 23/11/2019 FnaAccFna

78. 77 Date Description Requisition Requested by Requisition Approved by Received by Issue requested by Issue Approved by Delivered to Requisition and issue voucher No. 28/7/21 Laser jet pro MFP M477 Josephus Mustapha Not Approved Josephus Mustapha Adeyemi L. Coker Not Approved Engineering 01349 Laser pro MFP M281 IsataGandie Not Approved Isata Gandie Adeyemi L. Coker Not Approved Internal Audit 01349 Laser Pro MFP M281 Musa Y. Sesay Not Approved Musa Y. Sesay Adeyemi L. Coker Not Approved Finance Department 01349 Toiletries Foday Thoronka Not Approved Foday Thoronka SamuraMa nsaray Not Approved General Services A 01349 Laser pro MFP M277 Clementine Y. Sesay Not Approved Clementine Y. Sesay Adeyemi L. Coker Not Approved Director of IT 01349 Laser pro 200 MFP M276m Clementine Y. Sesay Not Approved Clementine Y. Sesay Adeyemi L. Coker Not Approved Marian Yarjah 01349 Laser pro MFP M277 Isha Abdallah Not Approved Isha Abdallah Adeyemi L. Coker Not Approved PA to DG 01349 Laser pro MFP M281 Neimatu Koker Not Approved Neimatu Koker Adeyemi L. Coker Not Approved Director of Admin 01349  Items supplied that were never approved by the issuing depar tment as shown below .  Items supplied that were never approved by the requesting de partment as shown below : Date Description Requisition Requested by Requisition approved by Received by Issued requested by Issue approved by Delivered to Requisition and issue voucher No. 05/07/21 Tyres RS 17 Alpha Mansaray Not Approved Alpha Mansaray Samura Mansaray Ahmid Kannah Alpha Mansaray 01349 12/07/21 100 AMP Battery Mohamed Bayoh Not Approved Mohamed Bayoh Adeyemi Coker Ahmid Kannah Mohamed Bayoh 01349 12/07/21 Toiletries Mohamed Kamara Not Approved Mohamed Kamara Adeyemi Coker Ahmid Kannah Weekly G8 01349 05/07/21 Stationery Josephus A. Musa Not Approved Josephus A. Musa Emmanuel V. Foday Ahmid Kannah Engineering Dept 01349 Date Description Requisition Requested by Requisition approved by Received by Issue requested by Issue approved by Delivered to Requisition and issue voucher No. 23/6/21 Tyres R7 For Toyato Prado Lamin F. Kanneh Brima Kargbo Lamin F. Kanneh Samura Mansaray Not Approved DG’s Office 01349 27/5/21 Vehicle Tyre 195 R15 Mustapha Jah Ahmid Kannah Mustapha Jah Adeyemi L. Coker Not Approved Mustapha Jah (Senior Driver) 01349

73. 72 12 Cinderella Travel & Tours 14,500,000.00 9/12/2019 FnaAccFna 13 Cinderella Travel & Tours 2,000,000.00 21/11/2019 Date Change 14 Cinderella Travel & Tours 12,700,000.00 23/11/2019 FnaAccFna 15 Cinderella Travel & Tours 14,500,000.00 9/12/2019 FnaAccFna 16 Cinderella Travel & Tours 24,500,000.00 22/11/2019 FnaMpmFna 17 Cinderella Travel & Tours 3,700,000.00 27/11/2019 Date Change 18 Cinderella Travel & Tours 89,500,000.00 19/12/2019 FnaLhrFna 19 Cinderella Travel & Tours 33,500,000.00 15/11/2019 Fna Add Fna 20 Cinderella Travel & Tours 21,300,000.00 24/1/2020 FnaNboFna 21 Cinderella Travel & Tours 109,550,000.00 27/9/2019 FnaDacFna 22 Cinderella Travel & Tours 21,300,000.00 24/1/2020 FnaNboFna 23 Cinderella Travel & Tours 89,350,000.00 29/10/2019 FnaSshFna 24 Cinderella Travel & Tours 62,390,000.00 11/6/2018 FnaXnbFna 25 Cinderella Travel & Tours 27,500,000.00 6/10/2019 FnaRaiFna 26 Cinderella Travel & Tours 18,923,000.00 1/5/2019 LhrFnaLhr 27 Cinderella Travel & Tours 59,300,000.00 10/11/2019 FnaCptFna 28 Cinderella Travel & Tours 47,350,000.00 18/9/2019 FnaIadFna 29 Cinderella Travel & Tours 33,530,000.00 10/11/2019 FnaJnbFna Total 975,593,000.00 Omed Travel and Tours No Company Amount Date Route 1 Omed Travel And Tours 2,000,000.00 2/12/2019 Date Change 2 Omed Travel And Tours 78,720,000.00 3/8/2019 FnaLhrFna 3 Omed Travel And Tours 97,500,000.00 4/9/2019 Fna Bud Fna 4 Omed Travel And Tours 2,000,000.00 2/12/2019 Date Change 5 Omed Travel And Tours 78,720,000.00 3/8/2019 FnaLhrFna 6 Omed Travel And Tours 91,550,000.00 5/9/2019 Fna Bud Fna 7 Omed Travel And Tours 37,000,000.00 30/11/2019 FnaEwrFna 8 Omed Travel And Tours 47,500,000.00 28/8/2019 Fna Bud Fna 9 Omed Travel And Tours 27,800,000.00 20/11/2019 FnaAccFna 10 Omed Travel And Tours 135,000,000.00 30/11/2019 FnaAtlFna 11 Omed Travel And Tours 41,500,000.00 4/9/2019 Fna Bud Fna 12 Omed Travel And Tours 12,900,000.00 21/11/2019 FnaAccFna 13 Omed Travel And Tours 12,900,000.00 21/11/2019 FnaAccFna 14 Omed Travel And Tours 3,900,000.00 26/11/2019 Date Change 15 Omed Travel And Tours 59,850,000 2/8/2019 FnaKglFna 16 Omed Travel And Tours 59,850,000 2/8/2019 FnaKglFna 17 Omed Travel And Tours 41,500,000 4/9/2019 Fna Bud Fna 18 Omed Travel And Tours 41,500,000.00 4/9/2019 Fna Bud Fna Total 871,690,000.00