55. 50

1. i 3

54. 49 17.0 CONCLUSION The Review highlighted systemic challenges and proffered recommendations. It is hoped that the new Management will implement these recommendations in order to address these systemic challenges. However, it is prudent for the new Management to have training on ethics and integrity for st aff of the Hospital. It is also mandatory pursuant to Section 8, that institutions should comply with the instructions of the Commission, failing which the relevant compliance sanctions as contained in the Anti - Corruption Act 2008 as amended in 2019 would be invoked.

2. ii

49. 44 being discussed and agreed collectively as Management. A case in point was the allocation of drugs weekly to Wards. In most instances also, issues/matters or information that border on the general staff are not cascaded or com municated by the Management to staff regularly. For instance, the Outreach was unaware of support to the Hospital by MOHS until when he was told in the DHMT meeting months gone. Moreover, it was observed that communication method was mostly verbal and not documented in the forms of emails, memos, circulars, etc. This is very essential for purposes of referencing when questions are asked in relation to what informed or which decision resulted in the implementation of programs and activities that make it jus tified, procedural and/or legitimate. In fact, the official mode of communication to convey management decisions/positions that will affect programmatic issues within an organization or entity is through memos, circulars etc. Verbal communication cannot be reliable and substantive. Also, the organization lacked a communication manual or policy which guides the flow of communication with the in internal and external publics. 16.2 Implication Staff are in difficult situations when communication lines are unclear. Inaccurate information will be peddled. Information not meant for the public will be disclosed in an unconventional manner. 16.3 Recommendations The Hospital is seen as an entity that prides itself in maintaining the integrity and confidentiality of patient information. It is therefore recommended that, a clear and instructive mode of communication from the German Doctors to the Hospital Management and the staff and the general public to always be in either emails, memos or other forms of acceptable formal communication with the Catholic Diocese of Bo copied therein. The obverse is

15. 10 of its funding for the Serabu Hospital only, it will end its cooperation with the Catholic Diocese of Bo, on 1st August, 2021. This would have dire consequences on the people of Serabu and its environs. The Serabu Community Hospital is located in a rural area, in the Bumpeh Ngao Chiefdom, Bo District and is the only medical facility available for about 50,000 people in that community and its environs. German medical specialists treat patients there and train skilled native medical personnel. Sierra Leone’s clinical health workers are trained in this hospital to later be able to provide medical care independently. The most important task is to lower the maternal and child mortality. The medical priorities are obstetrics, infections, surgical emergencies, and, increasingly, chronic internal diseases. The Serabu Community hospital consists of an emergency ward, an outpatient clinic, and inpatient wards, which are divided into wards for women, men, children, and a postnatal ward with a total of about 250 hospital beds. The German Docto rs have officially declared that they will cease supporting the hospital on the 2nd of August 2021 or with conditions met it will be extended to the 31st of December 2021. If the services of the Germans discontinued, it will have an adverse effect not only to the community of Serabu but the country and neighboring countries whose patients seek treatment at this hospital. In light of the above, and in tandem with Sections 7(2) (c)(g)(h) of the Anti - Corruption Commission Act(ACA) 2008 as amended in 2019, the ACC Prevention Department conducted this Review of the Systems and Processes on the Serabu Community Hospital with the core objective of identifying systems failures and to secure revision of those practices and further report on any corruption - relat ed acts. 2.0 OBJECTIVES OF THE REVIEW The broad objectives of the Systems Review Intervention are: To identify systems failures at the Serabu Community Hospital and to secure the revision of those practices.

20. 15 5.2.0 RECRUITMENT OF THE THREE MANAGEMENT POSITIONS Article 5(h) of the Memorandum of Agreement (MOA) between The Catholic Diocese of Bo, Sierra Leone and the German Doctors E. V. Bonn, Germany states “ The Local Partner will cause the Hospital Management to be responsible for the immediate replacement of vacant positions of each of: Medical Superintendent. Hospital Manager. Matron. Logistics Manager and Accountant (Herein after referred to as Key Staff) Further, Section (a) provides: “The replacement and hiring/appointment of Supervisor and Key Staff, as well as any major change in the structure and focus of the project, will require consensus between German Doctors and the Local Partner. The Local partner here is the Diocese of Bo represented by His Lordship, the Catholic Bishop of Bo. On this, the Acting Manager explained that the German Doctors (GDs) req uested to be part of the recruitment process. But based on his understanding of Section 5(h) quoted above, the Interim Management went ahead with the recruitment in the absence of the GD. He also claimed that the GD was kept in the know through emails thr oughout the process and later presented the proposed candidates, who were however rejected by the GD, who cited their non - involvement in the recruitment process as a breach of the Memorandum of Agreement(MOA.) Examination of the recruitment documents submitted to the review team, revealed: No evidence of advertisement on a Local newspaper for all the three vacancies. No evidence of advertisement on any website. No evidence of Internal Job Advertisement for all the three vacancies.

35. 30 areas, such as, Pharmacy, Stores, Finance, etc in order to exhibit high level of professionalism resulting in effective and efficient service delivery. To develop Terms and Conditions of Service for Staff and Codes of Conduct . Operational policies that cover all the areas of the hospital be developed, reviewed, and approved by the Board and implemented. Management Response Management will incorporate in the new Hospital Organogram Secretary as part of the Technical Leadership Team. Management will prioritize in reconstructing the Hospital Board.” Management will ensure the recruitment of competent and qualified staff.” GD Response The German Doctors confirmed that reports were submitted directly from the Hospital Management to GD and not through the Board. A situation the GD referred to as unfortunate and that resulted to delay and mistakes in the report submitted. The GD additionally stated that decisions related to the day - to - day work of the Hospital were taken by Gd Bonn citing that GD was more familiar with the management of a hospital. The GD reaffirmed that the structure that was in place was “Certainly far from ideal” Review Team Comment on the Responses The response of the GD is consistent with the finding and recommendation of the review team. The review team therefore re - iterate the Board and the Hospital Management be restructured and effective.

18. 13 There is no Procurement Unit or individual in charge of procurement. An engagement with the “Former Logistics Officer” revealed that he was never involved in any procurement including all those mentioned above. In the current Caretaker administration, proc urement is being done by Acting Manager (The Director of Caritas), Acting Finance Officer (Finance Officer Caritas) and the Medical Superintendent (A staff of MoHS). For almost all the procurements made by the Serabu Community Hospital, from 2019 to July 2021 including for drugs, neither delivery notes, nor distribution lists or stores issue vouchers made available to confirm their issue and use. 5.1.3 Implications T he Serabu Community Hospital Management following the recommendations of the German Doctor s in procurement undermines our National practices relating to procurement. 5.1.4 Recommendations The Management of the Serabu Community Hospital to establish a functional Procurement Unit charged with the responsibly of all procurements. That a system of segregation of duties to ensure separation of authorisation, initiation (Request), review, approval, and reporting be established. Management to ensure that the relevant sections of the National Public Procurement Act and Regulations be respected and adhered to in all procurements, regardless of what is recommended by the German especially when it is not in sync with the national laws. All procurement should be properly forecasted and budgeted for. All procurement should be supported by the relevant documents including Local Purchase orders, Proforma Invoices, bid advertisement, bid

31. 26 An Internal Auditor be recruited and supported to ensure the effective monitoring and reporting of compliance in internal administrative control. A Monitoring and Evaluation officer be recruited to ensure the continuous tracking and assessment of achievement of set project objectives and deliverables as well as identifying deviation from project criterion and MOA for immediate corrective actions. The supervisor to heighten his/her supervisory role in line with Clause 6 (c) of the MOA. Management Response Management will endeavor to address the recruitment of an Internal Auditor” 8.0 MANAGEMENT STRUCTURE AND ADMINSTRATION OF THE HOSPITAL 8.1.1 MANAGEMENT OF THE BOARD 8.1.2 Findings It was also observed that the Hospital Board is operationally dormant. The last Board meeting was held in 2019 wh ich is two years down the line and it is key requirement for the convening of Board Meetings. As such, decisions, and instructions on the running of the Hospital were made and given by the German Doctors and the B ishop of the Catholic Diocese of Bo, often separately. So in effect, the Board has not been effective and functional . The review team discovered that His Lordship the Bishop, who chaired the “Board” was only copied all reports and correspondences are addre ssed to the GDs rather firstly discussing with the Board.

33. 28 absence of German presence/representation on the Board given the cause for Board Meetings not been held is problematic and has to be corrected. Annual, Quarterly and Monthly f inancial and Narrative report should be submitted to the Board for scrutiny before been sent to the GD. As this will provide the Management Board the opportunity to address any problem on time as expected. Major procurements and other major decision shoul d be deliberated and approved by the Board in a Board meeting before undertaken 8.2 ADMINISTRATION 8.2.1 Findings The ACC review team also discovered that reports addressed to the GDs only border around financial and no narratives on the general hospital administration. In an interview with the Hospital Secretary, the Team noted that he is not part of the Hospital Management Team, and rather performs largely secretariat duties, distributing papers to Units etc. The Review Team (RT) observed gener ally a weak Management system. There is apparently an existing structure explained as Organogram but lacks its real purpose and also no Strategic Plan which speaks to the management and the direction of the hospital . The Review Team observed the serious lack of specialized skills by staff in charge of technical Units. The person in charge of Pharmacy is not trained and qualified in Pharmaceuticals. The same for the outgone Logistics Officer, the current Matron etc The re is also lack of a codified Terms and Conditions of Service for workers and also a Code of Conduct and Ethical Behavior which guides the conduct and behavioral patterns of staff in the Hospital .

19. 14 documents, procurement Committee evaluation reports, Purchase Orders, delivery notes, invoices, and receipts depending on the procurement value. That a Procurement Commit tee be established comprising a representative from each unit to ensure the evaluation of all procurements. That the Procurement Committee to be established verifies all items procured delivered before taken to stores. That payment for all procurements be based on the Procurement Committee’s Work/Service Completion Certificates and Goods Delivery Certificate. Management Response “ Though with financial implications, management will be committed to adhering to the National Public Procurement Act.” “Advertisement for the position of Procurement and Logistics Officer was done, but the recruitment process is yet to be finalized. See attached job Advertisement in the Global Times News Paper” GD Response The GDs Intimated that their procurement rules in clude three different quotations that need to be analysed for both price and quality that must be adhered to. Review Team Comment on Responses The R eview T eam reiterate that al l national procurement rules be followed at all times. The three quotation established by the Germans is not appropriate in all procurement conditions. The national procurement rules stipulate different procurement procedures for different procurement threshold. In order to avoid delays in the procurement pro cess, we further recommend that there should be proper forecasting be made. Furthermore, the recruitment of the Pr ocurement Officer be expedited.

53. 48 16.0 CONFLICT RESOLUTION We observed that the MOA provides for conflict resolution in Clause 8(b). However, the said clause lacks clarity as to the exact steps to be taken to resolve conflict between the Local Partners and the German Doctors. 16.1 Implication The lack of clarity in Clause 8(b) has the risk of misunderstanding and misinterpretation as to how conflict can be resolved between the Local Partners and the German Doctors; that may further result to escalation of issues and disagreement that may hinder the smooth running of the hospital. The current impasse between the German Doctors and the Local partners is a clear manifestation of the lack of clarity in Clause 8(b) of the MOA. 16.2 Recommendation We recommend that: Going forward, all agreements entered by the Board for and on behalf of the Serabu Community Hospital should be translated into a workable document to enhance clarity and application. Conflict resolutions clauses should be exhausted before any other actions. Management Response “Management will engage stakeholders in the management of the Serabu Community Hospital to review the Current conflict resolution document in a simple translated working document to enhance clarity and application.” GD Response The GD agreed with the find ing of the Review Team citing that “Fuel Managem ent has been a constant issue.” and remained to be a problem although the issue was also highlighted in the 2018/2019 evaluation report of the hospital.

27. 22 Relevant supporting document such as, pharmacy requisition, received and issue Vouchers, Pharmacy Ledger and entries to Bin Cards are not effectively maintained. 6.3.2 Implication Lack of trained and qualified pharmacist and drug storekeeper as well as the ineffective use of relevant pharmacy documents undermine accountability , transparency, smooth running of the hospital and creates room for corruption. 6.3.3 Recommendation That trained and qualified pharmacist and drugs storekeeper be immediately recruited. Relevant supporting documents such as, pharmacy requisition, received and issue Vouchers, Pharmacy Ledger and entries to Bin Cards be effectively maintained. In line with recommendation (4) in the Independent Systems Review Report, we recommend that mont hly stock - taking be conducted at the pharmacy and report on same be presented to the Board. GD Response The GD consented to the review team’s finding that the pharmacist is not trained and qualified. The GD, however, claimed that they had always wanted to recruit trained and qualify Pharmacists but were always discouraged by the Hospital Management citting S erabu location and terrain as an excuse - making it difficult to recruit trained and qualified pharmacists. The GD also stated that two (2) pharmaceutical assistants were trained intensively by Pharmacists without Borders. Review Team comment on R esponses The team emphasis on the recruitment of trained and qualified Pharmacist

26. 21 Throughout the seven days of our engagement in the hospital, the review team observed only two security guards deployed at the main gate with very minimal searching and restriction of veh icles and people movement during the day. In two instances, we observed the movement of vehicles in and out of the Hospital Compound without being searched. 6.2.3 Implication Failure by Management to ensure all round security leaves the Hospital vulnerable to theft and other security threats from within and outside. 6.2.4 Recommendations Management to increase the presence of security guards as well as capacitating them on security matters. During the day, at least two security guards should be deployed at the main gate, one at the main drug store and pharmacy, one at the fuel and generator point and one roaming with clear mandate to record the movement of bulk quantity of drugs and other medical items. All staff working in the hospital to be thoroughly searched on entering and leaving the Hospital Compound. All staff of the hospital to always wear their staff identification on entering the gate and during working hours. A system of movement restriction to strategic locations such as the pharmacy, drug stores and wards be instituted. 6.3. THE MANAGEMENT OF THE PHARMACY 6.3.1 Finding There is still no trained and qualify pharmacist and drug storekeeper. Currently, the Assistant Finance Officer who is also not a trained pharmacist acts as the drug stores keeper.

47. 42 available in the theatre. At the moment, only caesarian operation is done in the hosp ital. Also some nurses in the theatre reside in the community and when there is an emergency at night, they have to walk in the dark to come to the hospital. This is very risky for the nurses for fear of snakes and physical attacks especially if they are p erceived as bad in the community. At the time of the review, there was shortage of Anesthesia in the hospital and only one was available which sometimes feel exhausted especially when there is an influx of patients for surgery in the hospital. There is al so staff challenge in the theatre as there is only one team that runs the shift system. They come in the morning and leaves at 16:00 hours. It is also the personnel in that team that will be selected to run the night shift in case of an emergency. 15.2 I mplication Where surgical instruments are reusable, it is not a good practice to be employed in order to save lives and assist in cost efficiency. By virtue of the practice the clinicians place themselves at high risk in trying to be creative in order to ensure that care is offered to the patients. It also raised red flags in relation to the inherent risk of this practice to the patients and possible litigation risk to the institution. 15.3 Recommendations Since the Germans are not providing the necessary instruments and equipment for the effective and efficient running of the theatre and also considering the inherent risk of the practice of reusing the instruments in the theatre, it is recommended that management finds an alternative to salvage the situat ion in order to avoid the possible causes of death by the practice. We recommend that nurses on call should be provided with a quarter for easy access to the theatre without any risk or fear in their movement to the hospital from their houses outside of th e Hospital facility. We recommend that Management should provide an additional team to the theatre so that they will introduce a two - shift system with different personnel.

32. 27 8.1.3 Implications There is no clear lines of instructions and control, which leaves the Hospital Management in Serabu sometimes in dilemma as to whose instructions to follow, in the event, instructions from the Germans and the Diocese conflict. The ineffectiveness of the Board led to lack of strategic direction and supervision which further created room for the very weak control environment at the Serabu Community Hospital. Since His Lordship the Bishop is only copied on all reports, this prevented Him and the General Board Members from further scrutinising Operational Management before reports are sent to the GD. Thus, created room for flaws. The lack of narrative and anal ytical (descriptive, predictive, and prescriptive) reports on the GD projects and other Hospital Operations prevented the Board from clearly understanding what obtains on ground on timely basis. Which greatly hampered the decision - making ability of the Boa rd resulted to all the problems highlighted. 8.1.4 Recommendations Management Steering Board be properly constituted and made effective by meeting and discussing issues relating to the strategic operations of the Serabu Hospital at least once every quarter. As a result of the implications, the RT recommends that the Hospital Secretary becomes a member of the Hospital Management Board preferably its Secretary and also with clearly defined roles and prominence, in the Hosp ital, not above the Hospital Manager. It is further recommended that the Board meets at established periods and times (regularly), to discuss and take decisions on the day - to - day running of the Hospital with the view that the Germans will be provided upda tes, minutes shared with them of Board meetings accordingly electronically. The

51. 46 These issues were also identified by the External Auditors of the Serab u Community Hospital in their 2018/2019 Financial Statement Audit Report but remained unresolved. 14.2 Implication The exclusion of fixed assets from the financial statements may understate the net worth of the hospital and may not show the true picture of financial position of the same. The lack of a fixed asset policy may lead to adhoc decision on fixed assets which may increase cost due to damages that cannot be traced to personnel. Lack of insurance on fixed assets exposed the assets to the risk of no t being covered in the case of any eventuality. 14.3 Recommendation We recommend that: A fixed asset policy be developed and implemented. The Serabu Community Hospital to ensure that all fixed assets such as land and building, machinery, fixture and fitti ngs, theatre equipment etc are capitalise. All fixed assets be coded The fixed Asset to be updated includes all the fixed assets with the appropriate columns including column for price and date procured. Asset listing should be developed and pasted in all offices where assets are deployed. Management Response “ Management will ensure that fixed asset policy will be developed and implemented with special reference to all features required in the asset register.”

29. 24 In line with recommendation (9.0) of the Independent Systems Review, we recommend that an extensive outreach intervention, especially targeting Serabu and other communities with a concentration of end - users of the facility to explain details of the Service Charter, the Free Health Care initiative, and general service of the h ospital. GD Response The GD confirmed that this issue was also brought up by two independent consultants to which the GD advised that a clear and conspicuous service Charter be developed and mounted. The GDs were surprised that this has not been done. Review Team comment on the Responses The German Doctors response is in line with the team finding and recommendation. The Management of the Serabu Hospital should expedite the process of developing a comprehensive Service Charter. 6.5.0 D EPLOYMENT OF SPECIALISTS - GERMAN DOCTORS 6.5.1 Findings During the time of our intervention, there were no German Doctors attached to the Hospital, as a result, we could not confirm the criteria for their deployment. 6.5.2 Implications If there are no set criteria with regards to needs and specialty there are tendencies for the German Doctors to be underutilized and thereby not justifying the cost of their deployment. Without set criteria and standards, it will be difficult to measure the performance and impact of t he German Doctors. 6.5.3 Recommendations Let deployment of any German Doctor be based on needs assessment.

36. 31 9.0. FINANCIAL MANAGEMENT 9.1 FINANCIAL MANUAL 9.1.1 Findings There is no Financial Policy and Procedures Manual that will provide step – by – step guidance on the management of finances at the hospital. The absence and need of a financial policy and procedure manual were also identified and recommended by the Hospital’s External Auditors in their 2019 Financial Statements Audit Report but remained unresolved to date. Though management claimed that a draft financial policy and procedure manual that covers all operating under CARITAS is “being ” prepared, such draft was not made available to the ACC review team neither evidence of its operation apparent. 9.1.2 Implications The lack of Financial Policy and Procedure Manual has the tendency of staff using discretions in their operations which will undermine accountability and transparency. The lack of financial policies and procedures manual resulted in payments been made by Financial Officers without any indication of the basis on how these payments were requested, authorized, and approved, and effected. 9.1.3 Recommendations We recommend that: The finalisations, approval and implementation of the draft financial policies and procedures manual be expedited. Management Response “ Serabu Hospital has Management Handbook. However, management will extract relevant portions for a user - friendly version for staff use.”

48. 43 Management Response “Management is expecting a 40ft container of medical equipment’s now at the Deep - Water Quay awaiting clearing. This will address the issue of instruments in the theatre” “Management will identify and provide rooms to accommodate nurses on - call duties in the hospital” “Management will introduce a two - shift system in the theatre in the hospital, though this might have a financial implication.” G D Response The GD intimated that the Operating Theatre was in a good condition up to “Summer 2020”. The GD described the sudden change as unfortunate. GD reaffirmed the management position that there is currently a container with medical equipment at the Freetown harbor that may improve the situation when cleared. GD however highlighted that the container has been at the Freetown Habour since My,2021. Review Team Comment on Responses The Clearing of the Container be expedited in line with the National Procurement rules. 1 6 .0 LINE OF COMMUNICATION 16.1 Findings The Review Team examined the communication pattern, flow, and processes within and outside of the Hospital. It established that communication flow was substantially vertical and not horizontal. This means, the Serabu Hospital Management will communicate t o the Germans in Germany and copying the Bishop of the Catholic Diocese of Bo, and the German Doctors will also communicate to the Hospital Management copying the Bishop. But also, instructions are given to drive changes in the hospital on ground by the Ge rman Doctors without they are

23. 18 However, some of the drugs procured from April to July, 2021 could not be traced to the respective drug bin cards as they were not taken on charge. 5.3.1 Implications The decision to hoard such vital consumables (Gloves and Medicines) in the operations of the Hospital was ill advised and seriously undermined the smooth running of the hospit al as well as the health and safety of Doctors, Nurses and Patients. This further implied that there is no effective system in place to manage (Monitor) the supply and usage of gloves and medicines. Failure to take drugs on charge and show how they were i ssued would mean that the drugs were not delivered to the Serabu Government Hospital, w hich may mean that the claimed shortage of drugs by the GD was due to drugs diverted to some other places rather than being delivered to the Serabu Hospital. 5.3.2 Recommendations The Review T eam recommends the following: A Committee headed by the Medical Superintendent be set - up to establish stock levels on all drugs and medical items. The stock levels should include Minimum, Maximum and reorder levels. Put a system in place to effectively monitored the use and accountability of gloves and other medical consumables. In this regard, a Form may be designed and positioned to all wards to capture the use of gloves by staff. The form should capture the quantit y of gloves supplied to award and who uses them. All drugs and medical items delivered to and issued from stores should be promptly taken on charge. That relevant supporting document such as Delivery Notes, Goods Received Vouchers, Allocated Stores Ledg er, Bin Cards, Stores Requisition Books

22. 17 GD Response The GDs stated that the MoU referred to by the Review Team was not valid as it expired on 31 st March 2021. The DG reiterated that despite several requests , they were not involved in the recruitment of the three (3) key staff as they were not given access to “all applications” for th e positions to ensure a fair and transparent process, regardless of religion, sex, ethnic background, etc a condition they have set for the recruitment of “new staff” consequent to the consultant's audit report. Review Team comment on R esponse Managemen t of the Serabu Hospital are yet to provide evidence of the advertisement in respect to the recruitment of the three positions. The review team emphasised that all recruitments should follow due processes and free from all biases Furthermore, all recruitm ents should be done in consensus and participation of both parties (The GD and the Diocese). 5.3. CHO s WORKED FOR A WHOLE WEEKEND WITHOUT GLOVES & MEDICINES With regards to the gloves, the Medical Superintendent intimated that due to perceived misuse of gloves supplied to wards, it was a deliberate decision to create artificial scarcity by hoarding the gloves. Our engagement with other staff (All levels) revealed that indeed gloves were not available at the Hospital in one particular weekend and that gloves for use in wards were later made available by the outreach officer from Government Supplies for the Under Fives. With regards the drug shortages, the review team could not confirm that there were drugs shortages. We however noted that there was rapid procurement of large quantities of drugs within April and May 2021, which the Medical Superintendent and the Acting Manager claimed was because of drug shortages.

41. 36 It was also realized that, in the current administration of the hospital, there was no automated recording of the dispensation of drugs in the pharmacy setting. Therefore, the P harmacist could not establish the quantity of drugs received and dispensed duri ng a particular period. In the old administration, such system existed in the automation of drugs which gave a proper accountability of the receipt of drugs and dispensation. The Review Team further assessed the adequacy and effectiveness of internal contr ols on medicine management in the wards within an accurate setting including stock control on medicines and monitoring. In the dispensation of drugs in the Wards, drugs are not directly supplied to the Wards, rather drugs are prescribed by the Medical Doc tor for patients and the prescription is taken to the pharmacy by the patient Caretaker to be supplied. The drugs are administered to the patients according to their charts. However, a stock register is not maintained by the in - charges in the wards where t hey can take on charge drugs received from the patients and also dispensed at any particular point in time, which will be useful to an independent verifier/auditor. 10.3 Implications Without a trained and qualified pharmacist , it will be difficult to provide a great source of advice to patients and to recommend safe combinations of medicines or solutions to specific patient problems. In the absence of recording of receipts and administering of drugs, there will be a challenge in accounting for the dru gs and also serve as a conduit for the pilferage of these drugs. 10.4 Recommendation The hospital management should recruit a trained and qualified Pharmacist who is required to work closely with other members of staff, such as physicians, nurses and procurement officer in the procurement of drugs so that drugs are procured in accordance with the required specifications and dispensed accordingly.

30. 25 Let there be an established standard or measure of performance for German Doctors deployed. GD Response The GD agreed with the Review Team’s finding that there was no German Doctor at the Serabu Hospital during the ACC Review of the Serabu Hospital. The GD cited the end of the corporation as a reason for that. Review Team comment on the Responses We agreed with the GD response 7 .0. GENERAL SYSTEMIC REVIEW FINDINGS, IMPLICATIONS, AND RECOMMENDATIONS 7.1.1 INTERNAL AUDIT, MONITORING, AND SUPERVISION 7.1.2 Findings There is no internal Auditor at the Serabu Community Hospital. There is also no Monitoring and Evaluation Officer. Though there is a “Supervisor “as provided for in Clause 6(c) of the MOA, but the supervisor is ineffective as there is no report on the activities of the supervisor. The absence and need of an Internal Auditor was also i dentified and recommended by the Hospital External Auditor (King Walker and Associate) in its 2019 Financial Statement Audit Report but remained unaddressed. 7.1.3 Implication The absence of an Internal Auditor, Monitoring and Evaluation Officer and effe ctive “Supervisor, deprived the Serabu Community Hospital’s management from identifying problems, deviations from best practices, and non - compliance to controls been identified and corrected on a timely basis. 7.1.4 Recommendation We recommend that:

17. 12 A desk - based review was done relating to review on Hospitals. Interviews were conducted will the relevant personnel that led to a thorough understanding by the review team, of the op erations of the Serabu Community Hospital as well as the relationship that exist between the German Doctors and the Serabu Community Hospital. Relevant documents were requested and examined. These include Audit Reports, fleet records, fuel records, medical records, stores records and sites visited. The documents were requested to get an insight into the Hospital’s operational and administrative divisions. A draft was presented to the German Doctors and Diocese for validation and there response to the findin gs and recommendations . There responses are inputted in the report. 5.0 FINDINGS, IMPLICATIONS AND RECOMMENDATIONS 5.1 FINDINGS ON ISSUES HIGHLIGHTED IN THE LETTER OF THE GERMAN DOCTORS 5.1.1 PROCUREMENT ISSUES 5.1.2 Findings All documents examined revealed that the Management of Serabu Community Hospital followed the recommendation of the German Doctors to do procurement which is not in line with the national procurement regulations. The R eview T eam discovered that between March and July 2021 the Serabu Community Hospital procured drugs from Rodyna Pharmaceutical, Jagissa Pharmacy, Idalanda Enterprises, Eastern Pharmacy and Med Laboratory all in Bo inline with the recommendation from the Germans. That is, no advertisement, no bidding process, etc were observed. From interviews conducted with senior personnel of the hospital, it was revealed to us that this has been the practice of the Germans by using the Sole Sourcing method of procurement.

40. 35 The spending of revenue before been banked has the tendency of cash being misappropriated and may lead to spontaneous spending since there is cash in hand to be spent. The entrusting of requisition, a uthorisation, and approval of petty cash expenditure in the hands of just two people created a limited segregation of duties on petty cash management. This practice creates room for corruption. The spanning of receivables for a period of almost two years implied that management is not taking sufficient steps to collect debt, hence depriving the hospital from much needed cash for its operations. 9.4.3 Recommendation We recommend that Standardised Receipts be issued for all revenues collected by the hospital. The request, authorisation, approval, and payment of petty cash be segregated to at least three personnel. That a petty Cash imprest system with an appropriate float be immediately introduced. Own source revenue be banked intact. Managemen t to immediately collect the Le 107,173,000.00 owed to the hospital by the three debtors mentioned on table 1 & 2 above. 10.0 DRUGS MANAGEMENT 10.1. DISPENSATION OF DRUGS FROM THE PHARMACY AND THE WARDS 10.2 Finding The P harmacist operating the pharmacy is not trained and qualified. According to our interview with the pharmacy attendant, he stated that he was appointed by the German to act in that capacity without going through any formalized training and skills upgrade.

16. 11 To examine the “Structural Problems” raised by the German Doctors in the letter to the Bishop of the Catholic Diocese of Bo, Most Reverend Charles A. M Campbell and the following counter claims response made by the Steering Board of the Serabu Community Hospital with a view of coming up with a clear p osition as to what actually obtained at the Hospital. To examine the various structures of the Serabu Community Hospital with a view of identifying weaknesses in practices and procedures and proffering appropriate instructions with a view of promoting efficient and effective service delivery at the Serabu Community Hospital. To instruct the establishment of an appropriate systems and processes in place at the Serabu Community hospital with the view of ensuring that donor funds are used for the intended purposes only. To restore trust between the German Doctors and the Steering Management Board of the Serabu Community Hospital to continue their cooperation in the interest of the people of Serabu and its environs. 3.0 SCOPE OF THE REVIEW This review covers the period January 2019 - June 2021. Prior to the commencement of the review exercise, an Inception Meeting was held on 26 th July 2021 in which His Lordship Bishop Charles Campbell, other members of the Steering Management Board were all present. Individuals also spoken to; the immediate past Manager, James T. Lahai, the former Administrator of the Hospital, Rev. Fr. John Joe Sandy and the Interim Hospital Manager, Dr. David S. Yambasu. 4.0 METHODOLOGY An engagement Letter was sent to His Lordship Bishop Charles Campbell, few days before the holding of the Inception Meeting. Purpose of th e review was discussed, and consensus reached for the review to commence.

56. 51 Published by the Anti - Corruption Commission Headquarters: 3, Gloucester Street, Freetown, Sierra Leone, West Africa Hotline Nos: 077 - 985985 , 077 986 986, Website: http//www@anticorruption.gov.sl 515 (All Networks) Bo Office Address: 10 Bo Pujehun Drive, Kebbie Town Email: info@anticorruption.gov.sl Makeni Office Address: Mena Hill Reservation, Makeni Kenema Office Address: Reservation Road, Off Maxwell Khobe Street Kono Office: 37 Masingbi Road, Koidu City Kono Port Loko : 27 Conteh Street, Port Loko

25. 20 6.1.3 Implication Failure of management to conduct an independent Investigation , on the drug theft, deprived management the opportunity to identify or figure out how the theft occurred and put measures in place to prevent future occurrence. Same could be said with regards the abandoned police investigation as there is no police investigation report on same. Nurses handling keys to patients’ medical drawers creates the same risk that led to the drug theft. 6.1.4 Recommendation We recommend that the Incoming Management pursue the police investigations as well as conduct an independent management investigation on the drug theft that occurred in 2019. That the keys to patients’ medical drawers be handled by the patients themselves or their caretaker to ensure that the patients have full control over their drugs. That monthly stock - taking be conducted on the main medical stores and pharmacies . That Close Circuit Televisions (CCTV) be installed in strategic locations such as the gate, pharmacy, corridors of wards and stores. 6.2. SECU RITY ARRANGEMENTS AT THE SERABU COMMUNITY HOSPITAL 6.2.1 Findings An engagement with the Acting Manager of the Serabu Community Hospital indicated that an attempt to recruit a private security agency proved very expensive, thus preferred to maintain the same old arrangement with plans to have at least two security guards at the main gate to record movements when the situation stabilizes.

38. 33 9.3.2 Implication The non - preparation of Bank reconciliation Statement has the impact of differences between the bank statement and cashbook not detected and corrected. 9.3.3 Recommendation We recommend that monthly Bank Reconciliation be prepared for all bank accounts ma intained by the Serabu Community Hospital and such reconciliations should be reviewed by a Senior Officer in the Finance Office. 9.4 OWN SOURCE REVENUE 9.4.1 Findings The review team observed that receipts were not being issued for the various own source revenue received from registry, lab, drugs, and theatre. Own source revenue collected are not intactly banked. Petty cash expenditure are made from taking on own sourc e revenue before banked. The review team also observed unapproved and unregulated expenditure from own source revenue in the form of petty cash. The request and approval of petty is centred around two James Kamara (Assistant Finance Officer) and Alien Man saray (Team Lead). In the absence of one, the other does the requisition, approval, and payment. Additionally, payments in the form of petty cash were not supported by receipt to confirm the purpose for which the cash was used. We observed that two mining Companies and an NGO (Non - Governmental Organisation) as below, owed the Serabu Community Hospital a total of Le One Hundred and Seven Million, One hundred and seventy - three thousand Leones (Le107, 1 73,000.00). We observed that the debts owed by the two mini ng Companies have spanned to almost two years without any evidence of payments.

34. 29 The hospital lacks Operational P olicies and Procedural Manuals that will provide step by step guidance on the administrative operations of the Hospital. Most of administrative actions and decisions are made on adhoc basis. The review team observed that most of the activities are done on verbal instructions claimed to have been made so by the GD as their focus is on the end and not the means. 8.2.2 Implications The lack of an Organogram and S trategic P lan have resulted to blurred line of authority, responsibilities, accountability, reporting, decision making and direction of the hospital. This has the impact of power and decision making been concentrated on few. Thus, resulted to some of the problems highlighted. The lack of requisite capacity of staff to perform their roles and job s categorically would mean they will not do well and act professionally. For instance, a person who is not a trained pharmacist will not dispense drugs accurately and also maintain proper records. This was observed during the examination on the dispensatio n of drugs vis - a - vis records maintained as the lapses identified were numerous. The lack of a codified and proper condition of service in the hospital will de - motive staff and consequently staff members will plunge themselves into illegal activities withi n the hospital . The absence of operational policies and procedures has the impact of staff not being held accountable as there is no step - by - step guidance of what is expected of them 8.2.3 Recommendations The Hospital Secretary should be part of the Management Team to act as Secretary to take minutes and other administrative work. It is recommended that staff with the requisite specializations, skills, capacity, and competencies be made to work in the resp ective technical

37. 32 “Serabu Hospital has Management Handbook. However, management will develop a Financial Manual.” 9.2 ACCOUNTING DOCUMENTS 9.2.1 Findings We observed that accounting documents such as Payment Vouchers and expenditure proposal / Expenditure requisition lack the characteristics of accountable document such as serial number and are not in duplicate or triplicate carbonised book form. Our review revealed that almost all the accounting documents related to cheque payments centred on few people. The initiation, authorisation and approval of all cheque payments were done by these people. The supporting documents l ac k characteristics such as serial numbering, duplicate copies, etc. 9.2.2 Implications The lack of serial numbering, unique features and carbonised book form has the impact of accounting documented been manipulated without been identified and corrected. 9.2.3 Recommendations Management should ensure that proper accounting documents with the requisite characteristic be maintained. The Finance Officer to ensure that supplies possess authentic relevant supporting documents before transacting with them. 9.3 BANK RECONCILIATION 9.3.1 Findings Monthly Bank Reconciliations statements were not prepared the Finance Officer.

28. 23 6.4 FINDINGS ON ALLEGED EXTORTION AND THE NEED FOR FURTHER INVESTGATIONS 6.4.5 Findings We could not confirm allegation of extortion, but however the review team observed the following That patient under the Free Health Care category are required to pay registration fees of Le 2,000 and follow - up fees of Le 1,000. We were informed that these were instruction given by the German Doctors. That the Service Char ter developed is not exhaustive and lucid on t he cost of the various services, drugs and was not conspicuously displayed. That there was no evidence of internal investigation into allegations of extortion. 6.4.6 Implications Payment by patients under the Free Health care category undermines purpose of the Free health Care scheme. Without proper sensitisation of patients on how to access service and drugs and the cost attached leave them vulnerable to extortion and other corrup t practices. 6.4.7 Recommendations We recommend that the Free Health Care scheme should be strictly adhered to and no form of payment requested or required from patients under that category. However, since the drugs are not provided by Government, save o n two occasions, let it be given another nomenclature then, since it is not totally free, as payments are made for registration. We recommend that the Service Charter be upgraded to meet best practice, placed in strategic location, and regularly updated when there are changes or reviews in prices and services.

46. 41 14.0 GRIEVANCE REDRESS MECHANISM TO PATIENTS CONCERNS AND COMPLIANTS 14.1 Finding The hospital did not have a mechanism to redress grievances related to free drug supplies to the patients and other public concerns about the hospital so that action will be taken within a stipulated timeframe. It was also mentioned by the Management of the hospital that a complaint box was once available in the h ospitals to receive the grievances of the public. This was not continued because patients were not responding to the use of that system. 14.2 Implication Without proper grievance redress opportunity or regime within the Hospital arrangement and structure, service delivery to patients by healthcare givers can be abused with impunity. 14.3 Recommendation The Management of the hospital should provide and institute mechanisms to redress patients’ complaints, and adequate sensitization on, and popularization o f the mechanisms are critical. The hospital service charter should contain a grievance redress mechanism. 1 5 .0 OPERATING THEATRE 15.1 Findings There is a lack of adequate supplies to carry out functions in the major and minor theatres. This is especially true for instruments that are used for surgery as they are overused because those that were supplied by the German Doctors are well overdue. It is over a year that drugs for surgical operations have not been supplied by the German Doctors. This has caused the doctor not to be performing Hernia and general surgery because they require different kinds of suture, and they are presently not

50. 45 recommended when communication is from the Diocese of Bo to the Hosp ital Management, staff, and the public. It is also recommended that a communication policy or manual is developed. Communication within and without the Hospital by staff through the policy will be clearly defined, so a staff will know what to communicate to a colleague or a member of the public, at a material point in time. Management Response “Management will step up formal communication. Bishop will be in copy of all official communications. The Hospital Management will adopt Confidentiality Note for a ll staff.” “Management will develop a Communication Manual.” 14.0 FIXED ASSETS MANAGEMENT 14.1 Findings The R eview T eam observed that the Serabu Community Hospital does not have a policy on fixed assets and fixed assets management. Therefore, there is no step - by - step guidance on what “asset” is to be expensed or capitalised, on depreciation rate and depreciation policy. The team observed that t he Serabu Community hospital does not capitalise asset such as land and buildings, motor vehicles, hospital beds, office equipment such as computers, theatre equipment’s, oxygen machine etc. The Team also observed that most the assets are not coded. The fi xed Asset Register is not properly maintained in that it does not have columns for cost of the asset, depreciation rate, location of the asset, user of the asset, depreciation to date, Net book value and that almost 80% of them do not have date of acquisit ion or date received. The T eam also observed that the property and plants owned by the hospital such as buildings equipment’s and thermal generator and solar installed are not insured.

21. 16 Evidence of correspon dence between the German Doctors and the Acting Management Team regarding the recruitment process of the Three (3) Key Staff were not made available to the review team. Job descriptions, job application letters, interview questionnaires, and marked score sheets for applicants relating to the recruitment process of the three - key staff, were made available to the review team. The interview panel according to the interview score sheet consisted of the following: o Reverend Moses Kawa o Theresa Songu o Dr. Gembeh (T he Medical Superintendent) o Patricia Mokowa (Hospital Supervisor) 5.2.1 Implication The rift between the Acting Management Team representing the Local Partner here and the GDs on this means the parties did not reach consensus as provided for by Clause 8( a) of the MOA. There was a clear misunderstanding of the interpretation of the clauses of the MOA relating to the recruitment of key staff between the parties. 5.2.2 Recommendations Going forward, all agreements entered in to by the Management of the Serabu Community Hospital should be translated into workable documents (Policies and procedural manuals) to enhance the clarity of intention and purpose. The Local Partners and the GDs to meet and agree on the way forward on the recruitment of the three - k ey staff. Management Response “Serabu Hospital Management advertised the three key positions in the Global Times News Papers Online portal created for the submission of applications.”

42. 37 The Pharmacist should develop a stock record to take on charge receipts of drugs and the dispensation of d rugs in order to determine the stock level for re - order. Management Response “The Catholic Diocese of Bo will explore funds to recruit a trained Pharmacist and Pharmacy Secretary.” “Management will adhere to both Manual and Automated recording of drugs in the Hospital” “Management will develop a Stock Register System in the Wards and Out – Patient Department to be monitored by both the Matron and Pharmacist .” 11.0 USE OF EMERENGENCY DRUGS 11.1 Findings Emergency drugs are administered to patients in the hospital after 16:00 hours, when the pharmacy is closed. These drugs are supplied by the Pharmacist to the Community Health Officers (CHO) in the various wards. The CHOs make requisition to the Pharmacist and the drugs are supplied without any approval process or monitoring report to determine the stock level for re - order. For emergency treatment, there are two categories of patients that benefits from the emergency drugs and there are costs associated with these treatments. Patients for medical treatme nt pay Two Hundred Thousand Leones (Le200,000) whilst those for surgical treatment pay Five Hundred Thousand Leones(Le500,000) and these are standard costs maintained in the hospital. On arrival of these patients in the hospital, they will be asked to m ake cash deposit to the cashier before treatment commences in some cases. When treatments are prescribed for a patient and that patient is discharged, a bill is prepared and the cost deducted from the cash deposited before he patient is released. However, there was no evidence to show that the remaining amounts if any from the deposit are paid back to the patients.

52. 47 15.0 F UEL MANAGEMENT We observed that fuel is donated from VIMETCO to the hospital in addition to those procured by the hospital management. However, records were only available for the fuel donated by VIMETCO from April to date. No records were available for fuel procure d by the hospital mana gement. The R eview T eam observed that the management of fuel is not centralised to a particular responsible officer. The R eview T eam observed that there are no policy for the management of fleet and fuel. 15.1 Implication Fuel stored on jerry cans have the risk of fire accident and fuel can be easily carted away. The fact that fuel procured is not centralised/stored at the Serabu Community Hospital and that fuel for vehicles is normally collected from Bo, this may increase fuel consumption and fuel cost. 15.2 Recommendation We recommend that a small fuel depot be constructed at the Serabu Community Hospital to reduce the high rate of fuel consumption and cost of fuel having to be collected from Bo as well as the risk of fire and fuel theft. A policy on the management of fleet and fuel Proper records should be kept for fuel purchase and utilised Management Respons e “ Management is highly considering the construction of a small fuel depot at the Serabu Community Hospital when funds are available.”

43. 38 11.2 Implication With the demand for cash deposit before patients are treated, can cause patients death especially if the patient cannot afford the money instantaneously. 11.3 Recommendation We recommend that the bills for the treatment of patients from emergency drugs be prepared and payments made by the patients rather than the cash deposit system. Management Response “Hospital Management will ensure that bill for the treatment of patients from emergency drugs is prepared and prompt payments made by the patients.” 12 . 0 SECURITY OF DRUGS 12.1 Findings In 2019, there was a theft of drug incident in the hospital and the major driver for this was that no proper measures were put in place for the prevention of such occurrences. Before the theft incident, a mechanism was in place where the bags of nurses and other staff were searched before they could leave the hospital gate. However, this system was not sustainable in the hospital. Lately, a cupboard system was introduced as another preventive strategy that has minimized the theft of drugs to some extent. Th is system allows drugs to be kept in a cupboard assigned to patients under lock and key. The keys are kept by the nurses and the cupboards could only be opened when there is time to administer drugs to the patient. 12.2 Implication The system of nurses keeping the keys can pose a challenge as it is open to abuse and pilferage.

44. 39 12.3 Recommendation We recommend that the keys for the cupboards be kept by the individual patient's caretaker so that during the dispensation of drugs, the caretaker for thos e patients can open the drawers to remove the drugs to be administered. Management Response “ Management will ensure that patient cupboard keys be handled by patients’ relatives.” 13 . 0 PROVISION OF DIET TO PATIENTS The provision of diet provides a significant element of comfort to patients during their stay in the hospital. Therefore, they should have a full nursing assessment of needs on their admission. 13.1 Findings In our intervention in this aspect in the hospital, the following were observed: No copy of delivery note found in the store for food items supplied even though it was alleged by the matron that the originals of those Delivery Notes are kept by the Finance Officer which was proved to be false. Mo nies were disbursed to the Matron to buy food items for diet for the hospital. Diet is provided to patients under the following categories{: • Pregnant Women • Lactating mothers • Children under five • Vulnerable Two meals are provided to the patients per day at the cost of Le4,500 for children and Le5,000 for Adults. These include breakfast and Lunch and the budget for these two meals are prepared based on the number of patients in the wards.

14. 9 1.0 BACKGROUND In a bid to combat, suppress and eradicate corruption in Sierra Leone, the Anti - Corruption Commission (ACC) was established in 2000 to lead the fight against corruption, and with implied objectives to improve service delivery that has the impact of improvi ng the socio - economic development and the lives of the people of Sierra Leone. To further strengthen the work of the Commission, the Anti - Corruption Commission Act, of 2008 was enacted as amended in 2019. Specifically, Sections 7(2) (c)(g)(h) of the Anti - Corruption Act(ACA)2008 as amended in 2019 mandates the ACC to review practices and procedures in Ministries, Departments, Agencies (MDAs), Persons, authority, public bodies, or private sector institutions in order to identify Corruption vulnerabilities an d make recommendations to improve on efficiency and effective service delivery. For little over two (2) decades since its establishment, the ACC has been collaborating with the general public among the strategies to receive tip - offs, complaints and open l etters by journalists/the media, NGOs, CSOs, donors, teachers, students etc. This strategy and collaboration over the years have been effective in the fight against corruption. In July 2021, the ACC was tipped - off through a letter addressed to the Bishop of the Catholic Diocese of Bo, Most Reverend Charles A. M Campbell, by the “GERMAN DOCTORS HILFF, DIE BLEIHT” relating to “recurring structural problems” at the Serabu Communit y Hospital, with allegations ranging from “non settlement of account dated back to April,2021”, “Not acting on an Independent Audit issues, resulting to some worsening off”, “theft of medicine”, “violation of procurement rules” to “doctors and CHOs workin g for weeks without gloves and medicine, even though funding was provided for these by the German Doctors” In another le tter, dated 24th June, 2021, which came to the attention of the ACC few days later, the Hospital Board accepted the position of the Ge rman Doctors to ending its cooperation and relationship with the D iocese/Serabu Community Hospital, but refuted almost all the claims made by the German Doctors. The German Doctors have stated in their letter dated 24 th June, 2021 that, if immediate actions are not taken to guarantee it of complete and effective use

45. 40 However, the quantity of food provided to patients per meal is very sm all and perhaps this might be due to the amount provided per person considering an increase in the prices of commodities. 13.2 Implications Without a Delivery Note, a storekeeper will not be able to reference the specification of items supplied to the co ntract document and this might possibly lead to under supply of goods. Monies given to Matron to provide diet to patients is a conduit for corruption since she plays a supervisory role on the issue of diet in the hospital. Due to the prevailing market situ ation , the amounts budgeted per patient for diets are not adequate enough to even p rovide two square meals per day . 13.3 Recommendations Delivery Notes play a key part in the accounts payable process by confirming that items have been received. Therefore, a copy of each delivery note of goods supplied should be retained by the Matron who supervises the store and ensure that all items are delivered according to specifications. The Hospital should hire a contractor/supplier through a competitive bidding process in accordance with the procurement rules whilst the matron will focus on the clinical aspect of the hospital. All items supplied by the supplier should be taken on charge and issues to the Caterer recorded. We recommend for an increase in the quant ity of meals of meals provided to patients Management Response “Management will adopt a system in ensuring that all Delivery Notes are kept by the Storekeeper and monitoring by the Procurement Officer.” Once Procurement Unit is established Management ensure due process are followed.” “ M anagement will refer to WFP Patients Ration Matrix to ensure full compliance.”

39. 34 TABLE - SUMMARY OF RECEIVABLES No. Debtor # of Outstanding Invoices (Months) Amount (Le) 1 Sierra Rutile Iluka 21 46,300,000.00 2 Sierra Minerals Holding Limited 23 44,958,000.00 3 Children of the Nation 4 15,915,000.00 Total 107,173,000.00 TABLE 2 - SUMMARY OF RECEIVABLES – COLUMN CHART 9.4.2 Implication The non - issuance of receipt on revenue collected creates room for revenue not to be completely accounted for. Sierra Rutile Iluka ; 46,300,000.00 Sierra Menerals HoldingvLimited ; 44,958,000.00 Children of the Nation ; 15,915,000.00 0 5000000 10000000 15000000 20000000 25000000 30000000 35000000 40000000 45000000 50000000

6. 1 EXECUTIVE SUMMARY The Serabu Community Hospital is the property of the Roman Catholic Mission and has operated since the 1970s. German Doctors (GD) commenced support to this hospital in 2010. The Hospital in 2007 - 2011 had Rev. Fr. John Joe Sandy as the Administrator. Mr. James T. L ahai served as Hospital Manager from 1 st January 2013 to 31 st March, 2021. From 1 st April 2021 to the time of the review (26 th - 31 st July, 2021), the Hospital had an Interim Management - a stop - gap measure, seconded from Caritas Bo Office, with Dr. David Yambasu serving as Ag. Manager and Mr. Patrick Dauda the Ag. Finance Officer - all appointed by the Catholic Bishop of Bo Diocese. The Review conducted has the following as highlights of the key findings and recommendations Summary o f General Key Findings a nd Recommendations FINDINGS RECOMMENDATIONS FINDINGS ON ISSUES HIGHLIGHTED IN THE LETTER OF THE GERMAN DOCTORS Violation of procurement rules All documents examined revealed that the Management of Serabu Community Hospital did not follow the National Public Procurement Procedures. The Management claimed that all procurements were done as recommended by the German Doctors (GDs). For example, drugs procurements were limited to the three suppliers recommende d by the GDs namely Rodyna Pharmaceuticals, Jagissa Pharmacy, and Indalanda Enterprises. • Management to ensure that the relevant the National Public Procurement Act and Regulations be respected and adhered to in all procurements. No Procurement Unit or i ndividual in charge of procurement. Procurement is being done by Acting Manager (The Director of Caritas), Acting Finance Officer (Finance Officer Caritas) and the Medical Superintendent (A staff of Ministry of Health and Sanitation). • The Management of the Serabu Community Hospital to establish a functional Procurement Unit charged with the responsibly of all procurements. There should be segregation of duties/roles.

24. 19 and Stores Issue Vouchers, for all drugs and medical items received into and issued out of stores be maintained and properly filed. Management Response “Serabu Hospital Management will put a system in place for an e ffective monitoring of supplies” “ The Hospital Management put in requisitions for drugs, but there was a delay in the supply by the vendors. Robust actions will be ensured to for a just in time (JIT) supply” Review Team comment on Responses The R eview T eam re - iterate that our recommendation be implemented . 6.0. RECOMMENDATIONS OF AN INDEPENDENT REVIEW OF THE OPERATIONS OF THE SERABU CATHOLIC MISSION HOSPITAL, BO DIOCESE SOUTHERN SIERRA LEONE IN JULY - AUGUST 2020 REVIEW 6.1. 1 FURTHER INVESTIGATIONS INTO THE THEFT OF DRUGS AND REFORMS NEEDED 6.1.2 Findings Our review revealed that after the preliminary investigations, further action was not taken on the investigations into the theft of drugs and prime suspect is still on the run. Other than the claimed Police Investigations, there is no evidence of management independent investigation on the said drug theft, which could have assisted management to identify or figure out how the theft occur and ho ld somebody accountable. On the are a of reforms, the R eview T eam observed that a pull approach on medical supplies to patient s has now been introduced. Now patients collect their drugs and lock them in drawers though the keys to the drawers are still be i n g handled by the nurses’ contrary to the initial arrangement that patients or their C aretakers should handle the keys to their medical drawers.

4. iv 10.1 .DISPENSATION OF DRUGS FROM THE PHARMACY AND THE WARDS ..... 35 11.0 USE OF EMERENGENCY DRUGS ................................ ................................ .... 37 12.0 SECURITY OF DRUGS ................................ ................................ ....................... 38 13.0 PROVISION OF DIET TO PATIENTS ................................ ................................ . 39 14.0 GRIEVANCE REDRESS MECHANISM TO PATIENTS CONCERNS AND COMPLIANTS ................................ ................................ ................................ .............. 41 15.0 OPERATING THEATRE ................................ ................................ ..................... 41 16.0 LINE OF COMMUNICATION ................................ ................................ .............. 43 14.0 FIXED ASSETS MANAGEMENT ................................ ................................ ........ 45 15.0 FUEL MANAGEMENT ................................ ................................ ........................ 47 16.0 CONFLICT RESOLUTION ................................ ................................ .................. 48 17.0 CONCLUSION ................................ ................................ ................................ .... 49

7. 2 No delivery notes, distribution lists or stores issue vouchers were m ade available to the Review Team to confirm the supply/delivery of goods procured, their issuance and use. • All procurement should be supported by the relevant accountable documents including Local Purchase orders, Proforma Invoices, bid advertisement, bid documents, procurement Committee evaluation reports, Purchase Orders, delivery notes, invoices, and receipts depending on the procurement value. Recruitment of the Three Management Key Positions There was no consensus between the GDs and Local Partner on the recruitment process as provided for by Clause 8(a) of the Memorandum of Agreement (MOA). The German Doctors requested to be part of the recruitment process but the Interim Management, relying on Clause 5 ( h ) of the MOA conducted the recruitment in their absence claiming to have kept the GDs informed via email throughout the process. • The Local Partners and the GDs should meet and agree on the way forward on the recruitment of the three - key staff. No evidence of advertisement for these positions. No evidence that the GDs were kept informed throughout the process. However, Management promised to provide evidence of newspaper publications and email conversations. • All job vacancies should be advertised and shoul d be in line with relevant laws. Community Health Officers worked for a Whole weekend without Gloves & Medicines Our engagement with other staff (All levels) revealed that indeed gloves were not available at the Hospital in one weekend, and that gloves for use in wards were later made available by the outreach officer from Government Supplies for the Under Fives • Put a system in place to effectively monitor the use and accountability of gloves and other medical consumables DRUG SHORTAGE With regards the drug shortages, the review team could not confirm that there were drugs shortages. We however noted that there was rapid procurement of large quantities of drugs within April and May 2021, which the Medical Superintendent and the Acting Manager claimed was because of drug shortages. • All drugs and medical items delivered to and issued from stores should be promptly taken on charge in all store’s documents. Some of the drugs procured from April to July, 2021 could not be traced to the respective drug bin cards as they were not taken on charge. • That relevant supporting document such as Delivery Notes, Goods Received Vouchers, Allocated Stores Ledger, Bin Cards, Stores Requisition Books and Stores Issue Vouchers, for all drugs and medica l items received into and issued out of stores be maintained and properly filed. • All drugs and medical items delivered to and issued from stores should be promptly taken on charge. •

5. v ACRONYMS GDs - German Doctors CHOs – Community Health Officer ACC - Anti - Corruption Commission RT - Review Team ACA, 2008 - Anti - Corruption Act, 2008 MDAs - Ministries Departments and Agencies NGOs – Non - Governmental Organizations CSOs - Civil Society Organizations MoHS – Ministry of Health and Sanitation MOA - Memorandum of Agreement

10. 5 • It was observed that the Hospital Board is operationally dormant. Decisions and instructions on the running of the Hospital were made and given by the German Doctors and the Bishop of the Catholic Diocese of Bo, often separately. • We recommended that the Board be properly constituted and meets at established periods and times (regularly), to discuss and take decisions on the day - to - day running of the Hospital with the view that the Germans will be provided updates, minutes shared with them of Board meetings accordingly electronically. • Annual, Quarterly and Monthly financial and narrative reports should be submitted to the Board for scrutiny before been sent to the GD. As this will p rovide the Management Board the opportunity to address any problem on time as expected. • Major procurements and other major decision should be deliberated and approved by the Board in a Board meeting before undertaken • Lack of specialized skills by staff in charge of technical Units. • It is recommended that staff with the requisite specializations, skills, capacity, and competencies be made to work in the respective technical areas, such as, Pharmacy, Stores, Finance, etc in order to exhibit high level of professionalism resulting in effective and efficient service delivery • There is also lack of a codified Terms and Conditions of Service for workers and also a Code of Conduct and Ethical Behavior which guides the conduct and behavioral patterns of staff in the Hospital • To develop Terms and Conditions of Service for Staff and Codes of Conduct • The Outgone Management T eam claimed the existence of a Strategic plan and an Organisational Chart (Organogram) at the Serabu Government Hospital, in their handing over note, but evidence of such were not made available to the ACC review team despite several request s to the outgone and current Caretaker Management T eam. • An Organogram that provides a clear hierarchy and reporting line be immediately developed and implemented. • A S trategic P lan that provides the strategic direction of the Hospital be developed and regularly reported. • All work plans (activity plans) should be aligned with the strategic plan before approved and undertaken. We also observed the absence of key management structures and personnel such as Human Resource Officer, Projects Officer, Nutritionist, fleet & fuel officer, State registered nurses and procurement officer, sufficient doctors that are required and necessar y for the effective running of the hospital. This has resulted in staff been overloaded with multiple and conflicting responsibilities • It is recommended that staff with the requisite specializations, skills, capacity, and competencies be made to work in t he respective technical areas, such as, Pharmacy, Stores, Finance, etc in order to exhibit high level of professionalism resulting in effective and efficient service delivery. The hospital lacks Operational Policies and Procedural Manuals that will provide step by step guidance on the administrative operations of the Hospital. Most of administrative actions and decisions are made on ad hoc basis. The review team observed that most of the activities are done on verbal instructions claimed to have been made so by the Board and the GDs as their focus is on the end and not the means. • Operational policies that cover all the areas of the hospital be developed, reviewed, and approved by the Board and implemented.

8. 3 RECOMMENDATIONS OF AN INDEPENDENT REVIEW OF THE OPERATIONS OF THE SERABU CATHOLIC MISSION HOSPITAL, BO DIOCESE SOUTHERN SIERRA LEONE IN JULY - AUGUST 2020 FURTHER INVESTGATIONS INTO THE THEFT OF DRUGS AND REFORMS NEEDED Management failed to further pursue the police investigation. No evidence of management conducting an independent internal investigation on the said drug theft, which could have assisted management to identify or figure out how the theft occurred and hold those responsible accountable. On the area of Reforms, Manag ement have moved from the “push” System whereby drugs were supplied in bulk to wards to the “PULL” system whereby patients collect their drugs on prescription and lock them in drawers. The Review Team however, noted that the keys to the drawers have still been handled by the nurse’s contrary to the initial arrangement that patients or their caretakers should handle the keys to their medical drawers. • We recommend that the Incoming Management pursue the police investigations as well as conduct an independent management investigation on the drug theft that occurred in 2019. • That the keys to patients’ medical drawers be handled by the patients themselves or their caretakers to ensure that the patients have full control over their drugs. • That month ly stock taking be conducted on the main medical stores and pharmacy. • That Close Circuit Televisions (CCTV) be installed in strategic locations such as the gate, pharmacy, corridors of wards and stores. SECURITY ARRANGEMENTS AT THE SERABU COMMUNITY HOS PITAL. Throughout the seven days of our engagement in the hospital, the review team observed only two security guards deployed at the main gate with very minimal searching and restriction of vehicles and people movement during the day. Management claimed recruiting a security firm would be too costly to sustain. • Management to increase the presence of security guards as well as capacitating them on security matters. During the day, at least two security guards should be deployed at the main gate, one at the main drug store and pharmacy, one at the fuel and generator point and one roaming with clear mandate to record the movement of bulk quantity of drugs and other medical items. • All staff working in the hospital to be thoroughly searched on entering and leaving the Hospital Compound. • All staff of the hospital to always wear their staff identification on entering the gate and during working hours. • A system of movement restriction to strategic locations such as the pharmacy, drug stores and wards be inst ituted. THE MANAGEMENT OF THE PHARMACY There is still no trained and qualified P harmacist and drug storekeeper. Currently, the Assistant Finance Officer who is also not a trained pharmacist acts as the drug stores keeper. Relevant supporting document such as, pharmacy requisition, received and issue Vouchers, Pharmacy Ledger and entries to Bin Cards are not effectively maintained. • That trained and qualified P harmacist and drugs storekeeper be immediately recruited. • Relevant supporting document such as, pharmacy requisition, received and issue Vouchers, Pharmacy Ledger and entries to Bin Cards be effectively maintained. • In line with recommendation (4) in the Independent Systems Review Report, we recommend that monthly stock taking be conducted at the pharmacy and report on same be presented to the Board.

13. 8 FIXED ASSETS MANAGEMENT • The Serabu Community Hospital does not have a policy on fixed assets and fixed assets management. Therefore, there is no step - by - step guidance on what “asset” is to be expensed or capitalised, on depreciation rate and depreciation policy. • T he Serabu Community hospital does not capitalise asset such as land and buildings, motor vehicles, hospital beds, office equipment such as computers, theatre equipment’s, oxygen machine etc. • The Team also observed that most the assets are not coded. • The fixed Ass et Register is not properly maintained. • The property and plants owned by the hospital such as buildings equipment’s and thermal generator and solar installed are not insured. These issues were also identified by the External Auditors of the Serabu Communi ty Hospital in their 2018/2019 Financial Statement Audit Report but remained unresolved. • A fixed asset policy be developed and implemented. • The Serabu Community Hospital to ensure that all fixed assets such as land and building, machinery, fixture and fittings, theatre equipment etc are capitalise. • All fixed assets be coded • The fixed Asset to be updated include all the fixed assets with the appropri ate columns including column for price and date procured. • Asset listing should be developed and pasted in all offices where assets are deployed. FUEL MANAGEMENT • We observed that fuel is donated from VIMETCO to the hospital in addition to those procured by the hospital management. However, records were only available for the fuel donated by VIMETCO from April to date. • The review team observed that the management of fuel is not centralised to a particular responsible officer. • The review team obs erved that there are no policies for the management of fleet and fuel. • We recommend that a fuel depot be constructed at the Serabu Community Hospital to reduce the high rate of fuel consumption and cost of fuel having to be collected from Bo as well as the risk of fire and fuel theft. CONFLICT RESOLUTION We observed that the MOA provides for conflict resolution in Clause 8(b). How ever, the said clause lacks clarity as to the exact steps to be taken to resolve conflict between the Local Partners and the German Doctors . • Going forward, all agreements entered by the Board for and on behalf of the Serabu Community Hospital should be translated into workable document to enhance clarity and application. Conflict resolutions clauses should be exhausted before any other actions.

12. 7 • Monies were disbursed to the Matron to buy food items in respect of diet for the hospital. • The Hospital should hire a contractor/ supplier through a competitive bidding process in accordance with the procurement rules whilst the matron will focus on the cl inical aspect of the hospital. • The quantity of food provided to patients per meal is very small and perhaps this might be due to the amount provided per person considering an increase in the prices of commodities. • We recommend for an increase in the quan tity of meals provided to patients GRIEVANCE REDRESS MECHANISM TO ADDRESS PATIENTS’ CONCERNS • The hospital did not have a mechanism to redress grievances related to free drug supplies to the patients and other public concerns about the hospital • The Management of the hospital should provide and institute mechanisms to redress patients' complaints, and adequate sensitization on, and popularization of the mechanisms are critical. OPERATING THEATRE • There is a lack of adequate supplies of instruments to carry out functions in the major and minor theatres. That instruments used for surgery are worn out because they have been frequently reused and have past their useful life span. • Since the Germans are not providing the necessary instruments and equipment for the effective and efficient running of the theatre and also considering the inherent risk of the practice of reusing the instruments in the theatre, it is recommended that management finds an altern ative to salvage the situation in order to avoid the possible causes of death by the patients. • Also, some nurses in the theatre reside in the community and when there is an emergency at night, they have to walk in the dark to come to the hospital. This is very risky for the nurses for fear of snakes and physical attacks especially if they are perceived as bad persons in the community • We recommend that nurses on call should be provided with a quarter for easy access to the theatre without any risk or fear i n their movement to the hospital from their houses outside of the Hospital facility • There is also staff challenge in the theatre as there is only one team that runs the shift system. They come in the morning and leave at 16:00 hours. It is also the personnel in that team that will be selected to run the night shift in case of an emergency. • We recommend that Management should provide additional team to the theatre so that they will introduce a two - shift system with different personnel LINE OF COMMUNICATION • It established that communication flow was substantially vertical and not horizontal. • It was observed that communication method was mostly verbal and not documented in the forms of emails, memos, circulars • It is therefore recommended that, a clear and instructive mode of communication from the German Doctors to the Hospital Management and the staff and the general public to always be in either emails, memos, or other forms of acceptable formal communication with the Catholic Diocese of Bo copied therein. The obverse is recommended when communication is from the Diocese of Bo to the Hospital Management, staff, and the public. • The organization lacked a communication manual or policy which guides the flow of communication within and out of the organization. • It is also recommended that a communication policy or manual is developed to guide the operations of the hospital.

9. 4 FINDINGS ON ALLEGED EXTORTION AND THE NEED FOR FURTHER INVESTGATIONS We could not confirm allegation of extortion, but however the review team observed the following • That patients under the Free Health Care category are required to pay registration fees of Le2 , 000 and follow - up fees of Le1,000. We were informed that these were instructions given by the German Doctors. • That the developed Service Charter, which is major tool in preventing exto rtion is not exhaustive, and lucid on the cost of the various services and drugs and was not conspicuously displayed. • That there was no evidence of internal investigation into allegations of extortion. • We recommend that the Free Health Care scheme shoul d be strictly adhere to and no form of payment requested or required from patient under that category. • We recommend that a service Charter be developed, placed in strategic location, and regularly updated when there are changes in prices and services. • T he service charter should entail detail Grievance Redress Mechanism. • Whistle - blower protection mechanism • In line with recommendation (9.0) of the independent Systems Review we recommend an extensive outreach intervention, especially targeting Serabu and other Communities with concentration of end users of the facility to explain details of the Service Charter, the Free Health Care initiative, and general services of the hospital. DEPLOYMENT OF SPECIALIST - GERMAN DOCTORS During the time of our intervention there were no German Doctors attached to the Hospital, as a result we could not confirm the criteria for their deployment. • Let deployment of any German Doctor be based on needs assessment. • Let there be an established standard or measure of performance for German Doctors deployed. OTHER CORRUPTION RISK ASSESSMENT INTERNAL AUDITING/MONITORING AND SUPERVISON • There is no internal Auditor at the Serabu Community Hospital. • There is also no Monitoring and Evaluation Officer. • Though there is a “Supervisor “as provided for in Clause 6(c) of the MOA, but the supervisor is ineffective as there is no report on the activities of the supervisor. • An Internal Auditor be recruited and strengthened to ensure the effective monitoring and reporting of compliance to internal administrative control. • A Monitoring and Evaluation officer be recruited to ensure the continued tracking and assessment of achievement of set project objectives and deliverables as well as identifying deviation from project criterion and MOA for immediate corrective actions. • The supervisor to heighten his/her super visory role in line with Clause 6 (c ) of the MOA MANAGEMENT STRUTURE AND ADMINISTRATION • The Review Team (RT) observed generally a weak Management system. The structure referred to is not robust enough to effectively manage the hospital and address emerging challenges. • The M anagement of the hospital is centered on few individuals. The Hospit al Secretary is not part of the Hospital Management Team, and rather performs largely secretariat duties, distributing papers to Units etc. • There is lack of narrative reporting from all departments and units of the hospital with the exception of the matron and finance. • We recommend that the Hospital Secretary becomes a member of the Hospital Management preferably its Secretary and also with clearly defined roles and prominence, in the Hospital, not above the Hospital Manager • Every department and unit should present quarterly and annual report with detailed narratives.

11. 6 FINANCIAL MANAGEMENT • No Financial Policy a nd Procedures Manual • Our review revealed that almost all the accounting documents related to cheque payments centred around few people. The initiation, authorisation and approval of all cheque payment were done by these same individuals with no or limited consultation with the general hospital structure. • We observed that accounting documents such as Payment Vouchers and expenditure proposal / Expenditure requisition lack the characteristics of accountable document such as serial number and are not in duplicate or triplicated carbonised book form. • To deve lop Financial procedure Manual • To develop proper Accountable documents that have all accounting features BANK RECONCILIATION Monthly Bank Reconciliations statements were not prepared by the Finance Officer. • We recommend that monthly Bank Reconciliation be prepared for all bank accounts maintained by the Serabu Community Hospital and such reconciliations should be reviewed by a Senior Officer in the Finance Office. OWN SOURCE REVENUE • The R eview T eam observed that receipts were not being issued for the various own source revenue received from registry, lab, drugs, and theatre. • Own source revenue collected are not intactly banked. Petty cash expenditures are made from taking on own source revenue before banked . • The R eview T eam also observed unapproved and unregulated expenditure from own source revenue in the form of petty cash. • The request and approval of petty cash is centred around two, James Kamara (Assistant Finance Officer) and Alieu Mansaray (Team Lea d). In the absence of one, the other does the requisition, approval, and payment. Additionally, payments in the form of petty cash were not supported by receipt to confirm the purpose for which the cash was used. • We observed that two mining Companies and an NGO (Non - Governmental Organisation) owed the Serabu Community Hospital a total of Le One Hundred and Seven Million, One hundred and seventy - three thousand Leones (Le107,173,000.00). We observed that the debts ow ed by the two mining Companies have spanned to almost two years without any evidence of payments. • Standardised Receipts be issued for all revenues collected by the hospital. • The request, authorisation, approval, and payment of petty cash be segregated to at least three personnel. • That a petty Cash imprest system with an appropriate float be immediately introduced. • Own source revenue be banked intact. • Managemen t to immediately collect the Le 107,173,000.00 owed to the hospital by the three debtors. STORES • DRUGS MANAGEMENT • The Pharmacist is not trained and qualified • The hospital management should recruit a trained and qualified Pharmacist who is required to work closely with other members of staff • There is no automated recording of the dispensation of drugs in the pharmacy setting • We recommend that there is both manual and automated recoding of drugs in the hospital. • A stock register is not maintained by the in - charges in the wards where they can take on charge drugs received from the patients and also dispensed at any particular point in time, which will be useful to an independent verifier/auditor. • The Pharmacist should develop a stock register to take on charge receipts of drugs and the dispensa tion of drugs in order to determine the stock level for re - order. • There was no evidence to show that the remaining amounts of cash deposit for emergency drugs administered to patients are paid back to them. • We recommend that the bills for the treatment of patients from emergency drugs be prepared and payments made by the patients rather than the cash deposit system. • The cupboard systems for the storage of drugs for patients and the keys kept by the nurses can be a recipe for the abuse of patients’ drugs • W e recommend that the keys for the cupboards be kept by the individual patient's caretaker so that during the dispensation of drugs, the caretaker for those patients can open the drawers to remove the drugs to be administered. PROVISION OF DIET FOR PATIENTS • No copy of delivery note found in the store for food items supplied • Copies of Delivery Notes of goods supplied should be retained by the Matron who supervises the store and ensure that all items are delivered according to specifications.

3. iii TABLE OF CONTENTS ACRONYMS ................................ ................................ ................................ .................. v EXECUTIVE SUMMARY ................................ ................................ ............................... 1 1.0 BACKGROUND ................................ ................................ ................................ .. 9 2.0 OBJECTIVES OF THE REVIEW ................................ ................................ ....... 10 3.0 SCOPE OF THE REVIEW ................................ ................................ .................. 11 4.0 METHODOLOGY ................................ ................................ ............................... 11 5.0 FINDINGS, IMPLICATIONS AND RECOMMENDATIONS ................................ 12 5.1 FINDINGS ON ISSUES HIGHLIGHTED IN THE LETTER OF THE GERMAN DOCTORS ................................ ................................ ................................ .......... 12 5.1.1 PROCUREMENT ISSUES ................................ ................................ ................. 12 5.2.0 RECRUITMENT OF THE THREE MANAGEMENT POSITIONS ....................... 15 5.3. CHOs WORKED FOR A WHOLE WEEKEND WITHOUT GLOVES & M EDICINES ................................ ................................ ................................ ........ 17 6.0. RECOMMENDATIONS OF AN INDEPENDENT REVIEW OF THE OPERATIONS OF THE SERABU CATHOLIC MISSION HOSPITAL, BO DIOCESE SOUTHERN SIERRA LEONE IN JULY - AUGUST 2020 REVIEW .... 19 6.1.1 FURTHER INVESTIGATIONS INTO THE THEFT OF DRUGS AND REFORMS NEEDED ................................ ................................ ................................ ............. 19 6.2. SECURITY ARRANGEMENTS AT THE SERABU COMMUNITY HOSPITAL. .. 20 6.3. THE MANAGEMENT OF THE PHARMACY ................................ ...................... 21 6.4 FINDINGS ON ALLEGED EXTORTION AND THE NEED FOR FURTHER INVESTGATIONS ................................ ................................ ............................... 23 6.5.0 DEPLOYMENT OF SPECIALISTS - GERMAN DOCTORS .............................. 24 7.0. GENERAL SYSTEMIC REVIEW FINDINGS, IMPLICATIONS, AND RECOMMENDATIONS ................................ ................................ ...................... 25 7.1.1 INTERNAL AUDIT, MONITORING, AND SUPERVISION ................................ . 25 8.0 MANAGEMENT STRUCTURE AND ADMINSTRATION OF THE HOSPITAL .. 26 8.1.1 MANAGEMENT OF THE BOARD ................................ ................................ ...... 26 8.2 ADMINISTRATION ................................ ................................ .............................. 28 9.0. FINANCIAL MANAGEMENT ................................ ................................ ............... 31 9.1 FINANCIAL MANUAL ................................ ................................ .......................... 31 9.2 ACCOUNTING DOCUMENTS ................................ ................................ .............. 32 9.3 BANK RECONCILIATION ................................ ................................ .................... 32 9.4 OWN SOURCE REVENUE ................................ ................................ ................... 33 10.0 DRUGS MANAGEMENT ................................ ................................ ..................... 35