2024

ANTI-CORRUPTION COMMISSION OF SIERRA LEONE

An independent institution established for the prevention, investigation, prosecution and punishment of corruption, corrupt practices and to provide for other related matters. 

Contact us on: +23278832131 or info@anticorruption.gov.sl
Address:  Integrity House, Tower Hill, Freetown Sierra Leone, West Africa.

Freetown City Council , FCC 1

System & Processes

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2. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t

1. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t

77. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 75

78. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 76

79. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 77

12. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 10  Untimely Allocation of Grant: Owing to the untimely allocation of tied grants to devolved sectors, activities scheduled for a specific quarter were carried forward to the next quarter which caused these activities to overlap. This normally causes delay in the implementation of programmes.  Poor Filing and Records Keeping: It was observed that devolved sectors did not maintain proper documentations. Their filing systems were poor as they were only concerned with keeping their PET Forms but not the entire documents for an audit trail. Furthermore, copies of transaction were not kept or files unless references were made to the officer in charge at FCC .  Office Space: According to the Local Government Act, devolved offices of Ministries should be provided with office space, and reside in their devolved Local Councils. The team discovered that among all of the Ministries devolved to FCC, only the Officer of Social Welfare was resident at the FCC. The others claimed no office spaces were provided to them by the Management of FCC.  The team found out that the devolved officers of the Ministry of Agriculture resided at Newton which was under the Western Area Rural District Council. It was highly likely that they implemented similar projects which were from different budget lines. This was tantamount to duplication of activities which could create room for corruption.  The role of the Chief Librarian should be separated from the devolved functions of Library activities in the municipality. Every district had an allocation for Library services for their respective regions.  The Review Team noticed that the Chief Liberian had a national function to perform. This made him independent from the work of the devolved officer. However it was observed that the chief Liberian diverted allocations meant for the municipality to national functions (monitoring and supervision of library activities in regions, site visitation etc)  The Management of FCC should provide office spaces to all devolution staff / officers rather than allowing them to work from afar. All devolved officers were required to sign the attendance register at the Council rather than their parent Ministry.  Management of FCC should monitor and supervise the agricultural activities of such devolved sector. Also, the Internal Audit of FCC should conduct an audit and present report to the Management of the Council;  The Sierra Leone Library Board should submit the name(s) of the devolved Officer(s) to FCC rather than the Chief Librarian.

46. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Figure 4: Store environment Figure 3: Systems Processor Taking notes in the Office of the Storekeeper Recommendation Management should either relocate the store to a more ventilated and tidy location, or renovate the current location to make it conducive for purpose. Management Response(s) As we speak funds have been approved by Management for the cleaning of the store of which 70% of the cleaning has been undertaken. 4.5.2 Area of focus: Verification of security items The team made a random inspection on the following accountable documents alongside requisition and suppliers. These documents were printed by the Sierra Leone Government Printing Press 44

25. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Figure 1: A Market Keeper making direct payment at the Cash Office during W orking Hours.  The Cash Office has in store huge amounts (millions) of coins and such monies were still showing in the books of the Council as cash in hand. The coins should have been deposited in- to the Council’s Account at the Central Bank of Sierra Leone. 23 Figure 2: Large Amount of Coins in Store Recommendation(s)  Coins at the Cash Office should be liquidated at the Central Bank.  Management must ensure the avoidance of conflict of interest. The positions of the Chief Cashier and Head of Market should not be performed by one, and the same person. Therefore, Management should urgently designate someone to act as Chief Cashier whilst they recruit for the other position.  Finance Department should ensure that all payments are directly paid into the banks. Also, payments received after working hours must be credited to the banks not later that 12:00PM the following day.

5. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 3 4.13 CONSTRUCTION OF EASTERN MUNICIPAL SCHOOL ....... ...........................................................67 4.13.1 Breach of Procurement Procedures ..................................... ...........................................................68 4.13.2 Misappropriation of Donor Funds ......................................... ...........................................................68 4.14 SOCIAL SERVICES DEPARTMENT ....................................... ...........................................................70 4.14.1 Finding(s) .............................................................................. .................................................,.........87 4.14.2 Area of Focus: Registration of Customary Marriages and Divorces....... ...................................... .71 4.14.3 Area of Focus: Duplication of Function......................... ...................................................................71 4.14.4 Area of focus: Printing of Certification .................................. ...........................................................72 4.14.5 Area of Focus: Charges Levied on Services ........................ .......................................................... 73 4.16.6 Area of Focus: Office Equipment .......................................... ...........................................................73

80. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Published by the Anti - Corruption Commission Headquarters: 3, Gloucester Street, Freetown, Sierra Leone, West Africa Tel.No: 223645 Website: http//www@anticorruption.gov.sl Bo Office Address: 45, Kissy Town Road, Bo Email: info@anticorruption.gov.sl Makeni Office Address: Mena Hill Reservation, Makeni Kenema Office Address: Reservation Road, Off Maxwell Khobe Street Kono Office: 37 Masingbe Road, Koidu City Kono Hotline Nos: 077 - 985985 , 077 986 986 , 078 - 394111 515 (All Networks)

48. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 46 From the above Table, we were able to discover that excess books of 4,170, 2,430 and 17,500 were issued in 2016, 2017, and 2018 respectively to the Municipal Trade Department. No proper explanation or relevant documents were provided to us with regards these excesses in supplies to the Trade Department. Implication(s) Excess printing was considered as wastage of resources and a recipe for corruption. Recommendation(s)  The Internal Audit of FCC should conduct a systematic audit on stores and enforce internal control measures.  The Storekeeper should account to Management for the aforesaid excesses supplied to the Trade Department. Management Response(s) The issue of excess market tickets shown in the table above was due to market tickets printed at the last two months of every year. In this regard, we were not able to use all the 10,000 printed/ procured books, so the balance of these books were stated as a closing balance for that particu- lar year and also served as an opening balance for the next year before requests were raised for new supplies. 4.5.3 Area of focus: Monitoring and Supervision There was lack of segregation of duties in the functions of the finance department and that of Stores as the former supervises the latter. Though Accountable documents were kept in the Store, this did not warrant the Finance department to supervise the Store. The activities of the Store keeper were quite different from that of the Finance Department. Implication(s) The Finance Department disburses payments for all transactions approved by Management. There was conflict of interest for the Finance department to make payment and also supervised the storage of items already paid for. Recommendation(s) The Stores Unit should be supervised and monitored by the Internal Audit Unit. Copies of delivery notes should be forwarded to the Finance Department for accountability purposes.

24. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 22 Implication(s) A debt of Thirty–Seven Billion, Eight Hundred and Eighty Nine million, Three Hundred thousand, Five hundred and Fifty - Six Leones (Le37,889,300,556) would seriously affect the programs and operations of FCC. This also undermined revenue generation. Recommendation(s) Management should constitute a Debt Recovery Unit and /or team to collect such debt. The FCC should take legal action as a means of recovering these monies, where necessary. Management Response(s) Two debt recovery Units SMBJ Holdings & Magic are now in place and also teams from FCC areresponsible for the collection of arrears. For the period under - review, debts have been recovered by these Units and team. iv Cash Office The Cash Office, being a subset of the Finance Department, does collect and compute Own Source Revenues and present same to the Finance Office. Before the introduction of a banking system, the Cash Office had been the main revenue collection point for the Council. With the introduction of a banking system, all payments with respect to revenue must now be paid to either of the stationed banks (Zenith Bank SL and / or Commerce and Mortgage Bank). This Cash Office should submit all revenues collected to the Finance Department. The following were discovered:  The Unit was supervised by the Head of Market, who was also the Chief Cashier. After the Deputy Chief Cashier collated the revenues, documents were sent to the Chief Cashier / Head of Market for decision making, for approval, or action;  We realized that the cash office was still collecting and / or receiving monies for revenue mobilization. According to the Chief Cashier, these monies were collected and / or received from market due collectors who came after working hours, but the monies were later paid into the banks the following day. However, the market due collectors always (whether during or after working hours) paid to the cashiers at the Cash Office rather than the prescribed method of payment to the Banks.

61. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t The team realized that none of the aforementioned has been effected as no supporting document was presented to the team. Also with regards to fine or imprisonment no action has been taken (No supporting documents). Implication Not providing document and implementing the above shows that the unit is not functioning. Recommendations The By - laws being a statutory document should be effected and implemented accordingly 4. 9 MANAGEMENT OF FREETOWN CITY FOOTBALL CLUB (FCFC) Freetown City Football Club (FCFC) was acquired from the Freetown United Football Club (FUFC) by the then Mayor, His Worship Herbert George - Williams. An acquisition fee of Thirty Million Leones (Le30, 000,000) was paid in two installments in November 2008 and January 2009 respectively. It was agreed between the two clubs that four officials were to be taken over by FCFC upon acquisition. The objective of having a Football Club by FCC was to create employment by tapping the skills and talents from youths. Private individuals, Communities, Institutions could own a football club. The common goal of owning a football club was to win silverwares and generate revenue in trading players. FCFC was similar to the Port Authority Football Club (PAFC). The Port Authority administration owns, supervises and monitors the football Club. Finding(s)  The findings show that the administration of FCC was not fully committed to performing it fiduciary duties. They saw the football club as a liability and worth not maintaining. 59

16. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 14 the draft manual given the fact that it still lacked Parliamentary ratification, we nonetheless accepted the fact that its contents were still consistent with international standards, and best practice. Management Response(s) There was a finalized audit manual. See evidence for verification. 4.1.2 Area of Focus: Annual Audit Plan According to International Audit Standards 300 – In planning an Audit of a Financial Statement, the auditor should plan the audit so that the engagement will be performed in an effective manner. The objective was for the auditor to develop an Audit Plan in order to reduce audit risk to an acceptably low level. Finding(s) The Audit team maintained an Annual Audit Plan, but the team was severely limited in executing all activities as contained in the plan for the financial year. Implication(s) Failure to audit all activities as per work plan increased the risk in the management of FCC’s rev- enue and finances. Recommendation(s) Management should urgently ensure that the Internal Auditor Unit is provided with support and logistics required to efficiently, and effectively carry out the activities of the Unit as contained in the Annual Audit Plan. Management Response(s) An audit plan was maintained and activities were undertaken in line with the Annual Work Plan. Any activity not undertaken was carried forward to the following year . 4.1.3 Area of Focus: Audit Committee The Audit Committee played an important role in providing a structured and systematic oversight of the organization’s governance, risk management, and internal control practices. In respect of this, Section 4.3 of the Draft Audit Manual for Local Councils,2004 clearly defined the composition of the Audit Committee:

11. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 9  The Team was told that only Eight (8,) out of a total of eighteen (18), assorted vehicles, including ambulances, (excluding motor bikes) were road worthy. These vehicles were yet to be verified.  No information was provided to the Team with regard boarding vehicles.  With respect to fuel request procedures, it was observed that no technical knowledge was used to determine the quantum of fuel a vehicle or motorbike could consume per kilometer covered. In some transactions, fuel request forms were not attached to the fuel chit;  Unavailability of fuel reconciliation reports with fuel suppliers on fuel allocation;  Fuel was provided to staff on a weekly basis but the team realized that there were staff who were entitled to this facility but did not benefit.  Also, staffs who were without vehicles exchanged their fuel for money lesser than the corresponding value of the fuel chit. Government therefore lost huge sums is this direction;  Furthermore, staff failed to use their vehicles for official purposes dur- ing the time of need; and  There was no policy on fuel allocation.  Fuel supply for extra runs should be backed up with appropriate fuel approval forms and fuel estimate per distance to be cover (especially for provincial travels); and  Only staff with their name printed on their vehicles’ Life Card should be provided with fuel. PROCUREMENT MANAGEMENT Procurement Committee:  We discovered that there was in existence a Procurement Committee but that it was not functional. We did not see any evidence of procure- ment committee minutes neither any correspondence from such Com- mittee regarding approvals for procurement activities undertaken.  As stated in the Act, the Procurement Committee shall be at the helm of all procurement activities undertaken and should be given the necessary support to be effective and efficient in the discharge of their responsibilities. Procurement Records:  The team observed that proper filing system of procurement docu- ments was not maintained.  The Procurement Unit should ensure effective records management and the office environment tidied up by shelving all files. Procurement Irregularities :  Examination of procurement records revealed various irregularities in previous procurements done. The irregularities range from non -compliance to tax and NASSIT laws and failure to provide requisite documents by bidders to improper/non construction of con- tract agreement.  The Evaluation Committee members should ensure that due diligence is followed in awarding contracts to suppliers. Furthermore, the Procurement Officer must ensure all members of the Evaluation Committee sign all evaluation reports before awarding contracts.  Issues will be raised with the investigations department of the ACC for further investigation. DEVOLVED SECTORS  Delay in Remitting Returns: Upon allocation of grants to devolved sec- tors by the Finance Department of FCC, it was expected that the various Finance Officers should forward their returns of previous grant received before requesting for subsequent allocations. The team identified that these Finance Officers usually failed to remit these funds to FCC for proper accountability. They rather submitted PET forms for replenishment. The Council however delays this process until all returns are properly submitted.  The Finance Department of the Council should ensure that all remittances were received from the Finance Officers before subsequent allocations were approved, and transferred to the respective sector(s) to ease the reconciliation process;  The officer in charge of devolved sectors at the Council should make available copies (initiation to completion) of completed transactions to devolved officers for proper filing, and records man- agement;

71. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Koreans, they were to provide the funds while FCC provides the labor. The then City Engineer was the focal person through whom communication was done via emails which were copied to the Foreign Officer of Council. According to some of the correspondences, the Embassy requested the engineer to submit names, contact details, bank accounts and emails of local suppliers so that they (the embassy) would communicate directly with them. Upon completion of the project, the Embassy requested that a donation ceremony be done in April 2018 on the site in the presence of the Korean delegates and that originals of the invoices and receipts were to be collected from the Engineer for accountability purposes. A total of One Hundred and Twenty Thousand United States Dollars ($120,000) an equivalent of Seven Hundred and Nineteen Million, Nine Hundred and Seventy Thousand Leones (Le 719,970,000) was generated by the Koreans and each supplier’s account were credited with their respective amounts. In an examination of this contract, the following were observed: 4.1 3.1 Breach of Procurement Procedures There were no bidding procedures undertaken considering the quantum of money involved. The Procurement Department was not involved in the selection of the four (4) suppliers submitted to the Korean Embassy in Nigeria. The suppliers were:  Rural and Urban Construction and General Supply  EDSHERIE Construction Company Ltd  SAMTECH enterprise Metal Works and Training Center and  HF Building Materials and Hardware. The engineer being the mediator, created email accounts for each supplier and maintained the password. He also facilitated the opening of United States Dollar Accounts of the suppliers from various banks. All communications from the Embassy to the suppliers were received by the engineer and later communicated to them when their accounts were credited; The suppliers never knew who contracted their services as they were only communicating with the engineer and taken instructions from him. 4.1 3.2 Misappropriation of Donor Funds Section 36(1) of the Anti - Corruption Act (ACA) of 2018, states that “A person who misappropriates public funds or property commits an offense” 69

31. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Budgeted Figures Actual Revenue Variance Revenue 2016 2017 2018 2016 2017 2018 2016 2017 2018 Local Tax 682,500,000 682,500,000 716,625,000 52,194,000 42,575,000 96,085,000 (630,306,000) (639,925,000) (620,540,000) Property Tax 12,831,197,890 10,872,951,267 11,416,598,830 4,104,112,429 4,217,267,575 3,559,600,600 (8,727,085,461) (6,655,683,692) (7,856,998,230) Market Dues 1,755,000,000 1,842,750,000 1,934,887,500 1,270,670,000 1,112,406,500 1,695,265,000 (484,330,000) (730,343,500) (239,622,500) Business Licenses 3,503,440,000 3,678,612,000 3,597,942,600 2,878,815,500 2,404,438,598 2,912,653,294 (624,624,500) (1,274,173,402) (685,289,306) Burial Fees 318,375,000 334,293,750 351,008,438 146,162,500 125,351,514 90,941,000 (172,212,500) (208,942,236) (260,067,438) Lease/Rent Property 1,543,500,000 1,620,675,000 1,701,708,750 138,604,350 1,060,845,950 183,175,068 (1,404,895,650) (559,829,050) (1,518,533,682) Lorry Park 121,500,000 127,575,000 133,953,750 - 424,118,602 696,11 8,602 (121,500,000) 296,543,602 562,164,852 CBO Regis- tration 96,000,000 100,000,000 105,840,000 94,570,000 130,490,000 141,470,000 (1,430,000) 30,490,000 35,630,000 Bill Boards 160,000,000 168,000,000 176,400,000 195,366,000 319,711,000 657,848,995 35,366,000 151,711,000 481,448,995 29 4.2.4 Comparative Analysis between Budgeted and Actual on Owned Source Revenue

7. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t EXECUTIVE SUMMARY Consistent with it’s mandate to prevent corruption in public bodies, the Anti Corruption Commission ((ACC) conducted a systems review of the Freetown City Council (FCC). The Council is the oldest in S ierra Leone and receives the highest transfer from Central Government. The total amount transferred to th e Council amounts to Le3,729,176,550representing 12.13% of the total amount transferred to Councils in the Fiscal Year 2018. The review entailed an examination of the practices and procedures of the Council in order to identi fy weaknesses and gaps in the system that will give rise to corruption and undermine service delivery. The review concluded with recommendations that are given to address these weaknesses and gaps. The revie w covers the period 2015 to 2018 and various thematic areas were examined including Internal Controls, Financial management, Human Resource Management, Fleet and Fuel Management, stores management, Procurement and the operations of the devolved sectors. The summary of Key Findings and Recommendations are tabulated as follow: FINDINGS RECOMMENDATIONS INTERNAL CONTROL There is no approved Audit Manual.  The draft Audit Manual of Sierra Leone 2014 should be revised and subse- quently approved by Parliament. Limited audits are carried out due to lack of supports and logistics.  Management should urgently ensure that the Internal Auditor Unit is provided with support and logistics required to efficiently, and effectively carryout the activities of the Unit as contained in the Annual Audit Plan. Audit Committee is improperly constituted and remains ineffective.  Management should ensure an Audit Committee be immediately established and it’s membership properly constituted to augment the work of the Audit Department. Management of the Council has failed to act on findings and queries/recommendations of the internal audit reports.  Management, alongside the Audit Committee, should ensure that internal audit queries were treated with the greatest concern, and recommendations proffered are thoroughly implemented. The operations of the devolved sectors are not audited.  Management should empower the Audit Unit to conduct extensive and regular mandatory audits on all projects of devolved Sectors, from initiation to completion, in order to ensure value for money. FINANCE DEPARTMENT Revenue Generation: Municipal trade / Market toll  There was poor monitoring and supervision of Market Keepers (collectors of market dues) and they are properly identifiable.  Monies collected from market dues were paid to the cashier rather than to the bank. .  Receipt Books were supplied on a weekly basis but were not reconciled accordingly. Instead of balancing-off weekly, new stocks were supplied to add up to the existing stocks.  There are over lapping duties/roles in the management of Market Toll: the head of trade also head of cashiers.  Market Keepers should be provided with uniforms or identity cards for easy identification. Monitoring and supervision of Market Keepers and market places should be effectively and regularly conducted.  There should be mandatory reconciliation of the receipt books supplied, used and sales before subsequent supplies.  There should be segregation of duties in the management of funds to avoid conflict of interest. 5

75. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t The team identified that functions, which were carried out by the devolved Ministries, were also undertaken by the Social Services Department. Implication(s) It would lead to mismanagement of government resources and conflict in reporting. Recommendation(s) Management should ensure that all functions outlined in the Act on the devolved sectors should be undertaken by the devolved sectors themselves. Management Response(s)  Before the devolution, FCC being the oldest Council had been carrying out most of these functions (such as disability issues, child welfare and gender issues). We therefore only needed to collaborate.  As for registration of CBOs, Council started the process before the coming of Devolve Officers in the FCC. Collaboration with the devolve officer in the registration of CBOs is now done directly by Local Council’s designated staff. 4.1 4.4 Area of focus: Printing of Certification Finding(s) The team identified that certificates printed from the Government Printing were not sequentially printed year in year out. A serial number will be given to two different certificates of different years. These were sensitive documents that needed distinctive features. Implication(s) Such practices undermines transparency and creates opportunities for corruption. Recommendation(s) Management should make sure that certificates are sequentially printed to avoid duplication. Management Response(s) The printer has been advised to strictly follow your recommendation to follow the proper numbering/serial procedures 73

74. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Implication(s) Being in an acting position for over years without any form of incentive can serve as de - motivation for that officer. Recommendation(s) The Management of the Council should consider making the position substantive, based on the performance of the current job holder. Management Response(s) The status of the Deputy Head of the department has been rectified. 4.1 4.2 Area of Focus: Registration of Customary Marriages and Divorces Section 8 (1)of the Registration of Customary Marriages and Divorces Act 2009 states that “Where a marriage has been contracted under customary law, either party to the marriage or both parties shall apply in writing to the Local Council for registration of the marriage”. The team found out that the due processes as stated in Part III of the Act were not followed. Implication(s) Failing to comply with the due processes may encourage fraudulent registrations. Recommendation(s) The Department should follow the due processes as stated in the Customary Marriage and Di- vorce Act 2009. Management Response(s) Upon receipt of application, accompanied by pictures of spouse and affidavit in support of marriage, it was forwarded to the Chief Administrator for perusal and authorization to proceed with the registration process. 4 .1 4.3 Area of Focus: Duplication of Functions Finding(s) The Local Government Act 2004 clearly defines the devolved Ministries and their functions. One of the devolved Ministries to the Council was the Ministry of Social Welfare, Gender and Children’s Affairs, which was the only devolved Ministry located in the Council. The Act states the specific functions to be undertaken by the devolved Ministry, such as Family Case Work, Probation, Disability Issues, Child Welfare, CBOs, and Gender issues. 72

73. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  A donation ceremony as requested by the Koreans was actually done in the presence of the Korean Delegates (including the Ambassador), school authorities, and Management staff of FCC.  The review team considered this action as a misrepresentation as no work was done with funds provided by the Koreans.  The School in question was actually built by a philanthropic organization from UK, called ‘ Make it Happen’ . They provided everything including labor and handed the keys of the completed school building to the then Mayor of FCC. Recommendation(s)  All monies misappropriated by suppliers must be paid to the ACC;  The FCC should conduct internal investigations on the said project and forward same to the ACC;  An investigation should be conducted by the ACC to determine the veracity of the allegations. Management Response(s) The allegation is already under investigation by the Investigation department of the ACC. 4.1 4 SOCIAL SERVICES DEPARTMENT The Social Service Department is responsible for organizing and implementing all social activities of the Council. It was specifically established to address issues relating to Women, Children, the Aged, and Disable . Groups etc. The Department’s roles and responsibilities were classified into civic functions, func- tional activities, disability and gender Issues, revenue mobilization and disaster management. In terms of revenue generation, the Social Service Department specifically carries out registration for customary marriages and divorces, issues out permits on publicity, registration of Community Based Organizations (CBOs), orphanages, hiring of FCC properties, etc. 4.1 4 .1 Area of Focus: Acting Position Finding(s) The Deputy Head of the Social Service Department has been acting in that capacity for a very long time without any acting remuneration or written confirmation of the position. 71

49. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Management Response(s) The Internal Audit has taken the responsibility to supervise the stores. 4.5.4 Area of focus: Staffing Storekeeping is a delicate job and requires more than one personnel to undertake such task. However, it was realized that the Storekeeper had no deputy and /or Assistant in discharging his duties. Implication(s) The absence of an Assistant Storekeeper will stall the entire work process as there would be no individual to help the Store Keeper during work and when he is absent. Recommendation(s) Management should ensure that the Storekeeper is provided with an Assistant to assist him in the discharge of his functions for effective and efficient delivery of service. Management Response(s) Modalities will be put in place for additional staff. 4.5.6 Area of Focus: Leave of Store Keeper The Storekeeper has been in office for almost three (3) years and has never benefited from his rightful entitlement to annual leave. Implication(s) Not taking annual leave can impact productivity levels and staff morale. Recommendation(s) The Human Resources Manager should ensure that the Storekeeper and all staff enjoy their entitlement of annual leave. Management Response(s) It is true that the Store Keeper has not been on leave for three years now. His leave was paid for last year his services were highly needed due to the fact that External Auditors were around and he needed to answer to questions and submit them with information to help them with their work. 47

53. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Implication(s) The non - existence of a Procurement Committee affects the timely execution of procurement con- tracts and value for money is not ensured. Recommendation(s) As stated in the Act, the Procurement Committee shall be at the helm of all procurement activities undertaken and should be given the necessary support to be effective and efficient in the discharge of their responsibilities. Management Response No response 4.7.2 Area of Focus: Staff Capacity Section 17(1) of the National Public Procurement Act (NPPA) 2016 states that “Procurement - related functions shall be carried out by procurement persons, trained, and knowledgeable in accordance with the guidelines, and qualification requirements established by the Authority.” Also, Section 19(1) of the Public Procurement Act 2016 states that “A Procurement Unit shall be established in each procuring entity, staffed with persons trained and knowledgeable in procurement and charged with carrying out, on a continuous basis, functions related to procurement”. Finding(s) The team identified that of the five (5) staff in the Unit, only two (2) (the Procurement Officer an d the Procurement Assistant) had qualifications /or trainings in Procurement. Procurement functions were carried out by untrained personnel with little knowledge in procurement. Implication(s) Untrained personnel were normally not strongly positioned to effectively discharge their tasks giv- en the fact that they may not be very familiar with their subject matter. Recommendation(s) Staff in the Procurement Unit should be trained (upgraded) by Management in procurement pro- cesses. Management response No response 51

37. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 35 Management Response(s) No response 4.3.4 Area of Focus: Staff Personal Files /Records Staff File consists of a series of employee related documents that collectively make a central personal file. The file contains information that directly relates to an individual, including recor ds that provide evidence of their employment. In some cases, there may also be administrative staff files that document specific issues; such as compensation or grievances etc. and/or local area staff files that are intended for reference purposes. Files can be stored in any order that suits your area’s business processes. All records relating to an individual should always be kept together on a single file that clearly identifies the name and ID number of the employee. Finding(s) It was observed that as a result of the on - going decentralization process, the filing systems of staff records were also being decentralized. All divisional heads kept files of their respective st aff which was not a good practice. Moreover, most files examined did not contain relevant documents like certificates, testimonials, CV’s and other staff personal information. Implication(s)  The practice of staff personal files maintained by Departments will render the Function of the HR department ineffective.  Failure to update personal files of employees of relevant documents will limit information on that employee for staff development. Recommendation(s) The HR and Administration Department should exclusively handle all staff matters, including staff personal files, and they should ensure that such records are regularly updated. Management Response(s) No response 4.3.5 Area of Focus: Staff Performance Appraisal Performance Appraisal is the systematic evaluation of the performance of employees and it helps to understand the abilities of a person for further growth and development .

38. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Regulation 11.2 of the HRM Guidelines stipulates that “staff members shall be evaluated for their efficiency, competence, and integrity through performance appraisal procedures that shall assess the staff.............................” Finding(s) The review team identified that there were no performance appraisal system in the Council. An effective appraisal and performance management process can have a significant impact on the Council’s culture, staff morale and employee engagement levels – all of which enhance employer brand and support the retention of key talents within the Council. Implication(s) In the absence of an appraisal system, the Council cannot measure the performance of its employees for promotions and training. Recommendation(s) A staff appraisal system is to be developed in order to allow line Managers to provide feedbacks on employees’ performance as well as identifying areas for improvement for the employee. Management Response(s) No response 4.3.6 Area of Focus: Job Description A job description is a document that describes the general tasks, or other related duties, and responsibilities of a position. It may specify the functionary to whom the position reports, specifications such as the qualifications or skills needed by the person in the job, and a salary range. Finding(s) It was observed that job descriptions were not provided to employees when recruited but however, some were issued with a Term of Reference(ToR) which contained all information necessary for the employee's attention. Implication(s) Hiring employees without a written job description could lead to reduced productivity when the new hires are unprepared for their duties and require extra training to fulfill their jobs. Employees who work without clear direction can become confused, frustrated and demoralized. 36

69. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Management Response(s) The head of department has recommended the retention of the three(3) interns that are hardworking in the office. This has not been done yet. 4.1 2.2 Area of Focus: Capacity Building It was generally accepted that capacity building was closely related to education, training, and human resource development. Therefore, employees needed improvements in their ability to perform appropriate task within the set of performance standards in the institution. Finding(s) The review team observed that staff in the Department have not benefited in any training relating to their job. This could ensure employee skills and knowledge are up to date. It would also improve on staff morale. Implication(s) Lack of training would hinder the staff ability to improve and retain skills, knowledge on the sub- ject matter to perform appropriate task needed to ensuring that the institution’s goals are achieved. Recommendation(s) Management should ensure that staff in the Education Department are accordingly trained to develop their competencies and skills in order to improve effectiveness and increases efficiency in the Job. Management Response Only the head of department had a PHD, the rest needed to be encouraged to study . 4.1 2.3 Area of Focus: Distribution of Teaching and Learning Materials Finding(s) The Education Department was constrained with the distribution process as there were no official vehicles, and or motor bikes to convey these materials and staff to the various destina- tions, including inspections. Implication(s) Distributions of teaching and learning material were time bound and delay would lead to ineffective running of the school’s administration. 67

76. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 4.1 4.5 Area of Focus: Charges Levied on Services Finding(s) The team identified that even though there were stated prices for the different services rendered, yet charges were levied discretionally. Implication Discretional charges may create opportunities for corruption Recommendation(s)  Prices approved by Management should be strictly followed. Any changes should be communicated to the Chief Administrator for approval. Changes in levies should also be communicated to the public.  Service Charters should be erected with prize quotations for various services clearly stated. Management Response(s) The department has adopted your recommendation to request for charges as stated by Council. 4.14. 6 Area of Focus: Office Equipment Finding(s) The review team observed that the Department lacked office equipment such as printers, computers, and photocopier to help execute their duties. Furthermore, they were not provided with logistics to conduct background checks on marriages, divorces, and family tracing. Recommendation(s) Management should provide logistics for thorough checking on marriages and / or divorce matters before certificates were issued. Also, Management needs to urgently address these is- sues as they constituted the main activities of Department. Management Response(s) The department has forwarded a list of office equipment needed for the procurement office and the procurement process is in progress. 74

14. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 12 water/cheap alcohol sachets, shopping [plastic] bags, and water containers. This complicates an already difficult task of managing city waste. Moreover, the absence of an adequate and effective waste management system has caused both health and environmental problems. Residents dumping waste and dirt in the wrong places have not only led to clogging and blocking drainages and watercourses in the city, but have also raised very serious environmental questions. This has undoubtedly led to costly flood - related accidents as evidenced by the Mud slide at Mount Sugarloaf in the West End of Freetown. The population of Freetown is over one million with a growth of 4.2% per annum. 95% of the population does not have access to public water system provided by the Guma Valley Water Company (GVWC). FCC faces increasing demand for services from residents, yet the city’s tax base is limited, and levels of collection are among the lowest in West Africa. There is need therefore to improve equity in enforcement, and strengthen transparency, and dialogue with tax- payers to build trust. 2. 0 OBJECTIVES OF THE REVIEW  To promote efficient and effective service delivery at the FCC;  To improve ethical behavior in the organization;  To ensure recommendations are implemented; are economical, efficient and effective.  The law provides that if a vehicle is not parked in a designated parking area, such vehicle should be clamped for obstruction. Furthermore, clamping of such vehicle has a penalty fee which is to be paid into an account. The team discovered that no revenue was generated from the clamping of vehicles during the period under review but there were evidences to show that the offences were committed.  A total of Two Hundred and Forty nine million Five Hundred and Seventy Thousand Leones (Le 249,570,000) was debt owed to the FCC due to failure to pay fees for parking spaces;  No policy or contract document was shown to the review team that would signify binding agreement between the FCC and the said institutions. 3. 0 METHODOLOGY AND SCOPE The methodology for this study involved a desk - based review of relevant documents, and internet research of similar reviews in other municipalities. Accordingly, the team conducted interviews with key staff especially “those who bear the greatest responsibilities in the performance of their duties,” in line with the review objectives. Documents

44. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  The Team was told that only Eight (8,) out of a total of eighteen (18), assorted vehicles, including ambulances, (excluding motor bikes) were road worthy. These vehicles were yet to be verified.  No information was provided to the Team with regard boarding vehicles . Recommendation(s)  Accountable tools such as Logbooks, Vehicle Movement Register/Tracking System, Vehicle Request Form, Fuel Request Form, Fuel Distribution Ledger, Fuel Chit, Maintenance Request Form, Maintenance Reporting Template etc. should be developed by the Transport Unit and be operational at all levels of the Council;  The Transport Unit should ensure that files are maintained for vehicles;  A credible data base of all automobiles under the purview of Council should be developed, and regularly updated; Management Response(s)  A comprehensive data base has been set up, both electronic and hard copies. See evidence attached:  Accountable tools, such as vehicle movement register and vehicles request form are yet to be developed. A request has been sent to the procurement Unit for procurement of log books. It is only few of the audio vehicle meters that were not working. They have been checked by the Head of Maintenance. We are waiting for their repairs.  Accountable tools such as maintenance forms, reporting template and routine maintenance schedule for each automobile is yet to be developed. We however do have maintenance ledg- er books.  Fleet Management is done by the Transport Officer and supervised by the CA/HR.  Twenty - four(24) vehicles including the Ambulance were road worthy and not eight (8) out of eighteen (18) as was reported. They can be verified at any time.  List of vehicles to be boarded are available for verification. See documents attached . 4.4.2 Fuel Management The review exercise revealed the following:  With respect to fuel request procedures, it was observed that no technical knowledge was used to determine the quantum of fuel a vehicle or motorbike could consume per kilometer covered. In some transactions, fuel request forms were not attached to the fuel chit; 42

51. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 4.6 METROPOLITAN POLICE The Metropolitan Police Department of the Council is charged with the responsibility of maintaining law and order within the municipality of Freetown, thereby helping Council to enforce the bye laws of the Council’s Act of 2004. Finding(s)  In May 2010, 119 Metropolitan Police Officers were recruited with a probationary period of six (6) months from the date of commencement of employment.  Section 2.34 of the Revised Human Resource Management Guidelines for Local Government states that: “on first appointment to a permanent post, the probationary period for junior officers (Grades 1 - 5) shall be 3 months, and for Grades 6 upwards – 6 months. Appropriate line supervisors shall assist the Chief Administrator in collating assessment details.”  Furthermore, Section 2.39 strengthens the point: “In principle, probationary periods may not be extended beyond the period set out in 2.34......................”  These newly recruited staff members were never given confirmation letters for appointment after the probationary period not until 18 th July 2016 (five years had elapsed). It was stated in their appointment letter dated 18 th July 2016 that “you will be absorbed into the permanent establishment of Council with effect from 15 th December 2011 ”. Furthermore, these personnel were called into a meeting on 26 th July 2016 to sign an agreement that stated among other things that “ confirmation letters be issued out immediately without any financial obligation to the Freetown City Council” .  We noted from interviews conducted with these Officers that, they were under duress to sign the contractual agreement for them to forgo their accrued claims; failing to comply on their part would result in forfeiting their jobs.  In June 2014, 37 Metropolitan Police Officers were promoted to the ranks of Sergeant, Inspector, Assistant Superintendents, and Superintendent. These promoted Officers were decorated in ranks, but Council was still indebted to them financially and the Officers had not received their promotion letters. The team later discovered that several memos had been writ- ten to the then Chief Administrator to effect the change, but yet no action had been taken;  The Metropolitan Police are graded in ranks (e.g. Inspector, Superintendent Etc) unlike other staff that were ranked as junior, intermediate and senior staff. The team discovered that, the HR department had never placed the Metropolitan Police in grades to be consistent with their ranks; and 49

17. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 15 An external member as chairman who is knowledgeable in the operations of the Council; One external person as an ordinary member; and Councilors as members with vast knowledge in accounting/auditing/ or administrative issues. Finding(s) The review team discovered that the previous Audit Committees had been chaired by a seating Councilor. This contravened the prescription of the Manual as stated above. Implication(s) An Audit Committee, chaired by a sitting Councilor, affected the independence, and objectivity of the Auditors. Also, there would be conflict of interest in discharging his duties as a political figure,as well as addressing the organization’s governance, risk management, and internal controls. Recommendation(s) The Audit Committee should be chaired by an external member who is knowledgeable in auditing as stated in Section 4.3 of the Draft Audit Manual for Local Councils. Management Response(s) There was an Audit Committee. Letters were being issued to individuals to constitute the Audit Committee .Currently we are awaiting the Mayor on the selection of the Audit Committee Chairman who is supposed to be an external person. 4.1.4 Area of Focus: Tenure of the Audit Committee Section 4.2.5 of the Draft Audit Manual states that “members of the Audit Committee shall serve on the Audit Committee for not more than two terms of the two years each (no more than four consecutive years)” Finding(s) At the time of our intervention, there was no officially constituted Audit Committee at the FCC since the expiration of the previous one a year ago. Implication(s) The non - existence of an Audit Committee would affect the effective corporate governance, independence, and objectivity of the auditor, and the quality of the audit. Recommendation(s) Management should ensure an Audit Committee be immediately established to augment the work of the Audit Department.

62. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  The administration of the football club was single handedly managed by the Club Manager, who had less or no supervision of the affairs of the Club. The Club Manager reports to the Chairman of the FCFC, who happened to be the Chairman of the Sport Committee of the FCC (conflict of interest). The Chairman was suspended for collaborating with the Club Manager on clear issues of conflict of interest;  A 30 - man list of players was presented to the Sierra Leone Football Association (SLAFA) as the registered players of FCFC. These players were given an employment or engagement letter by the Management of FCC. The engagement letter stated that Council could assign other duties to players as and when necessary. In addition, Council would continue paying players monthly salaries (including allowances) upon player’s continued stay in the Club. Players were recruited as support staff of the Council, and were part of the FCC team that collected taxes in the Municipality of Freetown.  Some players including Osman Bangura were dropped from the team by the Club Manager (Mr. Francis Palmer - Wright) on the 1 st of June 2013. Osman Bangura was replaced with Edward Fornah. His salary was immediately transferred to Edward Fornah. The act of sacking and replacing players was done also on various occasions. No letters of termination were giv- en to them by the administration of the FCC neither a transfer lease from the Management of FCC;  The Chairman and the Club Manager signed the letters of termination which instructed the Management of FCC to delete the names of sacked players from the payroll by replacing them with the selected players. These were not communicated to the Human Resources Department;  There was no Board of Directors for the football club;  The Club Manager alleged that FCC owed him the sum of (One Hundred and Thirty One Million, Two Hundred and Ninety Three Thousand, Two Hundred Leones (Le131,293,200) for pre - financing activities in the football club. No written document existed to authenticate his claim;  The Club Manager was involved in the buying and selling of players during the transfer market. The Management of FCC was unaware of some of the sale of players, as proceeds from these sales were not credited into the FCFC account or brought to the attention of the Finance Department.  A former coach, John Agina Sesay, allegedly misappropriated Eighteen Million Leones (Le18,000,000) for the sale of three players (James Zino Conteh, Mohamed Zack Sesay, and Unisa Kalusha Conteh) to Diamond Stars FC. He also received One Million Five Hundred Thousand Leones (Le1,500,000) from Ports Authority in respect of balance payment for Desmond Wellington; and  Improper accountability on proceeds from the sale of players was a loophole for corruption. Below are names of some players sold with amounts to various football clubs with no 60

55. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Recommendation(S) The Procurement Unit should tidy the office environment by shelving all files. Management Response No response 4.7.5 Area of Focus: Debriefing to |Unsuccessful Bidders Section 27 of the NPPA state“ that a procuring entity shall immediately, after a successful bidder has been identified, inform the unsuccessful bidder(s) of the reason for which their respective bids were unsuccessful”. Sec 28(1) also provides as follows:“Subject to this Act, documents, notifications, decisions and other communication referred to in this Act, to be submitted by the procuring entity to a bidder, or by a bidder to the procuring entity, shall be in writing” Finding(s) The review team observed that the Procurement Unit had never communicated / or debriefed, informed the unsuccessful bidder(s) in writing. Implication(s) Withholding information that is to be provided to an unsuccessful bidder, as a prerequisite of a procurement process raises suspicion. Recommendation(s) For proper accountability and transparency, the Procurement Unit should always communicate in writing to all bidders whether successful or not. Management Response No response 4.7.6 Area of Focus: List of Suppliers/ Vendors Supplier’s evaluation is the process of evaluating (scanning) and approving potential suppliers by quantitative assessment. This is to ensure a portfolio / or data of best in class suppliers are available for use. Choosing the right supplier depends on a wide range of factors such as value for money, quality, reliability, and service. Finding(s) The Procurement Unit has a Suppliers’ Data, or Vendors List, which is an acceptable practice in procurement. Upon inspection and verification of the suppliers list, the team identified that most 53

50. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 4.5.7 Area of focus: Records Management There was not an adequate records management governance structure to provide an accountability framework of records management practices. Further review revealed the following:  There was no digital records system to catch up with the modern day’s technology as the Records Management Unit heavily relied on manual records keeping.  The Storekeeper never maintained a Store Records Vouchers for every item in Store.  Documents were placed everywhere which made it very difficult for the storekeeper to trace records. . Implication(s)  With electronics recording, it was easier to back up information and to keep information safe in case of fire or theft.  Failing to maintain a Store Records Voucher may lead to poor accountability and creates room for corruption.  With no proper shelving system, it would be difficult to trace documents and/ or items as they were all clustered. Recommendation(s)  Management should ensure that the Storekeeper is provided with a workable desktop for the computation, and storing of data. Furthermore, store records software should be used for ease of reference.  Management should ensure that the Storekeeper maintains and works with Store Record Vouchers. Every document should be displayed on the shelve and categorized. Management Response(s) The Store Keeper has been issued with a laptop to help him with his office duties. NB. All requisition for receipt books and all other Accountable documents for revenue purposes were now recorded directly in the Store Issue Voucher and Stores Requisition Voucher. This was also done for the issuing of other items in stores. All documents for revenue materials were now packed by items and serial number on the shelves in the store and can be easily identified by items and description. It can easily be picked up when needed by user departments. 48

34. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 32 value of assets, date of acquisition, and depreciation. It can be used to track all assets of a company. Finding(s) The review team observed that FCC did not maintain a fixed Assets Register. Implication(s) The Accountant will be unable to estimate the value of the assets of the Council in the absence of a fixed Register. Tracking of the Council assets will be difficult as there are no records to follo w. Recommendation(s) A Fixed Asset Register must be maintained so that assets are tracked, recorded for proper report- ing and audit purposes. The assets can also be coded for ease of identification. Management Response(s) No response 4.2.8 Area of focus: Minimum Wage The then Minister of Labour and Social Security, Dr. Matthew M. Timbo, tabled the statutory instrument No.6 of 2014 on the Regulation of Wages and Industrial Relations Act of 1971 (Act No.18 of 1971). Parliament unanimously adopted the minimum wage statutory instrument for the private sector and increased the minimum wage. This instrument, provided that“ the National Minimum Rate of Payment for Workers, shall now be Five Hundred Thousand Leones (Le500,000.00) and would come to effect on the 1st day of January 2015”. Finding(s) It was discovered that FCC never complied with the minimum wage payment to its workers as was provided by law and this affected about 71 casual workers in the institution since January 2015.These officers received Le350, 000 per month. Implication(s) Payment below minimum wage contravened the statutory instrument of 2015. Recommendation(s) With immediate effect the Council should commence the minimum wage payment to its workers and backlog payments are to be made to the affected staff. Management Response(s)

68. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Management Response No Response 4.1 2 EDUCATION DEPARTMENT The Education Department is responsible for the supervision of 56 Municipal Schools by providing Administrative assistance to these schools. The Ministry of Education has devolved Basic Education (i.e. the Primary and Junior Secondary) to Local Councils. Since the devolution of the Basic Education to the FCC, there has been an increase in the number of primary schools from 56 to 400. The FCC has also incorporated 80 Junior Secondary Schools as part of its responsibilities. The Department also supervises the conduct of exams for both Primary and Junior Secondary Schools at NPSC and BECE levels respectively. Also, the Department ensures the rehabilitation and / or construction of schools, and work closely with development partners to achieve this objective. The Education Department of FCC was actively involved in the distribution of the teaching and learning materials to the approved government and government assisted schools to ensure transparency and accountability in the process. As a Department, they ensured that private schools met all the necessary requirements stated for approval to operate as a government assisted, or community school. The under mentioned were discovered by the review team in their operations. 4.1 2.1 Area of Focus: Staff Strength Finding(s)  The Department of Education was under staffed, and it was quite apparent that with the numerous work and activities, they could not effectively execute the functions of the Department;  Given the wide scope of activities, and sensitivity of their task, the Department was not well equipped to facilitate its activities. Implication(s) Limited staff capacity hinders the effectiveness and efficiency of the Education Department in the discharge of their duties .. Recommendation(s) Management should ensure an increase in the staff strength, and that the Department is well equipped for effective and efficient service delivery. 66

52. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  The head of the Metropolitan Police had been in an acting position for over Seven (7) years with no written document to confirm his status. Recommendation(s)  Management of FCC has to regularize their financial obligation with respect to those promoted Officers;  HR Department should synchronize the grades and /or ranks of Officers to that of support and core staff; and HR Department should ensure all acting positions become permanent, and the rules, laws, and policies of employment must be strictly followed. Management response No response 4.7 PROCUREMENTMANAGEMENT Procurement Management is the systematic approach used for buying all the goods and services needed for a company to stay sustainable. When procurement is managed well, it would add val- ue to all business practices, and save both time and money. Furthermore, the goals of the procurement cycle are to:  Manage spending;  Support operations; and  Protect the organization from risk.  Procurement activities at FCC are sourced from Owned Source, GoSL Reproductive Child Health Program and DSDP. 4.7.1 Area of Focus: Procurement Committee Section 18(1) of NPPA 2016 states that: ‘a Procurement Committee shall be established in every procuring entity”. Also, according to Sec.18 (8) of the same Act, ‘a Procurement Committee shall make necessary arrangements tenure that timely information on the execution, and conclusion of contracts by a Department or Division of a procuring entity, as well as on supplier, contractor or consultant performance is reported to the Procurement Committee’. Finding(s) We discovered that there was in existence a Procurement Committee but that it was not functional. We did not see any evidence of procurement minutes neither any correspondence from such Committee regarding approvals for procurement activities undertaken. 50

56. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t of the awardees of contracts were not in the list. Implication(s) Lack of Suppliers’ Data or Vendors List would pose challenges in choosing alternatives in order to determine value for money. Suppliers’ Data is also necessary, as suppliers’ evaluation is a contin- ual process within an entity. Recommendation(s) The Procurement Unit should have an effective supplier database for ease of reference for the procurement of goods and services. Management Response No response 4.7.7 Area of Focus: Requisition Book Finding(s) There were no requisition books, which staff members use to request for office items / or stationery. Goods were procured and supplied without being requested for through the requisition books. Implication(s) Lack of requisition books for procurement of goods, and services, would pose challenges in track- ing the allocation and utilization of resources. Recommendation(s) A Requisition Book should be maintained by all Units of the Municipality. The Requisition Book has to be filled, signed, approved, and forwarded to the Procurement Unit for supply. Management Response No response 4.7.8 Area of Focus: Qualification/ Disqualification of Bidder Section 21(1) of NPPA 2016 states that “In order to be awarded a contract, or, if prequalification processes are being held, in order to participate in the procurement processes, a bidder must qualify by meeting the criteria set by the procuring entity which may include–  (a) Professional and technical qualifications;  (g) Financial resources and condition;  (i) Assessment by the National Revenue Authority (NRA) to ascertain payment of taxes; and  (j) Payment of social security contributions. 54

67. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  Poor Filing and Records Keeping: It was observed that devolved sectors did not maintain proper documentations. Their filing systems were poor as they were only concerned with keeping their PET Forms but not the entire documents for an audit trail. Furthermore, copies of transaction were not kept or files unless references were made to the officer in charge at FCC .  Office Space: According to the Local Government Act, devolved offices of Ministries should be provided with office space, and reside in their devolved Local Councils. The team discovered that among all of the Ministries devolved to FCC, only the Officer of Social Welfare was resident at the FCC. The others claimed no office spaces were provided to them by the Management of FCC.  The team found out that the devolved officers of the Ministry of Agriculture resided at Newton which was under the Western Area Rural District Council. It was highly likely that they implemented simila r projects which were from different budget lines. This was tantamount to duplication of activities which could create room for corruption. .  The role of the Chief Librarian should be separated from the devolved functions of Library activities in the municipality. Every district had an allocation for Library services for their respective regions. The review team noticed that the Chief Liberian had a national function to perform. This made him independent from the work  Work of the devolved officer. However it was observed that the chief Liberian diverted allocation s meant for the municipality to national functions (monitoring and supervision of library activities i n regions, site visitation etc) Recommendation(s)  The Finance Department of the Council should ensure that all remittances were received from the Finance Officers before subsequent allocations were approved, and transferred to the respective Sector(s) to ease the reconciliation process;  The officer in charge of devolved sectors at the Council should make available copies (initiation to completion) of completed transactions to devolved officers for proper filing, and records management;  The Management of FCC should provide office spaces to all devolution staff / officers rather than allowing them to work from afar. All devolved officers were required to sign the attendance register at the Council rather than their parent Ministry.  Management of FCC should monitor and supervise the agricultural activities of such devolved sector. Also, the Internal Audit of FCC should conduct an audit and present report to the Management of the Council;  The Sierra Leone Library Board should submit the name(s) of the devolved officer(s) to FCC rather than the Chief Librarian. 65

54. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 4.7.3 Area of Focus: Procurement Plan Procurement planning is the process of identifying and consolidating requirements and determining the timeframe for procurement with the aim of having them as and when they are required. A good procurement plan will describe the process in the identification and selection of suppliers/contractors/consultants. According to Section 29(1) of the NPPA 2016, all procuring entities shall undertake procurement planning, with a view to achieving maximum value for public expenditures and the other objects of this Act. Finding(s) The review team did not access any procurement plan for the periods under review as prescribed in S29 (2) above. All that was provided to the team was procurement activities completed in 2015 - 2017, while 2018 was incomplete. Implication(s) The absence of a Procurement Plan will prevent the Council from prioritizing its procurement needs and achieving value for money. Recommendation(s) The Procurement Officer should prepare a standardize procurement plan as prescribed by the Act. Management Response No response 4.7.4 Area of Focus: Records Management (Filing System) Section 32(1) of NPPA 2016 states “that the procuring entity shall preserve all documentation relating to the procurement processes, in accordance with applicable rules concerning archiving of government documentation, but at a minimum for a period of six years following the date of final completion of the procurement contract, or from the date of rejection of all bids or cancellation of the proceeding, as the case may be”. Finding(s) The team observed in relation to the above section that proper filing system of procurement docu- ments was not maintained. Implication(s) In the absence of a proper filing system audit trail would be rendered very difficult 52

65. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 4. 10 DEVELOPMENT AND PLANNING DEPARTMENT(DPU) The Development and Planning Department (DPD) was subdivided into four Units (Monitoring and Evaluation (M&E), Economist, Gender and Development, and Planning Units). Each Unit Head was required to channel all activities, and reports to the Head of DPD. Findings(s) The following findings were identified:  The Development and Planning Department had no fore knowledge of the activities and reports carried by the M&E Unit.  Both the Economist and Gender Units were vacant.  The DPD was understaffed with only three members carrying out the functions of the entire Department. The M&E Unit according to the FCC organogram was meant to be under the supervision of the DPD. However, the M&E Unit operated separately without any directive from DPD.  The DPD that was responsible for preparing the Technical Progress Report (TPR), no longer prepared such reports as it was now in the hands of the Finance Department; and  The DPD currently uses the three years (2016 - 2018) Development Plan as its working tool, which had reached its limit in 2018. Recommendation(s)  Management should ensure that the DPD is fully utilized by making sure all Units are active and functional;  The M&E Unit should channel all activity plans and report to the head of DPD for approval;  The TPR which is both quantitative and qualitative should be jointly prepared by the Finance Department and the DPD; and  Management should review the existing Development Plan. Management Response(s)  The DPD is a department which is currently made up of the Development Planning Unit and the M&E Unit. These two Units which made up the department, based on their current roles and responsibilities were not understaffed. It however, needed technical support in terms of training on the job and capacity support related to the use of office equipment to enhance the efficiency and effectiveness of the staff in the department.  The preparation of the TPR is one of the mandates of the DPD based on the human resource guidelines of the Council. However, the DPD has never been given the opportunity to carry out this function.  The TPR was a report that gave information on the progress made on the implementation of the development plan. The development plan looked at annual work plans of devolve sectors; 63

64. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  Since the due processes were not followed in the dismissal of Osman Bangura and other players, the termination could be considered illegal;  Relating footballers to employment contract (ful time) creates a binding relation Recommendation(s)  The Management of FCFC should develop written policies, regulations, code of conduct with re- spect to its players  FCFC should ensure that old/new players including officials are contracted for at least a minimum of three years  The review team strongly recommends that the Terms and Conditions of Service for employees of the FCC be applied to all workers of the institution, including the payment for terminal benefits to workers (inclusive of footballers with employment letters);  The Management of FCFC should ensure that the Technical Director/Head Coach should have a minimum of CAF “B” or “C” license together with backroom staff of medics and Physiotherapist with relevant qualification/training;  Monies misappropriated by Coach John Ajina Sesay and SuliamanS esay be investigated and funds paid to the Finance Department and credited into the club’s bank account (copy ACC). Failure on the part of the FCC would result in the ACC investigating the FCFC  The Management of FCC takes up its fiduciary duty to monitor and supervise the Football Management;  A Football Board should be constituted, consisting of five; three of which should be from the public. For instance a member from the Sierra Leone Football Association, Sport Journalist, Internal Auditor, Chief Administrator, and the Ministry of youths and Sports;  The Human Resources Department should be copied on all matters relating to recruitment of players;  The Management of FCC should only adhere to written instructions on pre - financing, and returns were to be made with relevant receipts to the Finance Department;  Players who were no longer needed by the club should be released or sold and proceeds credited into the club’s account;  The bank account of FCFC should be reactivated with immediate effect and audited for accountability and transparency. There should be a written explanation for the closure (dormancy) of the bank account with supporting documents;  A bank reconciliation statement should be provided to the ACC supported with a bank statement. Management Response(s) No response 62

47. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Figure 5: Outstanding Local Tax Booklets in store 2015 2016 2017 2018 Receipt 300 200 200 800 Issued (250) (200) (200) (550) Balance 50 - - 250 45 Vii. Local Tax The Table shows the number of booklets received from the Sierra Leone Printing Press. These were the booklets issued out to the Local Tax Unit for the periods (2015 - 2018). In 2015, 50 books were unsold indicating a loss to the Council as it cannot be rolled over to the following year. Ther e was a 100% sale in 2016, and 2017 respectively. As at November 2018, however, 550 books were sold with a balance of 250 and upon physical verification on the remaining stocks, we discovered that the Storekeeper was unable to account for 50 booklets . vi. Municipal Market Law 2016 2017 2018 Receipt 21,000 20,000 20,000 Issued (25,170) (22,430) (37,500) Balance (4,170) (2,430) (17,500)

39. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Recommendation(s) The Human Resource Department should ensure that all staff are issued with a job description. Also, all offer letters for newly recruited staff should be attached to a job description. Management Response(s) No response 4.3.7 Area of Focus: Recruitment and Selection Recruitment process is a process of identifying the jobs vacancy, analyzing the job requirements, reviewing applications, screening, short listing and selecting the right candidate. Finding(s)  There were two different sets of employees at the FCC - the core staff and support staff. The team discovered that these two sets of staff were recruited differently. The former set was recruited by the Ministry of Local Government - fourteen (14) in number while the latter set was recruited by the Management of FCC which formed the bulk of staff membership.  The total staff strength of FCC (excluding the technical staff under the office of Her Worship the Mayor) was 484 as shown below Staff composition Number of personnel under the purview of HR Personnel under the pur- view of Environment Di- vision Personnel Under the Purview of the Mayor Core 14 14 Metropolitan Police 112 112 Support Staff 359 359 Casual Workers 51 51 Office of the Mayor (Special Delivery Unit) 14 14 Total 484 51 14 549  It was also discovered that the HR Department does not recruit casual workers. Casual workers were recruited by the Environment Division. This implied that they were under the purview of the Environment Division.  Furthermore, the Office of the Mayor had fourteen (14) Technical Staff that were recruited by various donor organizations and sent to FCC to support the Mayor in her work. There was lack of information sharing from the Mayor’s office to Management with regards the Technical Staff (Delivery Unit). The table shows the list of organizations that recruited and financed the Delivery Unit staff: 37

15. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 13 were collected and analyzed in order to identify weaknesses in practices and procedure. A field visit was also made to project sites to physically observing service delivery. Additionally, the team researched other studies done in similar institutions to inform the conclusions. The inputs of end - users were also invariably considered, and are critical to the outcome of this review. The review period was between 2015 - 2018; a four - year period. 4. 0 FINDINGS AND RECOMMENDATIONS 4.1 INTERNAL AUDIT Section 84(1) of the Local Government Act of 2004 emphasizes that “Every Local Council shall establish an Internal Audit Department”. On the main function of the Head of Internal Audit, Section 84 ( 2) states that “The Head of the Internal Audit Department shall, at intervals of three months, prepare a report on the internal audit work carried out by the Department during the three months immediately preceding the preparation of the report, and submit it to the Local Council. The law, as provided by Section 84(4) of the said Act, directs that “A copy of the report shall be sent to the Minister”. The review team focused on the following areas of internal auditing during the course of the review: 4.1.1 Area of Focus: Audit Manual Finding(s) The Audit Unit works with the Government of Sierra Leone (GoSL) Draft Internal Audit Manual 2014 for Local Councils in the management of its revenue and finances. However, this document is yet to be approved by Parliament. Implication(s) Using a Draft Audit Manual does not guarantee its legality and / authenticity. It does not also guarantee that it is a policy document, or a working tool . Recommendation(s) The Sierra Leone Government Draft Audit Manual 2014 needs to be revised and immediately presented to Parliament for approval. Note: In the following areas of focus, as they border and deal with revenue and funds of the FCC, our intervention was accordingly shaped by testing for compliance with the Draft Internal Audit Manual, 2004. The said manual is the official guide that regulates the auditors and the audit processes within the FCC. Though we made it clear that it was not appropriate to deal with

36. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Recommendation(s) The institution should keep accurate record of employee attendance to help to identify those that were absent from work without providing valid reasons for appropriate disciplinary action. Management Response(s) No response 4.3.3 Area of Focus: Staff Annual Leave Regulation 5.7 of the Revised Human Resource Management Guidelines for Local Government 2004 states that “no member of staff shall be allowed to proceed on annual leave within the staff member’s first year of service.” Also, regulation 5.14 stipulated that “when exigencies of the Local Councils prevent a staff member from taking his/her full annual leave, annual leave may be accumulated and used in the following year. Maximum leave taken in a year shall not exceed 60 days.” Furthermore, Regulation 5.15 says that earned but not utilized leave over and above the maximum limit set out in 5.14 above shall be forfeited. In addition, 5.16 states that no compensation is due for forfeited annual leave, except that compensation for earned but not utilized annual leave may in exceptional circumstances be paid for at the discretion of the Chief Administrator with concurrence of the Chairperson, or Mayor. Finding(s) The team identified huge outstanding leave days for good number of staff members. Furthermore, at the time of the review, the FCC had no leave rooster showing schedules of intended leave dates as to when staff should go on leave. Implication(s)  Staff not allowed to take leave will adversely affect their level of performance.  More so, it was also a violation of the regulations on leave allocation which stipulates that “ leave shall be taken immediately on completion of 12 months service of engagement. Only in exceptional circumstances may such leave be accumulated for not more than two years - - ”  The absence of a leave roster may cause staff to take leave days randomly and not in a cohesive manner. Recommendation(s) A standard policy on leave plan and schedule, allocation, and utilization should be instituted with a view to giving each staff the opportunity to proceed on annual and other leave schedules, including accumulated leave days 34

70. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Recommendation(s) The Education Department should be provided with a vehicle to enhance a speedy and effective distribution of teaching and learning materials. Management Response The head of the Education Department has requested for motorbikes and vehicle to aid effective monitoring and supervision of schools. Nothing has been done by Management. 4.1 2 .4 Area of Focus: Government Allocation Finding(s)  Taking into consideration the huge task of the Education Department, it was however observed that government allocations were delayed, and were inadequate as the Department’s activities were time bound and any delay would hinder the smooth running of the schools in question.  Also, the review team noted that the Council did not support the Education Department from Own Source Revenue. Implication(s) Delay in allocations would hinder the smooth running of the Education Department. Recommendation(s) Management should augment the Education Department from Own Source Revenue in order to enable the smooth running of the Department as government allocations were delayed. Management Response An appeal could be made through Local Government Finance to fast tract / speedup the process. 4.1 3 CONSTRUCTION OF EASTERN MUNICIPAL SCHOOL Eastern Municipal School is located at Kennedy Street in the Eastern part of Freetown. The Education Department of FCC, through the Management of the Council, had a core responsibility of ensuring that Municipal Schools were in good condition. The school building needed rehabilitation and/or construction, so Council lobbied for funds to achieve the task. In March 2016, the former Mayor, His Worship B. Johnson, received funds from the Korean Ambassador, H.E. Noh Kyu - Duk in Nigeria,to carry out a facelift of the school. According to the 68

20. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 18 Implication(s) In the absence of the physical verification of deliverables, loopholes for corruption and substandard work will not be identified. Recommendation(s) The Internal Audit Unit must physically verify all deliverables from initiation to completion. The Audit Unit should produce a quarterly report on deliverables for sound economic, efficient, and effective management of public funds. Management should provide the Audit Unit with a vehicle when conducting out of station audit. Management Response(s) Going forward audit will partake in the verification of deliverable for both Council and Devolve Sectors. 4.2 FINANCIAL MANAGEMENT 4.2.1 Area of Focus: Owned Source Revenue Generation The FCC is a revenue generation institution, and the main source of generating its revenue is from Owned Sources. Owned Sources revenues are generated by the Council from various revenue streams. Some of these revenue generating streams include: i. Municipal Trade / Market Toll This Unit has the sole responsibility to collect market dues from traders in the 31 municipality markets. The review team discovered the following:  The Head, Municipal Trade was one and the same as the Head Cashier. There was duplication of functions as he supervised the revenues generated by the Cash Office, and monies paid in by Market Keepers;  There was poor monitoring and supervision of Market Keepers. The Unit occasionally conducted monitoring inspections on the specific markets, but no report of such was shown to the team.  Market Keepers were difficult to identify as they did not have Identifications cards nor did they wear uniforms, for ease of identification. Monies collected from market dues were paid to the cashier rather than to the bank.  Receipt Books were supplied on a weekly basis but were not reconciled accordingly. Instead of balancing - off weekly, new stocks were supplied to add up to the existing stocks.  The following were the figures presented by the Unit as revenue generated for the respective years

41. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 4.3.9 Area of Focus: Staff Grading/Rank Job Grading is a process of determining the worth or value of one job in relation to, or compared to another, regardless of the characteristics or experience of the specific individual occupying the position at any given time. In addition, it enhances other policies such as efficient salary administration, defined, and structured career - path development, and more aligned performance management, and staff training initiatives. Transparent job grading improves employee relations in that it provides a sound foundation for negotiation and workplace discourse which is substantiated by fair and objective criteria. Finding(s)  The review team realized that the grades/levels / ranks of the two sets of employees as stat- ed above at FCC were different. The core staff at Council were graded between G8 (being an entry point for graduate) to G12 (being top level) while the support staff were graded as junior (Clerical Staff), Intermediate (entry point for graduate), and senior staff. As a result of this, there was a vast disparity in salary between a grade 8 staff (Core staff) and an Interme- diate staff (Support staff) who were both graduates.  We also realized that these two sets of staff were paid from different sources with different salary scales. Implication(s) The disparity in Job grading makes the employees fe el that their contributions were not being accurately measured or valued and as such would affect the output of the employee. Recommendations The Management of FCC should synchronize the grading and incentive of its support staff to that of the core staff. Management Response(s) No response 4.3.10 Area of Focus: Terminal Benefits (ex - gratia) Rules 13.33 of the Revised Human Resource Management Guidelines for Local Government state that “All Local Councils are required to pay ex - gratia to staff of the Council on his/her retirement .”  39

9. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t TIED GRANT FROM GoSL The allocations of these funds were not timely and as such af- fected the implementation of activities.  Government should ensure there is timely allocation of grants for speedy implementation of quarterly activities. REVENUE GENERATION CAPACITY The Council’s revenue generation drive is weak. The analysis above shows that FCC experienced a negative variance on most of its target on Owned Source Revenue streams for the periods under review. The Institution experienced a positive variance on one-off revenue streams (bill boards, registration of CBO, etc).  Management should ensure that budgeted figures are realistic, reasonable, and achievable. Furthermore, more efforts have to be done to improve the revenue mobilization so as to meet and /or exceed its set targets. Month 2018 Customer Receipt number Amount ( Le) February Priority Solution - 1,584,000 April Zenith Bank - 2,112,000 May Access Bank - 70,400,000 June Colisee Boutique 2273 352,000 Lamar Travel Agency 2461 422,000 September Tee-Ess Ent 7893 528,000 F. Soufar 7609 2,112,000 October Afro International - 4,224,000 December 2018 Colisee boutique 8954 352,000 The table below shows transactions without supporting documents (written on blank sheet of paper) . 7 REVENUE GENERATION: STREET PARKING  The team realized that no payment voucher was seen for some payments made in 2018. What we found out were customers’ names, amounts presumably paid and receipt numbers that were written on a blank sheet (this does not form an evidence of re- ceipt. Others did have complete accountable documents).  The law provides that if a vehicle is not parked in a designated parking area, such vehicle should be clamped for obstruction. Furthermore, clamping of such vehicles would attract a penalty fee which is to be paid into an account. The team discovered that no revenue was generated from the clamping of vehicles during the period under review but there were evidences to show that the offences were committed.  A total of Two Hundred and Forty nine million Five Hundred and Seventy Thousand Leones (Le 249,570,000) was debt owed to the FCC due to failure to pay fees for parking spaces;  No policy or contract document was shown to the review team that would signify binding agreement between the FCC and the said institutions.  A robust debt collection team should be initiated to recover amounts owed by Institutions for street parking;  Management should initiate a fee for the clamping of vehicles as it was a revenue gap and such monies to be paid into an account.  The Finance Department should take full responsibility over the Street Parking Unit with respect to payment of fines.  An MOU should be signed between FCC and SLRSA with respect to the clamping of vehicles.  The Management of FCC should create off street parking sites for the general public in the municipality which should be fully managed by stewards.  Management should ensure that a contract agreement is signed between FCC and institutions requiring parking spaces for their vehicles.  Receipts should be issued for all payments for audit purposes.

40. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Mayor’s Delivery Unit Recruiting organization No. of Team Members (Staff) Toni Blair Institute 4 Irish AID 1 Cord Aid 1 ICASL 1 HP3M 2 Volunteers 3 Interns 2 Total 14 Year Number of Personnel 2016 25 2017 12 2018 25 38 The table below shows the number of staff recruited who never went through the proper recruit- ment process (e.g. advertising, short listing etc). It was also found out that some members of staff received their confirmation letters two years after their appointment. For instance, staff members who were appointed on the 1 st June 2014 (Ref 1036/B/319) received their confirmation letters (Ref:23289/b/319) after two years of appointment (18 th July 2016). In essence, confirmation letters should have been issued six months after probationary period. Implication(s) Withholding information from the HR Unit and Management staff will affect the ability to make decisions and take action with integrity. Recommendation(s)  Staff files of the Delivery Team Unit should be forwarded to the HR Department as they form a large part of FCC staff regardless of the fact that they were recruited by external agencies, but yet were employees of FCC.  Management should follow the proper recruitment processes. Also, confirmation letters should be given to staff after completing the probationary period. Management Response(s) No response

10. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 8 FUEL AND FLEET MANAGEMENT Fleet Management : The review exercise revealed the following:  Lack of Credible Fleet Data and Database Management (both electronic and hard copies). There was no comprehensive list of all fleet owned by the Council.  Accountable tools such as logbooks, Vehicle Movement Register, Vehicles Request Form etc, were not maintained. Most of the audio vehicle meters were out of order.  Accountability tools such as Maintenance Forms; Reporting Template and routine maintenance schedule for each automobile were not available at the time of the review.  The Transport Officer did not have any formal training in Fleet Management.  Accountable tools such as Logbooks, Vehicle Movement Register/ Tracking System, Vehicle Request Form, Fuel Request Form, Fuel Distribution Ledger, Fuel Chit, Maintenance Request Form, Maintenance Reporting Template etc. should be developed by the Transport Unit and be operational at all levels of the Council;  The Transport Unit should ensure that files are maintained for vehicles;  A credible data base of all automobiles under the purview of Council should be developed, and regularly updated; The table above explicitly tells us that since 2016 to 2018, revenue generated from Owned Sources ha ve never met It budgeted target Owned Source Revenue 2016 2017 2018 Local Tax (92%) (94%) (87%) Property Tax (68%) (61%) (69%) Market Dues (42%) (40%) (12%) Business Licenses (36%) (35%) (19%) Lease/Rent Property (91%) (35%) (89%) The table below gives the percentage increase (favourable) or percentage decrease (adverse) between budgeted and actual revenue generated on Owned Source Revenue FINANCIAL RECORDS The team discovered that 60% of the documents for various transactions examined were without receipts and other relevant documents to com- plete the transactions with suppliers.  Proper records management system should be put in place across the Council. All transactions should have supporting documents, including receipts, to finalize transactions for audit purpose. PAYMENT OF TAX AND NASSIT Council did not deduct the 5% withholding tax from most suppliers. Also, NASSIT contributions were deducted from staff’ earnings, but were not paid to NASSIT. PAYE Tax Deductions were computed from staff sala- ries, but were not paid to the NRA for over two years.  Tax obligations should be honored by the institution as stipulated by law.  Also NASSIT contributions should be paid in order to protect the future interest of employees. NASSIT and NRA will be informed about this anomaly in order for action to be taken. FIXED ASSET REGISTER No proper mechanism to track fixed assets of the Council. The review team observed that FCC did not maintain a fixed Assets Register.  A Fixed Asset Register must be maintained so that assets are tracked, recorded for proper reporting and audit purposes. The assets can also be coded for ease of identification. MINIMUM WAGE It was discovered that FCC never complied with the minimum wage payment to its workers as was provided by law and this affected about 71 casual workers in the institution since January 2015.These officers received Le350, 000 per month.  With immediate effect the Council should commence the minimum wage payment to its workers and backlog payments are to be made to the affected staff.

28. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Upon verification of the above payment vouchers (receipts and bank slips), the team realized that no payment voucher was seen for some payments made in 2018. What we found out were customers’ names, amounts presumably paid and receipt numbers that were written on a blank sheet (this does not form an evidence of receipt. Others did have complete accountable documents). The table below shows transactions without supporting documents (written on blank sheet of paper). Recommendation  Management of Council should ensure vehicle, motor bike and metropolitan Police are assigned to the unit for pulling down of illegal billboards.  Management should equip the unit with the necessary equipment to effect their work. The statutory document should be reviewed as the penalty for non - compliance is not commensurate to the act committed. 4.2.2 AREA OF FOCUS: STREET PARKING Street parking has now become a major composite to the revenue generating streams of FCC as it uses on - Street parking method by demarcating spaces either parallel, 30, 45, 60, or 90 degrees angle of parking. Meanwhile, off - Street parking was fully controlled by the street boys. The Street Parking Unit has allocated 297 parking spaces to 130 institutions in the municipality. A fee of Le1,000 (One Thousand Leones) is charged per hour for 8hrs working days (Monday - Friday). This implies an institution pays Le176,000 (One Hundred and Seventy Six Thousand Le- ones) per month for a space demarcated for parking. A total of L249,570,000 (two hundred and forty - nine million five hundred and seventy thousand Leones) is owed by Institutions to FCC as a result of parking spaces provided. The revenue generated for the period under review (2015 - 2018) was One Billion One Hundred and twenty one million, three hundred and thirty four Leones (Le1,121,334,000). The table below shows the revenue generated yearly. Year Amount Le 2015 17,754,000 2016 106,368,000 2017 386,836,000 2018 610,376,000 Total 1,121,334,000 26

45. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  Unavailability of fuel reconciliation reports with fuel suppliers on fuel allocation;  Fuel was provided to staff on a weekly basis but the team realized that there were staff who were entitled to this facility but did not benefit.  Also, staffs who were without vehicles exchanged their fuel for money lesser than the corresponding value of the fuel chit. Government therefore losses huge sums in this direction;  Furthermore, staff failed to use their vehicles for official purposes during the time of need; and  There was no policy on fuel allocation. Recommendation(s)  Fuel supply for extra runs should be backed up with appropriate fuel approval forms and fuel estimate per distance to be cover (especially for provincial travels); and  Only staff with their name printed on their vehicles’ Life Card should be provided with fuel. Management Response(s)  The quantum of fuel for vehicle and motorbike was determined by Management.  Reconciliation report as with fuel suppliers of fuel allocation were yet to be provided, but reconciliation with the supply fuel ledger and that of the office fuel ledger was done on a monthly basis.  Staff who received fuel chits had vehicles that they come to work with.  Staff do use their vehicles on official duties when the need arises.  Fuel policy is now available. 4.5 STORES MANAGEMENT Store Management is concerned with ensuring that all the activities involved in storekeeping and stock control are carried out efficiently and economically by the store personnel. 4.5.1 Area of Focus: Store Environment The Store was not tidy and/ or spacious as most of the items were obsolete. We found it very uncomfortable to work in the store as it was unsightly and the atmosphere was also unhealthy for the Storekeeper to execute his duties. Due to these factors, the Storekeeper spent most of his time outside his Office. 43

21. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Year Revenue Generated (Le) 2015 744,11,2,000 2016 1,138,675,000 2017 1,112,406,000 2018 (Oct.) 1,881,915,000 The table above shows the revenue generated from Market Tolls for the periods shown above. The figures indicate that that there was a boom in 2018 (Jan - Oct), which far exceeded (Seven Hundred Million Leones – Le 700m) 2016 and 2017 which were full calendar years while 2015 had the least collections. Recommendation(s)  Market Keepers should be provided with a form of identifications (Uniforms and ID). The Unit should be aided with logistics to conduct a robust monitoring, supervision, and inspection of Market Keepers, and market places;  The Head of the Unit should ensure that reconciliation was done on the supply of the receipt books with the various market heads before replenishment in order to avoid double counting;  To avoid conflict of interest, Management should ensure that the Head of Market discontinued performing the functions of Head of Cashier. A best practice would be to delegate and / or recruit a competent staff. Management Response(s)  There was no point in time when the two functions were executed by me. Increased to be the Head of Cash Office since a letter of transfer was given to me. However I am now the new head of the Municipal Trade Department. The Deputy has been acting in that capacity.  There is now effective monitoring of all Keepers as supervisors are now all over the various markets.  Uniforms and ID cards have now been provided to all Market Keepers. All payments are now done through the bank the following morning.  There is now proper reconciliation of receipt books supplied to Market keepers from stores on a regular basis. ii Valuation Department The Department has the responsibility to:  Discover properties; 19

19. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Recommendation(s) Management should empower the Audit Unit to conduct extensive audit on all projects of devolved Sectors, from initiation to completion, in order to ensure value for money. Management Response(s) Devolve Sectors were audited but it was limited to resources transferred to these Sectors (2018).Going forward an in - depth review will be done on revenue/expenditure of Own Source Revenue, grants allocation as well as donor funding. 4.1.7 Area of Focus: staffing Finding(s) The Audit Unit was understaffed with only five (5) members given the volume of work the FCC does, and the transactions involved in same. Equally, given the scope of activities, and the sensitivity of the tasks, the Internal Audit Unit should be well equipped to facilitate its activiti es. Implication(s) Understaffing in the Audit Unit would lead to inefficiency, and ineffectiveness, in the discharge of their duties. Recommendation(s) The Human Resource Department must ensure adequate staff are in the Audit Unit and Management should also ensure that the Internal Audit Unit is well equipped in terms of personnel. Management Response(s) Total staff strength of the Unit was 6  Head of Internal Audit  Deputy Internal Auditor  Assistant Auditor I  Audit Clerk 2  Audit Clerk/Secretary 1 4.1.8 Area of Focus: Physical Verification of Deliverables (Compliance Audit) Finding(s) The Internal Audit Unit does not physically verify deliverables, such as contracts agreements, project sites, fuel allocation and distribution and so on. These deliverables need to be audited from initiation to completion to ensure value for money. 17

42. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Finding(s) Terminal benefits are final entitlements of an employee upon retirement. However, it was observed that since 2015, staffs that were retired were yet to receive their ex - gratia from the Council. Implication(s) Delay in paying retirees’ benefits would affect their livelihood. Recommendation(s) Management should ensure that all backlog payment to retired staffs are paid. Management Response(s) No response 4.3.11 Area of Focus: Training and Development Training and development is a vital part of the human resource development. Most organizations look at training and development as an integral part of the human resource development activity. Training may be described as an endeavor aimed at improving or developing additional competency, or skills in an employee, to increase the performance, or productivity. Finding(s) The review team did not see any evidence of policy on career development plan for staff. There were no annual training plans, nor any Needs Assessment. Few staff however had the opportunity to benefit from a one off training in 2010. Implication(s) The absence of training in an organization certainly affects the productivity of staff. Staff members need training to improve their capacities with respect to the work they perform. Recommendation(s) FCC should develop a Career Development Plan (CDP) in order to improve on staff capacity and retention. Management Response(s) No response 4.3.12 Area of Focus: Staff Welfare Association This is an organization of employees that is concerned primarily with welfare and recreational activities of staff. It also advocates legislative and administrative actions on matters of compensation, and working conditions, on behalf of staff. 40

32. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 30 Finding(s) The analysis above shows that FCC experienced a negative variance on most of its target on Owned Source Revenue streams for the periods under review. The institution experienced a posi- tive variance on one - off revenue streams (bill boards, registration of CBO, etc). The table below gives the percentage increase (favourable) or percentage decrease (adverse) between budgeted and actual revenue generated on Owned Source Revenue Owned Source Revenue 2016 2017 2018 Local Tax (92%) (94%) (87%) Property Tax (68%) (61%) (69%) Market Dues (42%) (40%) (12%) Business Licenses (36%) (35%) (19%) Lease/Rent Property (91%) (35%) (89%) The table above explicitly tells us that since 2016 to 2018, revenue generated from Owned Sources have never met it budgeted target. Implication(s) Setting unrealistic targets will lead to huge adverse variances. Impliedly, this was loss to Council for not meeting its target. Recommendation(s) Management should ensure that budgeted figures are realistic, reasonable, and achievable. Furthermore, more efforts have to be done to improve the revenue mobilization so as to meet and /or exceed its set targets. Management Response(s) No response 4.2.5 Area of Focus: Receipt /Supporting Documents Findings The team discovered that 60% of the documents verified, and examined were without receipts and other relevant documents to complete the transactions with suppliers. Implication(s) Incomplete documentation will affect an audit process.

27. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Recommendation  There should be proper public education with regards the payment methods and the rest.  There is need to enact a By Law so that a penalty fee will be charged on defaulters.  Management should ensure officers are trained to keep them abreast abreast with modern day taxation trend. Management of FCC should foster a relationship with the national Revenue Authority (NRA), whereby an agreement would be signed whereby citizens would be asked to produce evidence of business or trade license to NRA before income tax and VAT or any other tax are computed by NRA. vi. Bill Board This unit also forms part of the revenue generating units of FCC. Section 3(j) of the Freetown City Council Statutory Instrument No. 4 of 2010 statutory nuisance Byelaws, states that “any display of banners or erection of billboards or other advertising hoardings without first obtaining appropriate permits from council ”. Section 2 states that any banner, billboard or advertising hoarding erected in contravention of par- agraph (j) of sub clause (2), shall be pulled do or confiscated by Council and cost for such action and a fine of Le 100,000 per billboard and Le 25,000 per banner levied on defaulter.  Lot of bill boards had been brought down due to the construction of roads and the unit is challenged to erect billboards.  No vehicle and/or motor bike is assigned to the unit to conduct monitoring and inspections of illegal erections.  Council does not have the machinery and / or equipment to pull down billboards that were illegally erected. The unit takes the risk to manually enforce the law without being accompanied by security personnel. The revenue generated by the unit is as follows: Year Amount (Le) 2015 77,012,000 2016 195,366,000 2017 319,711,000 Total 592,089,000 The table above shows that the unit generated Le592,089,000 (Five Hundred and Ninety - two Million, and Eighty - Nine thousand Leones). 25

8. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t The table shows amounts (Arrears + City Rates) due for payment to FCC by various sectors . CASH OFFICE RECOMMENDATION  The Head of Market and the Chief Cashier was the same person.  We realized that revenue collected by the market due collectors were deposited at the Cash Office contrary to the prescribed method of payment to the Banks and despite the risk of theft and misappropriation.  The Cash Office has in store huge amounts (millions) of coins and such monies were still showing in the books of the Council as cash in hand.  Coins at the Cash Office should be liquidated at the Central Bank.  The positions of the Chief Cashier and Head of Market should not be held b y the same person.  Finance Department should ensure all payments are directly paid into the banks. Also, payments received after working hours must be credited in the banks not later that 12:00PM the following day. Year Government (Le) General Public (Le) Accumulative Yearly Totals (Le) 2015 3,310,215,913 2,498,976,691 5,809,192,604 2016 2,021,077,913 8,727,085,461 10,748,163,374 2017 4,319,111,556 5,236,410,783 9,555,522,339 2018 6,540,011,556 5,236,410,783 11,776,422,339 6 REVENUE GENERATION: PROPERTY VALUATION DEPARTMENT RECOMMENDATION  The valuations of properties for tax purposes were discretionary with no established standards.  A number of properties in new settlements and difficult terrains have not been valued.  Public cooperating is limited due to ineffective public sensitization.  The Unit was understaffed with eighteen (18) officers to cover the 48 wards in the municipality and is faced logistical challenges to cover the whole municipality.  No information was provided to the Review Team on Revenue Generation since they have no knowledge of payments made by customers; and  Huge arrears were owed to the FCC/ accumulated by the public and government. The following table gives an over- view of amounts owed to FCC.  Management should constitute a Debt Recovery Unit and /or team to collect such debt. The FCC should take legal action as a means of recovering these monies, where necessary.  Management should constitute a Debt Recovery Unit and /or team to collect such debt. The FCC should take legal action as a means of recovering these monies, where necessary.  Fixed formula or standard should be developed for the valuation of properties.  The Unit should embark on a massive public education and sensitization cam- paign at national level to help the public understand, and contribute to the work of the Unit;  Management should capacitate the unit by recruiting more staff and provide adequate logistics to enable the Unit cover the whole municipality.

35. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 4.3 HUMAN RESOURCES MANAGEMENT 4.3.1 Area of Focus: Strategic Plan A Strategic Plan is a document that articulates both the decisions made about the organization's goals and the ways in which the organization will achieve those goals . Most organizations generally prepare three to five years ahead when engaged in strategic planning. Finding(s) At the time of our intervention, no strategic plan was presented to the review team by FCC. They were however working with a two (2) years 2016 - 2018 development plan for Freetown. Implication(s) Institutions that are not guided by a Strategic plan will not provide a clear direction in their operations. Recommendations The Management of FCC should developed a strategic plan to lay the roadmap for the Council for the next three or five years. Management Response(s) No response 4.3.2 Area of Focus: Attendance Register Employees are expected to be punctual, and dependable in order to meet the needs of their Departments and/employer. When employees are absent or tardy, work and service are interrupted and an additional burden is placed on other colleagues. Attendance and reliability are important factors in evaluating individual performance and continued employment. Employees who are unable to meet their employment obligations of regular and reasonable attendance and punctuality are subject to disciplinary action, up to and including termination of employment. Finding(s) Staff attendance was not properly maintained as most staff did not sign the attendance register. Implication(s) Without maintaining a proper staff attendance register, you cannot keep track of employee attendance accurately.  33

33. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Recommendation(s) All transactions should have supporting documents, including receipts, to finalize transactions for audit purpose. Management Response(s) No response 4.2.6 Area of Focus: Withholding Tax, PAYE and NASSIT Section 117 of the Income Tax Act 2018 mandates a 5% Withholding Tax Payments to contractors/ or suppliers to be deducted at source of income. Section 25 (1& 2) of the NASSIT Act of 2001 stipulates that the employer deducts 5 % from the employee's earnings and pays another 10% on behalf of the employee, giving a total contribution of 15%.Section 25(3) says that such payment should be paid within fifteen (15) days after the end of each month to the trust. Findings Council did not deduct the 5% withholding tax from most suppliers. Also, NASSIT contributions were deducted from staff’ earnings, but were not paid to NASSIT. PAYE Tax Deductions were computed from staff salaries, but were not paid to the NRA for over two years. Implication(s) Failure to pay taxes deducted from suppliers to NRA was in contravention of the tax law and had a ripple effect on the state economy. Equally so, reneging on the payments of NASSIT contributions on behalf of employees could have a long time effect on employees’ retirement. Furthermore, without deducting withholding tax on the supply of goods would cause loss of revenue to the Council. Recommendation(s)  Tax obligations should be honored by the institution as stipulated by law.  Also NASSIT contributions should be paid in order to protect the future interest of employees. NASSIT and NRA will be informed about this anomaly in order for action to be taken. Management Response(s) No response 4.2.7 Area of Focus: Fixed Assets Register Fixed Assets Register contains the list of all fixed assets of a company. It keeps track of book 31

13. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 11 1.0 INTRODUCTION Consistent with the responsibilities of the Anti - Corruption Commission (ACC), as set out in section 7(2) (f) of the Anti - Corruption Commission Act, 2008: “To examine practices and procedures of public bodies.....” and (h) “to issue instructions to public bodies of changes in prac - tices and procedures.....” A review of the Freetown City Council (FCC) became necessary given the strategic importance of the service provided to the municipality. Being a beneficiary of public funds, it was mandatory for the FCC to avail itself to oversight bodies in order to ascertain its level of transparency and accountability and compliance to best practices in their systems and processes. As a revenue generating institution, it was imperative for its systems of accounting to be examined with a view to ensuring identification of weaknesses in the system that create opportunities for corruption, and to recommend appropriate measures that would reduce, or where possible, eradicate such opportunities. Against the fore - going, the ACC, reviewed the practices and procedures of the FCC with the objective of identifying weaknesses in the systems with respect to vulnerability to corruption opportunities, and to further build on the strengths identified. The ACC had undertaken similar reviews in other institutions which have led to an improvement in service delivery; their efficiency and effectiveness and an increase in revenue generation/mobilization, and collection. In addition to the above, there had been numerous negative reports as contained in various publications in the print and electronic media about corruption and mal - administration in the administration of the municipality; and other implementing partners which have been gradually affecting their performance. FCC is the municipal government of the City of Freetown , the capital of Sierra Leone . The FCC was established in 1893 and is one of the oldest municipal governments in Africa. It is ironical that Freetown, which is one of the first planned cities in British West Africa, is now becoming a massive urban sprawl. This is due to a history of neglect by various municipal leaders since independence. The city has spread far beyond its original boundaries to areas that were once considered Rural Freetown. FCC seeks funds from developing partners to transform the city initiatives from several angles. Freetonians (citizens and residents of Freetown) have a greater role to play in ensuring compliance with taxes and other dues. Freetown has the potential to be one of the most beautiful cities in Africa, with her natural environment, mountains, forest, rivers, oceans and minerals. One major challenge the city faces however is managing the dumping of plastics – abandoned pure

63. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Name of players New club Amount (Transfer fee) Le 1. Medo Rizegger International Undisclosed fee 2. Batlet Gemstar Football Club 5,000,000 3. Edward Cole Port Authority Football Club 5,000,000 4. James Zino Conteh Diamond Star Football Club 9,500,000 5. Unisa Kalusha Conteh Diamond Star Football Club 6,000,000 6. Mohamed Zack Sesay Diamond Star Football Club 6,000,000 7. Abdul Budo Bangura Eastern Lions Football Club Undisclosed fee 8. Safia Henry (GK) Anti Drugs Strikers Football Club Undisclosed fee 9. Kemson Fofana Diamond Stars Football Club 18,000,000 10 Ibrahim Tarawali Horoya Football Club Guinea Undisclosed fee 11. Desmond Wellington Port Authority Football Club 6,000,000 12 Lahai Kallon Port Authority Football Club 8,000,000  Telephone numbers on the FCFC Letterhead were that of the Club Manager. The club is currently on tender for sale to interested bidders as advertised on 26 th February 2012. The Public Notice was signed by the Club Manager Mr. Francis Palmer - Wright;  On a letter dated 1 st August 2013, the Secretary General of FCFC (Mr. Sulaiman Sesay) allegedly misappropriated (Six Million Leones (Le6,000,000) for the sale of Desmond Wellington to Ports Authority;  FCFC had an operating bank account (001102000049) with the then Bank PHB (now Keystone Bank) at Lightfoot Boston Street, Freetown. This account was opened on 4 th November 2009, with an initial deposit of Three Million, Five Hundred and Twenty Thousand Leones, (Le3,520,000).  As at 30 th June 2010, the available bank balance was (Nine Million Nine Hundred and Eight Thousand Two hundred Leones (Le9,908,200).  The team realized that the bank account of FCFC was dormant and no bank reconciliation was provided as to what led to the dormancy of the account.  In addition, no breakdown was provided by the Finance Officer as to how the balance as at 30 th June 2010 was utilized. Implication(s)  Since footballers of the Council were like other employees, any attempt to terminate their services should meet the terms and conditions of service of the Council; 61 disclosure of proceeds to Management.

43. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Finding(s) The review team discovered that there was no Staff Welfare Association, or internal organization which mediated staff issues, and promoted the interest of same. Implication(s) None existence of employee association, affects the staff membership, as there would be no body to mediate staff concerns to Management. Recommendation(s) Management must ensure, with immediate effect, that employees of Council have an internal mediating body (FCC Staff Welfare Association). Management Response(s) No response 4.4. FLEET AND FUEL MANAGEMENT Vehicles and fuel were complimentary goods that were very vital to accomplishing the tasks embedded in the activities of the Council. They served as wide variety of needs–from occasional basic highway transportation to routine off - road use in executing planned activities. Rule 4.25 of the Civil Service Code for fuel allocation 2011 states that “Government shall provide fuel to facilitate the work of Ministries, Departments, and Agencies (MDAs) of Government..Officers in Senior Management positions who are provided with official vehicles on official duties shall be provided with fuel”. 4.4.1 Fleet Management The review exercise revealed the following:  Lack of Credible Fleet Data and Database Management (both electronic and hard copies). There was no comprehensive list of all fleet owned by the Council.  Accountable tools such as logbooks, Vehicle Movement Register, Vehicles Request Form etc, were not maintained. Most of the audio vehicle meters were out of order.  Accountability tools such as Maintenance Forms; Reporting Template and routine maintenance schedule for each automobile were not available at the time of the review.  The Transport Officer did not have any formal training in Fleet Management.  The Team was told that only Eight (8,) out of a total of eighteen (18), assorted vehicles, including ambulances, (excluding motor bikes) were road worthy. These vehicles were yet to be verified  The Transport Officer did not have any formal training in Fleet Management. 41

60. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t The table shows that there was an increase in revenue in 2017 as compared to 2018 this was due to the fact that the numbers of death cases recorded in 2017 are far higher than that of 2018. Recommendation  Management should ensure cemetery workers are encouraged with incentives so as to motivate them to do more.  Each cemetery should be provided with an office space and grave diggers are to be provided with the essential working tools on time.  Management should provide cemetery workers with protective gears and also some sanitary kits.  Management should promptly address the issue of inadequate staffing in the various cemeteries. Also, volunteers should be taken into consideration since they are actively on the job. The unit should be provided with vehicle for on the sport inspection to the various cemeteries. 4.8.2 Animal Welfare The Freetown City Council Dogs and other Animals Bylaw 2010 statutory instrument No. 3 of 2010 states that: 1. No person shall keep a dog within the city of Freetown unless: (a) Is registered with Council, in a manner prescribed by Council (b) Is confined to a kennel or kept on leash (c) If three month old or over, is vaccinated against rabies and documentary proof of such vaccination is produced. The team discovered that, with regards to the above instrument, no documentary evidence was shown to the team. In essence, nothing has been done to implement the By - law. 2. No person shall keep a vicious or dangerous dog with the City of Freetown unless that person takes the necessary precautions to prevent such dog from attacking. (a) 5(1) council may impound any unregistered dog or other animal found in any public place with the City (b) (2) council shall immediately give notice of the impounding of any unregistered dog or other animal by displaying a notice to that effect in a conspicuous place at the Council’s premises. (c) 5(6) penalty for offenders: fine of up to five hundred thousand Leones or six months im prisonment or both. . 58

66. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t planned project that were to be implemented by Council and other related development programs to be carried out by other donor agencies. The TPR was also an independent report that was put together by the Finance Officer (FO) and the DPD. The FO puts together the financial report whilst the DPD did the narrative of the report and its compilations. The report was eventually submitted to the Ministry of Finance (MoF) and the Ministry of Planning and Economic Development (MoPED).  The Council had already prepared a Development Plan called “Transform Freetown Plan”. The implementation of Transform Freetown spans from 2019 - 2022. 4.1 1 DEVOLVED SECTORS Findings The Third Schedule of the Local Council Act of 2004 categorically states the functions that are de- volved to Local Councils. The following sectors are now devolved to FCC: i. Ministry of Education; ii. Ministry of Health; iii. Ministry of Agriculture; iv. Ministry of Youth and Sports; v. Ministry of Social Welfare, Gender and Children’s Affairs; and vi. Library The team identified the following issues across the Sectors:  Delay in Remitting Returns: Upon allocation of grants to devolved sectors by the Finance Department of FCC, it was expected that the various Finance Officers should forward their returns of previous grant received before requesting for subsequent allocations. The team identified that these Finance Officers usually failed to remit these funds to FCC for proper accountability. They rather submitted PET forms for replenishment. The Council however delays this process until all returns are properly submitted.  Untimely Allocation of Grant: Owing to the untimely allocation of tied grants to devolved sectors, activities scheduled for a specific quarter were carried forward to the next quarter which caused these activities to overlap. This normally causes delay in the implementation of programmes. 64

26. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 24 Management Response(s)  Mr. Desmond Thomas who was head of Cash Office, ceased to be head of the Unit. The Deputy Mr. Momoh Kamara has been promoted to Chief Cashier and Mr. Desmond Thomas has been transferred as Head of Municipal Trade.  Markets dues collectors now pay directly into the bank.  The name Cash Office has now been changed to Financial Record Office, reason, they no longer receive cash.  The issue of coins being at the cash office/records office. The coins in question are worn out coins (on longer used) that have been there for the past four (4) accounting years. A meeting has been scheduled with the Central Bank and it is yet to hold for the onward transfer to BSL . v. Business Licenses 56 . (1) of the Local Government Act 2004 states “A local council shall issue a licence to any person in a locality who– (a) Establishes or maintains premises from which to practice any trade, business or profession; Revenue generated are shown below: From the above table, 2018 had the highest collection due to the fact that the system has been automated while the others were manually computed. Furthermore, this could be possible sign that compliance rate has been increased from the Citizens.  The team realized that officers of the unit are finding it very hard to locate some business premises within the municipality as a result of the house numberings. Also, the changing of business names and addresses had been a challenge.  The officers are constraint with vehicle in conducting visitation and / or mobilization preprocess.  There is poor or no public education on the issue of business license to the public.  No By - Law on Business licenses has ever been enacted Year Amount (Le) 2015 2,846,780,000 2016 2,880,495,000 2017 2,794,690,000 2018 6,688,000,000 Total collection 15,220,965,000

29. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 27 Month 2018 Customer Receipt number Amount Le February Priority Solution - 1,584,000 April Zenith Bank - 2,112,000 May Access Bank - 70,400,000 June Colisee Boutique 2273 352,000 Lamar Travel Agency 2461 422,000 September Tee-Ess Ent 7893 528,000 F. Soufar 7609 2,112,000 October Afro International - 4,224,000 December 2018 Colisee boutique 8954 352,000 Recommendation(s)  A robust debt collection team should be initiated to recover amounts owed by Institutions for street parking;  Management should initiate a fee for the clamping of vehicles as it was a revenue gap and such monies to be paid into an account.  The Finance Department should take full responsibility over the Street Parking Unit with respect to payment of fines.  An MOU should be signed between FCC and SLRSA with respect to the clamping of vehicles.  The Management of FCC should create off street parking sites for the general public in the municipality which would be fully managed by stewards.  Management should ensure that a contract agreement is signed between FCC and institutions requiring parking spaces for their vehicles.  Receipts should be issued for all payments for audit purposes. Management Response (s)  All documents regarding revenue generation on Street Parking has been sent to your office. Documents were also available for further verification in the office.  Policy for street parking is yet to be developed.  Revenue generated for street parking for the period 2015 – 2018 amounted to Le1, 121,334,000. All these monies were paid into the Councils bank accounts. See analysis. Documents are availa- ble for verification.

6. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t LIST OF ABBREVIATION A .C.C....................................................................Anti - Corruption Commission, Sierra Leone F.C.C. ..................................................................Freetown City Council G.V.W.C................................................................Guma Valley Water Company I.I.A......................................................................Institute of Internal Auditor G.o.S.L.................................................................Government of Sierra Leone M.O.U...................................................................Memorandum of Understanding S.L.R.S.A..............................................................Sierra Leone Road Safety Authority C.B.O...................................................................Community Based Organization CV’S....................................................................Curriculum Vitae H.R......................................................................Human Resource H.R.M..................................................................Human Resource Management M.D.A...................................................................Ministries, Departments, and Agencies C.A......................................................................Chief Administrator F.C.F.C..................................................................Freetown City Football Club D.P.U....................................................................Development and Planning Unit M&E.....................................................................Monitoring and Evaluation T.P.R.....................................................................Technical Progress Report T.O.R ..............................................................Terms of Reference NASSIT.................................................................National Social Security and Insurance Trust..................................................................... NRA.....................................................................National Revenue Authority D.P.O....................................................................Development and Planning Officer D.P.D ..............................................................Development and Planning Department F.O.......................................................................Finance officer CDP.....................................................................Career Development Plan NPSE....................................................................National Primary School Examination NPPA....................................................................National Public Procurement Act BECE....................................................................Basic Education Certificate Examination PAFC....................................................................Port Authority Football Club SLFA ............................................................ Sierra Leone Football Association M&E .....................................................................Monitoring and Evaluation MoF .................................................................... Ministry of Finance MoPED................................................................. Ministry of Planning and Economic Development ACA......................................................................Anti - Corruption Act 4

18. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Management Response(s) Tenure of an Audit Committee is 2 years. The Committee was dissolved in December 2017 due to the dissolving of Council. 4.1.5 Area of Focus: Audit Queries An Audit Query is an explanation that was required by the Audit team on certain points that they may have identified during an audit. These may be used to gather information for them to come to a conclusion in the audit. Finding(s) We discovered that Managers do not largely response to audit queries. As a result, most of the audit findings re - appeared in subsequent audit reports. The team also observed that, where audit queries were addressed, most of them were not adequately responded to, and Management had not treated such reports with utmost importance. Implication(s) Failure to treat internal audit queries with seriousness and urgency would weaken the internal controls, and as such, these findings would re - appear in subsequent audits. This will result in wastages and invariably affects service delivery. Recommendation(s) Management, alongside the Audit Committee, should ensure that internal audit queries were treated with the greatest concern, and recommendations proffered are thoroughly implemented. Audit responses should always be in writing. Management Response(s) For the period 2018, 2 audit queries were responded to.  Human Resource Audit  Devolve Sector Audit  All queries raised in these audits were addressed. 4.1.6 Area of Focus: Audit of Devolved Sectors Finding(s) Most of the activities in the Council were devolved, but however, the Audit team was not provided with the necessary funds to carry out audit at the devolved sectors. Implication(s) Failing to carry out audit on devolved sector projects/or contracts undermined the efficiency, economic value, and effectiveness of such projects. 16

23. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Recommendation(s)  Personal information relating to property should only be released on Court Orders;  The Unit should embarked on a massive public education and sensitization campaign at national level to help the public understand, and contribute to the work of the Unit;  Management should look into recruiting more staff to support the existing ones in the field; and  The Unit needs to be provided with logistics to reach the difficult terrain in the exercise of its mandate. Management Response(s) No response iii Rate Section This Section works in collaboration with the Valuation Unit in ensuring that rateable values (City Rates) computed are billed and / or issued to various customers in the municipality. It also has the responsibility to collect debts and forward defaulters to the Bailiff Section for appropriate action . Finding(s)  No information was provided to the review team on revenue generation since they have no knowledge of payments made by customers; and  Huge arrears were owed to the FCC/ accumulated by the public and government. The following table gives an overview of amounts owed to FCC. Year Government (Le) General Public (Le) Accumulative Yearly Totals (Le) 2015 3,310,215,913 2,498,976,691 5,809,192,604 2016 2,021,077,913 8,727,085,461 10,748,163,374 2017 4,319,111,556 5,236,410,783 9,555,522,339 2018 6,540,011,556 5,236,410,783 11,776,422,339 The table above shows amounts (Arrears + City Rates) due for payment to FCC by various sectors. The total city rates due for payment in 2018, inclusive of arrears by the government, was Six Billio n, Five Hundred and Forty Million, and Eleven Thousand Five Hundred, and Fifty - Six Leones (Le6,540,011,556). The accumulated total from the general public was Five Billion Two Hundred and Thirty - Six Million Four Hundred, and Ten Thousand Seven Hundred and Eighty - Three Leones (Le5,236,410,783). Therefore, both the GoSL and the general public owed FCC a cumulative total of Eleven Billion, Seven Hundred and Seventy - six million, Four Hundred and Twenty - two Thousand, Three Hundred and thirty - three Leones (Le11,776,422,339.) 21

57. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Procurement Activity Year Successful Bidder Source of Finance (Funding) Amount (Le) Irregularities 1 Rehabilitation of Engi- neering Department 2016 SMAK COMMERCIAL ENTERPRISES 46 Lightfoot Boston Road, off Wilkinson Road, Freetown 87,697,000 NASSIT Certificate was not submitted but was recorded Re- sponsive in the preliminary ex- amination. Only two members ( except Fi- nance Officer ) of the Technical Evaluation Committee signed the evaluation report. 2 Supply of Uniform Ma- terials, Raincoats and Boots to Lumley Gov- ernment Hospital - 2016 HAJ-MARAM INVESTMENT 14 Lightfoot Boston Street Free- town. DSDP / RCHP 26,000,000 Supplier’s name was not found on the suppliers’ data base sub- mitted to ACC. The Contract Agreement was only signed by the Supplier and not on the part of FCC 3 Cleaning Services to Lumley Government Hospital 2017 Mr. KLIN 40 Adelaide Street, Freetown. GoSL 39,499,000 Only quotation from Mr. KLIN was seen and non from other suppliers. It is a prerequisite of the RFQ method to collect three (3) invoices from three (3) differ- ent Suppliers. 4 Supply of Essential Drugs to Macaulay Street Government Hospital 2007 SAMADETTE Enterprise- 60 Sumalia Town Freetown GoSL 20,000,000 Quotation was only received from SAMADETTE and non from other suppliers (RFQ). 5 Procurement of Fuel to Macaulay Street Government Hospital 2017 A.M.Bah Enterprises Filling Station- Up Gun Turntable Black Hall Road, Freetown. GoSL 51,000,000 The contract agreement was only signed by the supplier and non on the part of FCC. 6 Supply of Laboratory Reagent to Kinghar- manRoad Government Hospital 2017 MEDHAFA Enterprises – 217 BaiBureh Road, Freetown RCHP 21,000,000 Of the three members in the Evaluation Committee, only one (Procurement Officer) signed the evaluation report. 7 Supply of Cleaning Ma- terials, Equipment and Detergents to Kinghar- man Road Government Hospital 2017 Edward Kanu Enterprises – 27 Garrison Street, Freetown 37,500,000 The Procurement Officer was the only member of the Evalua- tion Committee who signed the evaluation report. Implication(s) Non - compliance with the procurement regulations in awarding contracts may render the contract to be marred with corrupt practices. Also, failing to sign evaluation report does not give credibility to the eval- uation process. Recommendation(s)  The Evaluation Committee members should ensure that due diligence is followed in awarding contracts to suppliers. 55 Finding(s) The team examined samples of procurement activities conducted and identified the following irregularities in the procurement process:

22. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  Assess properties; and  Set tariffs on properties (Billing). The Valuation Department of FCC operates within the boundaries of Orugu Bridge and Levuma Beach (48 wards) as mapped out by Statistics Sierra Leone. The types of properties which are discovered and valued by the Valuer are:  New properties under construction; and  Properties not assessed. The following were the anomalies discovered:  The ratable value of a property was determined discretionarily by the Valuer.  It was very hard for Valuers to discover properties in difficult terrains due to the fact that logis tics were not provided.  Public education has been a major problem;  The Unit was understaffed with eighteen (18) officers to cover the 48 wards in the municipality;  Management does instruct the Unit to release Property Data of customers to service providers. Such information was private and confidential and should only be released on request of Court. The Department has done the following assessments on new properties within their jurisdictions in the municipality: Year Domestic Commercial 2016 617 53 2017 494 77 2018 553 62 Total 1,664 192 For the periods under review, a total of 1,856 (One Million, Eight Hundred, and Fifty - Six Thousand) properties were assessed. The Department also does assessment on change of ownership. The table below shows revenue generated by the department on change of ownership. A fee of Five Hundred Thousand Leones (Le500,000) was charged on every change of ownership on property. Year Number of Properties Cost per Property Amount (Le) (Le) 2016 93 500,000 46,500,000 2017 75 500,000 37,500,000 2018 (26 th Nov.) 94 500,000 47,000,000 Total 262 131,000,000 20 From the above table, a total of 262 (Two Hundred and sixty two) properties have changed ownership; amounting to a total generated revenue of Le 131,000,000 (One hundred and Thirty One Million Leo- nes).

72. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t Section 36(2) of the ACA 2008 further states that “A person misappropriates public revenue, public funds or property if he willfully commits an act, whether by himself, with or through other p er- sons, by which a public body is deprived of any revenue, funds or other financial interest or property belonging or due to that public body”. Section 37(1) of the ACA of 2008 moreover States that “Any person who, being a member or an officer or otherwise in the management of any organization whether a public body or otherwise dishonestly appropriates anything whether property or otherwise, which has been donated to such body in the name, or for the benefit of the people of Sierra Leone or a section thereof, commits an offence”. Finding(s) The table below indicates some donor funds that were misappropriated. These were monies credited into the accounts of the under mentioned suppliers but items were not delivered. No. Name of Supplier Address Contact number Contact Per- son Description of Items Total Amount Paid (Le) 1 Rural and Urban Con- struction and General Supply 422 Old Motor Road Allen Town 076 686 230 AbassKelfala- Bangura 70 Trips of Sand ½’’ Granite Aggre- gate 34,300,000 70,800,000 105,100,000 2 EDSHERIE Construc- tion Company Ltd . 80 Campbell Street, Freetown 079119673 Edna Sheriff Building Materials (Assorted) 190,700,000 3 SAMTECH Enterprises Metal Works and Train- ing Centre 35 Pademba Road, Freetown 076639751 Samuel Ibe- messie Assorted Metal Steel 154,992,000 4 HF Building Materials and Hardware 4 Ecowas Street, Freetown 076/077/044 605555 Hussain Fawaz Assorted Electricals 103,263,000 5 HF Building Materials and Hardware 4 Ecowas Street, Freetown 076/077/044 605555 Hussain Fawaz Assorted Building Materials 165,915,000 Totals 719,970,000 Monies were withdrawn from the various bank accounts of these suppliers and no deliveries were made to the site. The team could not verify any delivery note from the suppliers. One of the supplie rs was issued a completion certificate from the engineer of which he singlehandedly signed. None of the suppliers could give proper account of the money .  The business names and addresses of two of the suppliers (HF Building and EDSHERIE) could not be traced. 70

58. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t  Furthermore, the Procurement Officer must ensure all members of the Evaluation Committee sign all Evaluation Reports before awarding Contracts.  Issues will be raised with the investigations department of the ACC for further investigation. Management Response(s) No response 4.8 ENVIRONMENT, HEALTH AND SANITATION DEPARTMENT The department is sub divided into five (5) units:  Cemetery  Environmental Health  Animal Welfare  Disaster Risk management  Faecal Sludge management 4.8.1 Cemetry Each cemetery is to be headed by a cemetery clerk, who issues burial permit to bereaved family for burial. The team found the following:  Freetown City Council is operating on thirteen (13) cemeteries within the municipality. The table below shows the name of the cemeteries, current personnel (inclusive of casual workers excluding volunteers) and required number of personnel for each cemetery within the municipality. Cemetery Permanent staff Casual worker Required number of staff Lumley 2 0 6 Wilberforce 2 2 5 Murray Town 2 0 4 Congo Town 0 0 3 Ascension Town 4 0 8 Kingtom 3 0 7 Circular Road 3 2 7 Kissy Road 3 4 8 Racecourse 3 0 5 Personage Street 1 0 3 Kissy Mess Mess 4 1 8 Wellington 2 1 5 Allen Town 1 0 4 Total 30 10 63 56

30. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 28 4.2.3 Area of Focus: Tied Grant Section49(1) of the Local Government Act 2014 authorizes that“ A tied grant shall be paid to Local Councils towards their administrative costs.” The GoSL paid tied grant to sectors that were devolved to the Council. The table below shows the amount of tied grant paid by GoSL to the devolved sectors . Devolved Sectors 2015 (Le) 2016 (Le) 2017 (Le) 2018 (Le) Total (Le) Health Sector: 6,807,858,139 Primary 339,055,380 771,981,272 425,276,295 368,366,997 1,904,679,944 Secondary 744,612,832 1,452,142,727 1,450,245,104 1,256,177,532 4,903,178,195 Education 369,318,701 646,504,291 173,151,036 299,961,533 1,488,935,561 Library 137,704,127 406,399,549 124,994,267 216,534,141 885,632,084 Agriculture 71,836,218 211,806,921 9,9495,527 172,363,097 555,501,763 Social Services 131,157,754 331,947,618 8,005,021.50 145,528,736 616,639,129.5 Youth 190,710,402 131,758,656 61,509,217 62,752,926.50 1,063,370,331 Sport 190,710,402 26,220,431 61,509,217 62,752,926.50 341,192,976.5 Total 11,759,129,984 Finding(s) Government has disbursed Eleven Billion, Seven Hundred, and Fifty - Nine Million, One Hundred, and Twenty - Nine Thousand Nine Hundred, and Eight Four Leones ( 11,759,129,984) as Tied Grant for the aforementioned periods. The allocations of these funds were not timely and as such affected the implementation of activities. Implication(s) Delay in allocating tied grant would affect programmes and activities Recommendation(s) Government should ensure there is timely allocation of grants for speedy implementation of quarterly activities.

59. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t The table above shows that of the 13 cemeteries in the municipality, a total of 30 permanent staff and 10 casual workers are available. Our findings revealed that a total of 63 grave diggers are to be employed in all cemeteries. The table shows the required number of grave diggers whom are to be present in each cemetery. The table clearly shows that at each cemetery is understaffed considering the nature of work.  Most of the cemeteries are without a cemetery clerk and as a result the grave diggers are not supervised in carrying out their duties.  Grave diggers work throughout the week till close to 7pm day in day out. Neither incentive (working on weekends) nor overtime is paid to them for such herculean job.  The team identified that no office space is provided at the cemeteries for workers and these workers have to seat or wait under trees to execute their jobs.  Furthermore, these workers are not provided with sufficient working tools as most of them are out of order which hinder their speed of work.  C onsidering the nature work, Council has not provided protective gears to grave diggers for a period of time now.  Upon inspection, we noticed that most of the people working in the cemeteries are volunteers. They join hands with the workers to fast track multiple burial processes. This unit generates revenue from various categories of burial. The prices are follows; Le  Still Birth (0 - 5yrs) 10,000  Children (6yrs - 17yrs) 15,000  Adult (18yrs and above) 25,000  New vault 100,000  Old vault 80,000  Enclosure 30,000 Revenue generated is categorized below: Category of Death Burial Fees (Le) Total number of Death (2017) Total Amount paid (2017) (Le) Total number of Death (2018) (Le) Total Amount paid (2018) (Le) Still Birth (0-5yrs) 10,000 267 267,000 161 1,610,000 Children (6yrs -17yrs) 15,000 104 1,560,000 51 765,000 Adult (18yrs and above) 25,000 2038 50,950,000 1,055 26,375,000 New vault 100,000 233 23,300,000 173 17,300,000 Old vault 80,000 170 13,600,000 95 760,000 Enclosure 30,000 No data provided No data provided No data provided No data provided Totals 2812 89,677,000 1535 46,810,000 57

4. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t 4.3.9 Area of Focus: Staff Grading/Rank ........................................ ..............................................................39 4.3.10 Area of Focus: Terminal Benefits (Ex - Garcia) ..................... ..............................................................39 4.3.11 Area of Focus: Training and Development ........................... ...........................................’..................40 4.3.12 Area of Focus: Staff Welfare Association ............................. ..............................................................40 4.4. FLEET AND FUEL MANAGEMENT ......................................... ..............................................................41 4.4.1Fleet Management .................................................................. ..............................................................41 4.4.2 Fuel Management .................................................................. ..............................................................42 4.5 STORES MANAGEMENT ....................................................................... ................................................... ....................43 4.5.1 Area of Focus: Store environment ...................................................... ................................................... ....................43 4.5.2 Area of focus: Verification of security items .......................................... ................................................... ....................44 4.5.3 Area of focus: Monitoring and Supervision ........................................... ................................................... .....................45 4.5.7 Area of focus: Records Management ................................................... ................................................... ....................47 4.5.4 Area of focus: Staffing ............................................................ ..............................................................46 4.5.6 Area of Focus: Leave of Store Keeper ................................... .............................................................46 4.6 Metropolitan Police ................................................... .............. .............................................................48 4.7 PROCUREMENT MANAGEMENT ........................................ .............................................................49 4.7.1 Area of Focus: Procurement Committee ................................ .............................................................49 4.7.2 Area of Focus: Staff Capacity ................................................. ..............................................................50 4.7.3 Area of Focus: Procurement Plan .......................................... .............................................................51 4.7.4 Area of Focus: Records Management (Filing System) ........... .............................................................51 4.7.5 Area of Focus: Debriefing to | Unsuccessful Bidder ............... .............................................................52 4.7.6 Area of Focus: List of Supplier/ Vendors ................................ .............................................................52 4.7.7 Area of Focus: Requisition Book ............................................ .............................................................53 4.7.8 Area of Focus: Qualification/ Disqualification of Bidder ......... .............................................................53 4.8 ENVIRONMENT HEALTH AND SANITATION DEPARTMENT .................................................55 4.8.1 Cemetery ....................................................................................................................55 4.8.2 Animal Welfare .............................................................................................................57 4.9 MANAGEMENT OF FREETOWN CITY FOOTBALL CLUB (FCFC) ............................................ 58 4.10 DEVELOPMENT AND PLANNING DEPARTMENT (DPU) ..... .............................................................62 4.11 DEVOLVED SECTORS ........................................................... .............................................................63 4.12 EDUCATION DEPARTMENT .................................................. .............................................................65 4.12.1 Area of Focus: Staff Strength ............................................... ..............................................................65 4.12.2 Area of Focus: Capacity Building ......................................... ..............................................................66 4.12.3 Area of Focus: Distribution of Teaching Learning Materials . ..............................................................66 4.12.4 Area of Focus: Government Allocation ................................ . ..............................................................67 2

3. S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t S y s t e m s a n d P r o c e s s R e v i e w U n i t o f t h e P r e v e n t i o n D e p a r t m e n t CONTENTS LIST OF ABBREVIATIONS ........... .................................................. ................................................................4 EXECUTIVE SUMMARY ................................................................. .................................................................5 1.0 INTRODUCTION .................................................................... .. ............................................................. .11 2.0 OBJECTIVES OF THE REVIEW .................................................................................................... .........12 3.0 METHODOLOGY AND SCOPE ...........................................................................................12 4. 0 FINDINGS AND RECOMMENDATIONS ................................ .............................................................13 4.1 INTERNAL AUDIT ..................................................................................... .............................................13 4.1.1 Area of Focus: Audit Manual ..... ........................... ................. .............................................................13 4.1.2 Area of Focus: Annual Audit Plan .......................... ............... .............................................................14 4.1.3 Area of Focus: Audit Committee .......................... .................. ..............................................................14 4.1.4 Area of Focus: Tenure of the Audit Committee .... .................. .............................................................15 4.1.5 Area of Focus: Audit Queries ................................................. ..............................................................16 4.1.6 Area of Focus: Audit of Devolved Sectors ............................. ..............................................................16 4.1.7 Area of Focus: staffing ........................................................... ..............................................................17 4.1.8 Area of Focus: Physical Verification of Deliverables (Compliance Audit) ..............................................17 4.2 FINANCIAL MANAGEMENT ..................... ............................ ..............................................................18 4.2.1Area of Focus: Owned Source Revenue Generation ............. ..............................................................18 4.2.2 AREA OF FOCUS: STREET PARKING ................................ . ..............................................................26 4.2.3 Area of Focus: Tied Grant ...................................................... ..............................................................28 4.2.4 Comparative Analysis between Budgeted and Actual on Owned Source Revenue ............................. 29 4.2.5 Area of Focus: Receipt /Supporting Documents .................... ..............................................................30 4.2.6 Area of Focus: Withholding Tax, PAYE and NASSIT ........................ .............................................3 1 4.2.7 Area of Focus: Fixed Assets Register .................................... ..............................................................31 4.2.8 Area of focus: Minimum Wage .............................................. .............................................................32 4.3 HUMAN RESOURCES MANAGEMENT .................................. .............................................................33 4.3.1 Area of Focus: Strategic Plan ......................... ....................... .............................................................33 4.3.2 Area of Focus: Attendance Register ...................................... .............................................................33 4.3.3Area of Focus: Staff Annual Leave ......................................... ............................................................. 34 4.3.4 Area of Focus: Staff Personal Files /Records ........................ ..............................................................35 4.3.5 Area of Focus: Staff Performance Appraisal .......................... ............................................................. 35 4.3.6 Area of Focus: Job Description .............................................. ..............................................................36 4.3.7 Area of Focus: Recruitment and Selection ............................ ..............................................................37 1

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