1. 0

71. 70 The success of these reforms will depend on the commitment of OARG leadership, collaboration with oversight institutions, and active monitoring by the ACC. It is imperative that the OARG swiftly implements these recommendations to build a more resilient an d transparent institution. Failure to do so will not only compromise the integrity of the office but also erode public trust in its ability to fulfill its mandate effectively. The ACC remains committed to supporting the OARG in its efforts to enhance accountability and minimize corruption risks, ensuring that the institution operates in a manner that upholds the principles of good governance and public sector integrity.

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51. 50

29. 28 Management Response We acknowledge and share your concern regarding the absence of a procurement officer at the institution for the period of 2019 and 2020 fiscal years. We recognize that it was a risky administrative practice and we are sorry for any negative impact it may h ave had on the institution’s procurement needs. We also understand the frustration in not being able to identify who was responsible for procurement activities during that time. The lack of clarity regarding procurement functions and responsibilities durin g 2019 and 2020 is a serious concern, and we apologize for any confusion caused by this situation. The fact that no procurement officer was in place during that period raises questions about the existence of a procurement plan for those financial years. We acknowledge that without a designated procurement officer, it is highly unlikely that a comprehensive procurement plan was developed and implemented. We are sorry for any difficulties encountered during the review process in obtaining explanations and tan gible evidence regarding procurement activities during 2019 and 2020. We understand the importance of transparency and accountability in procurement processes, and we apologize for any shortcomings in providing the necessary information for your review. Mo ving forward, the Institution took immediate action to address these lapses and hence had ensure that a qualified procurement officer was posted to the institution to oversee procurement activities and in line with that, a comprehensive procurement plan ha s also been developed over the years for the period 2021, 2022, 2023, and 2024 to meet the institution’s procurement needs in a transparent and efficient manner which was forwarded to the National Public Procurement Authority for their

65. 64 6.8.6 Area of Focus: Records Management Finding The team discovered that the OARG office in Makeni does not maintain accurate records of documents for subsequent use. At the time of our visitation, there were inadequate office cabinets to keep files and as a result, some documents were laid on the bare floor. Please see photo below. Implication The poor records management may lead to misplacement of significant documents which cannot be easily traced for subsequent use. Also, laying official document on the floor may possibly attract the spillover effect of water and any oily substance which may alter the security features of documents.

69. 68 Findings The review team was informed that the regional offices have no hands in revenue collection. All payments are made into NRA’s bank account and payment slips are taken to the NRA staff who issue receipts for payments. Additionally, the regional offices do not undertake any procurement activities as everything needed for the smooth running of the offices comes directly from HQ, these include stationeries , office supplies etc. Implication The implication is that the regional offices has very little, or no autonomy and they stand the chance to suffer from lack of certain materials which will impact their work. For example, the team witnessed the shortage of forms from one of the offices. In addition to the intermittent shortage of forms the need for some urgent repairs on the office premises or machinery may be delayed and this may cause stress to the regional staff who may have to wait until staff from HQ arrive to fix these problems. Recommendation The review recommends that some modalities be put in place to ensure that these offices are empowered to be able to undertake some of these basic functions without recourse to HQ. The review team noticed that port Loko receives an amount of NLe3,000 as Imp rest per annum, whilst Makeni receives the same amount per quarter. Hence, we recommend that the imprest of the regional offices should be increased.

45. 44 system using pen. Additional ly, the review unveiled that, there was no unique reference number with key word classification systems, block letters and serial code assigned to each file per unit using indelible ink or permanent marker which could serve for ages without being easily remove fr om front side of the files. This unique referencing number may for instance includes; OARG/BR/CA/02/2023. Thus, means; OARG = Office of the Administrator and Registrar General which represents the Institution. BR = Business Registration (BR) which represents one of the units in the Institution. CA = Change of Business Address and this is one of the elements of BR. 02 = The second or otherwise business that change it address 2023 = Represent the current financial year. Thus, the above example illustrates best practice in terms of unique file numbering and referencing and, this is just for Business Registration but applicable to other unit within the institution. Implication The idea of no unique reference numbers on files with key word classification systems, block letters, serial codes etc. can create difficult situations to track records for decision making process. Recommendation We recommend that the Administrator and Registrar General in collaboration with all unit heads ensure that the institution’s files are

35. 34 the potential hazards this poses, as it has caused damage to the floors, cables, and equipment over the years. This issue however has been addressed to ensure the safety of our staff and the preservation of our valuable resources. In light of these finding s, we have taken action to rectify the situation. We are also developing and implementing a more efficient and organized filing system. Additionally, we will also explore options for better storage solutions to ensure the proper preservation of documents. Regarding the leaking roof, we have engaged the necessary professionals who have assessed the extent of the damages and they have proposed appropriate repairs. We apologize for any inconvenience or negative impact these issues may have caused. We are commi tted to resolving these problems and improving the overall functioning of the procurement unit. Your feedback is invaluable, and we appreciate your contribution to our continuous improvement efforts. 6.4 Finance Unit 6.4.1 Area of Focus: Petty cash As the name implies, is a small amount of cash on hand use for paying expenses too small to merit writing a cheque. This petty cash transaction if manage well, is very important to meet daily and routine expenses and can help greatly to foster better and t imely financial management process. In this regard, the team was interested to know how petty cash was being managed at OARG.

58. 57 to anyone who uses it, helping the organization efficiently communicate the change to anyone affected. SOPs also reduce the chance of miscommunication since the detailed steps leave little room for debate or questioning. Based on the aforesaid, the review team enquired from the ARG as to whether the institution operates using SOPs. Findings The review team was informed that the institution does not have SOPs but rather depends on the various Acts that speak to the various activities of the institution. Additionally, the review team was also informed that since all documents that are dealt with by the OARG are statutory instruments and therefore there is no need for the use of SOPs. Implications The implications are that without SOPs, an institution stands to lose the benefits derived from the use of SOPs as outlined above. Moreover, it is important to add that SOPs are still needed even when other published methods are available (such as Acts of Parliament) as SOPs describe the procedure in more detail than the published content, as well as explain any differences between the SOP and the published method. Recommendation The review team therefore recommends that the AORG work within the provisions of the Acts to develop the necessary SOPs to guide its day - to - day activities.

32. 31 Management Response We accept that in both 2019 and 2020, there was a lack of procurement staff and a failure to develop a procurement plan to assist the institution in fulfilling its mandates. We understand that this administrative gap could have potentially affected the smo oth functioning of the OARG, and we apologize for any negative impact it may have caused. Regarding the procurement activity carried out outside the approved work plan for the 2021 financial year, we take this matter seriously. We recognize the importance of adhering to approved plans and ensuring transparency in procurement processes. It is concerning that the review team was not provided with a supplementary plan or management resolutions authorizing this specific procurement activity. We have reviewed th e internal processes and decision - making that led to this procurement activity taking. The procurement activity in question, the fumigation service provided by A K Commercial Service, amounted to 30,000,000 Old Leones. We understand the need for clarificat ion and justification for this expenditure, as it was not part of the approved procurement plan. In response to this query, the Procurement Committee unanimously gave their approval for the Fumigation of the Office due to pest infestation and safety concer ns. The situation was urgent and therefore required immediate action to address potential risks or hazards this was the reasons behind this deviation from the approved plan. Additionally, we will provide a copy of the procurement committee minute to ensure transparency and accountability. We apologize for any confusion or concern caused by this irregularity, and we assure you that we are committed to rectifying the situation. We appreciate the audit team’s diligence in identifying this issue, and we

70. 69 7.0 CONCLUSION The corruption risk assessment of the OARG has highlighted serious governance, financial, and administrative deficiencies that create significant opportunities for corruption. The absence of strong internal control mechanisms, lack of compliance with financial procedures, weak procurement oversight, and inefficient records management have collectively undermined the effectiveness of the institution. Without immediate intervention, these weaknesses will continue to expose the OARG to financial mismanagement, operational inefficiencies, and reputational damage. A major concern identified in the assessment is the failure of the internal audit function to provide adequate oversight, as seen in the absence of annual audit plans and the non - existence of an audit committee. The poor procurement and financial managemen t practices, coupled with staffing shortages and inadequate records management, have further exacerbated institutional inefficiencies. Additionally, the regional offices are severely under - resourced, lacking critical personnel and financial management stru ctures, which increases their vulnerability to corruption. To address these concerns, the ACC has recommended strong institutional reforms, including enhanced financial oversight, improved internal audit processes, comprehensive records digitalization, and increased staffing in critical areas. These measures will help to strengthen transparency, accountability, and service delivery while ensuring compliance with legal and regulatory frameworks.

38. 37 momentums can severely undermine results and progress of the institution. This means that, government cannot fully meet its financial obligations to the OARG from 2020 to 2022 fiscal years. Implication The under – funding by government through the Ministry of Finance of the already plummeted budget of the OARG have greater impacts on the implementation of the institution’s activities and hence, derail from successes. Recommendation It is recommended by the team that the Ministry of Finance should regularly meet its financial obligations to OARG in order, to foster effective and efficient implementations of activities to enhance the achievement of results and progress. Management Response Management noted the concerns raised thereon in respect of the under - funding of the office in other to fully implement activities budgeted for. Management had made frank effort of lobby to Ministry of Finance for release of funds to meet its operations but it is still not forth coming. The plummeted of the office budget led to the scale down of some budgeted activities not fully implemented. Management also wants the team to forward some of these recommendations of the OARG review to the Ministry of Finance for release of funds to this office.

48. 47 Finding The review team observed that most of the units in the institution are understaffed to carry out their activities. Additionally, our review further discovered that many staff had either resigned or died without replacement and that hamper work progress wit hin the institution. Implication Shortage of employees limits the ability to promptly respond to members of the public, undermine service delivery and yield low results. This often leads to overcrowding; force staff to overwork and potentially increase the possibility of members of the public to cut corners which attract cost so as, to gain undue advantage in addressing their concerns. Recommendation In collaboration with the Human Resource Management Office (HRMO), the management of OARG should ensure that staff who had resigned or died are replace in order, to improve on the efficiency and effectiveness of service delivery. 6.5.5 Area of Focus: Classification/Separation of Records Classification in records management involves identifying and arranging records into categories according to an agreed structure and rules.

5. 4 TRIPS - Trade Related Aspects of Intellectual Property Rights WIPO - World Intellectual Property Organization WTO - World Trade Organization

46. 45 numbered and organized following the same pattern according to functions and activities in order to enable the easy tracking of records. 6.5.2 Area of Focus: Office Space and Cabinets This describes the physical availability of office space and enough cabinets to keep files for subsequent use by either the institution or clients/applicants. Finding From personal observation accompanied with thorough discussion with staff of the OARG, the team learnt that there was inadequate office space and cabinets to keep records of files. Each day dozens of files and records are generated from applicants or clien ts (members of the public) who need key attention for safe keeping. Also, due to the unavailability of office space and cabinets, most of the files are remarkably placed in an open table whilst, some are conveniently lying on the ground. Implication The shortage of office space and cabinets accompanied with the manner at which files were being handled by staff particularly placing them in an open table and some are lying on the ground, pose serious threat and complexity in records management. Recommendation It is recommended by the review team that, the management of the OARG should provide enough space and which will encourage the increment of cabinets for safe keeping of records.

67. 66 6.9.2 Area of Focus: Records Keeping One of the key mandates of the OARG is the proper storage of all the documents in their custody and to make them available as and when the need arise. Finding The team discovered that the OARG office in Port Loko does not label records or documents to enable easy identification and retrieval process for subsequent use. Implication This poor record keeping behavior may lead to difficulties in the search process of significant documents which cannot be easily traced when the need arises. Recommendation The team recommended that going forward, management of the OARG should maintain appropriate records keeping systems in the region (Port Loko) by ensuring that all files are label accordingly. 6.9.3 Area o f Focus: Revenue Collection The area of revenue collection is in the hands of the NRA staff who is assigned to the office as he/she is responsible for the issuance of receipts to clients who does business with the OARG. This said NRA officer is said to be housed in the regional offic e of the OARG alongside the OARG staff.

11. 10 Register including keeping a record of change of addresses/other particulars. It is the office that is charged with the responsibility to conduct civil marriages. In addition to the conduct of civil marriages, it is also responsible to register Marriage certificates, marriage certificate for Muslims and Christians and also register divorces; search, certify and prepare copies of wedding certificates. It is further responsible for the administration of the estates of deceased persons dying intestate as mandated by law or as ordered by the courts. It can represent the estate of deceased persons in any ongoing court action. The office of the Administrator and Registrar - General is responsible to register Adoption orders that have been granted by the High Court of Sierra Leone. The office of The Administrator and Registrar - General is responsible to manage the properties of deceased persons, collect rents and distribute same amongst the beneficiaries entitled thereto and to also make accounts available to the beneficiaries. The Re gistrar - General can also collect the entitlements of deceased employees from their employers and also recover their outstanding balance from the banks for the benefit of the persons entitled thereto. The Registrar - General can take over and administer any property that has been declared Bona Vacantia (property not owned by anyone) and manage such property on behalf of the state or sell such property.

27. 26 goods, works, and services that were above RFQ thresholds. Suppliers’ data base was adequately maintained by the procurement officer to keep track of vendors and their various area of specializations. However, below are findings and implications discovere d as well as recommendations proffered for best institutional practices during the course of our review. 6.3.1 Area of Focus: Procurement Plan The P rocurement P lan serves as a road map for the institution to carry out functions related to procurement particularly the sourcing of goods, services and works. Against that backdrop, the review team demanded to clearly ascertain if the institution in question (OARG) ha d been maintaining a formidable procurement plan that reflects the need of the institution in its operations. Finding First and foremost, the team discovered that, there was no procurement officer at the institution for the period 2019 and 2020 fiscal years to help the institution to meet its procurement needs. In addition to this risky administrative practice, the team c ould not find out who was responsible for procurement activities at such time. This means that, in certainty if there was no procurement officer at that time between 2019 and 2020 and the team could not identify who was in charge of procurement functions; it could be equally said that there was no procurement plan for those financial years. Even more so, with several deliberations with the current Procurement officer and other senior authorities of the institution to provide us an insight of how procurement activities were being carried out during these periods (2019 & 2020), none could provide any better explanations and

28. 27 tangible evidence to aide our review process. Consequently, only 2021 and 2022 fiscal years procurement plans were provided to us but 2022 financial year was out of our review scope for which we would not give it the much - needed attention except, we decide to observe certain patterns of procurements, we may either go beyond or above the scope of the review exercise. What strike the mind of the reviewers was, how the institution was meeting its procurement needs without a staff and plan? This humble question is left with the institution’s authorities to honestly answer. Implication Lack of procurement officer (s) and collaboratively procurement plan excerpt from various sectors and sub - units that reflects the needs of the institution to enhance its operations; may automatically undermine basic principles in procurement, and without regret promote unethical procedures which have maximum tendency to waste government resources and result in the mod of corruption. Recommendation Following this risky administrative practice for the periods (2019 and 2020), is recommended by the team that going forward, the procurement officer in collaboration with unit heads should develop procurement plan in line with the annual work plan of the i nstitution. Also, the head of the institution should ensure that, the procurement officer is functional at regular basis to help the institution meet its operational requirements needed as support to achieve overall goal and objectives.

88. 87 39 We recommend that a proper arrangement be made to ensure that the NRA’s staff operations does not adversely affect the overall operation of the OARG. An electronic means of making payments and issuing receipts could be a better alternative to the manual means currently in use. Digitalize payment system During the review, our team found out that the NRA staff in the OARG office in Port Loko is not regular at his seat. According to our discussion with an OARG staff, the NRA staff oversees revenue collections and issuance of receipt not only for OARG’s clie nts but also deals with clients of other government institutions within the region. Electronic payment system Verify payment system Registrar General

53. 52 Finding Throughout the review process, the team discovered that indeed files were being moved from one unit to the other especially the internal audit unit for verifications in relations to conformity with established laws and policies. In addendum, we also realized that files were moved from one unit for signature to the person assigned for such task by the institution. How ever, one major shortfall we noted was that, these movements of files were not even by fun recorded, monitored and tracked. This could be attributed to either, as a result of oversight or complete lack of knowledge from staff that such needs to be done to avoid manipulation of files. This terrible practice by the OARG staff left the review team in awe and anticipation that, there is possibility for documents or files to get missing and it will be very difficult to trace. Implication Failure by the OARG staff to maintain records for the physical movement of files from one staff to the other for either signature or verifications in accordance with applicable laws and procedures is deterrent to best practice. And at same time, when files are missing it is difficult to get the files again and this will probably result to a blame game syndrome. Recommendation Considering this peril manner at which files were been physically moved from one staff to the other, the team recommended that the leadership, in collaboration with heads of unit of the institution should develop and adopt systems for the physical movement of files either, through file movement form/slip or a way - book sign by both the sender and recipient staff to track every detail of files and avoid the

62. 61 Recommendation It recommended that the OARG put in place all necessary mechanisms to empower regional offices to start conducting marriages (both Christian and Muslim). .8.3 Area of Focus: Asset Register a nd Coding The essence of having an asset register and coding is to ensure that all assets of an institution are fully accounted for at any given time. On this note, the review team requested for the asset register and coding data, which was submitted for verification. Finding The team was provided with a Fixed Asset Register but realized that majority of the assets in Makeni office were procured over the years in Freetown (Headquarter). Coding was done with a delible ink creating possible risk for diversion to private use. Implication Failure to indelibly code asset is a high corruption risk issue as it will pave way for smooth conversion of government properties or assets to private ownership. Recommendation We recommend that m anagement should ensure that all the assets in the regions are coded with an indelible ink to avoid misuse and to distinguish them from private assets.

57. 56 The Review team recommends that in addition to the manual - hardcopy filing system, digital or soft copies of documents must be generated to form a backup and kept separately in case of any form of a disaster such as theft, fire or system crash. Management Response There was no record of work plan during the time under review but we had activities in line with the unit’s mandate. Considering the fact relating to the same we started keeping records of our work plan since 2022 till date. Records have never been kept randomly in the IP unit. All records are neatly kept in the unit’s cabinet and can be easily identify. The ICT unit is working on an automation system for IP and very soon the office will start searching for logos using the system. 6.7.1 Area of focus: Standard Operating Procedures (SOPs) A standard operating procedure is a set of written instructions that describes the step - by - step process that must be taken to properly perform a routine activity. An effective standard operating procedure clearly explains the steps taken to complete a task and informs the employee of any risks associated with the process. As such, it is clear that there are enormous benefits from the use of SOPs such as consistency and a decrease in the number s of errors made. An SOP can also help an organization evaluate employee performance, save time, money and create a safer work environment. Additionally, SOPs can improve communication throughout an organization. If a task changes, the SOP is updated and redistributed

68. 67 Findings During the review, our team found out that the NRA staff in the OARG office in Port Loko is not regular at his seat. According to our discussion with an OARG staff, the NRA staff oversees revenue collections and issuance of receipt not only for OARG’s clie nts but also deals with clients of other government institutions within the region. Implication The implication of the frequent absence of the NRA staff from office may cause delay in the operations of OARG in the region because the processing of documents is contingent upon the presentation of the NRA receipt which must be attached to the documents before they can be processed and presented for approval. Recommendation We recommend that a proper arrangement be made to ensure that the NRA’s staff operations does not adversely affect the overall operation of the OARG. An electronic means of making payments and issuing receipts could be a better alternative to the manual me ans currently in use. 6.9.4 Area of focus: Financial Management and Related Issues Record keeping and financial management are the two thematic areas of the review. These include revenue generation, utilization of funds and procurement. On this note the review team enquired into the financial management systems as obtained in the regions specifically the Northeast and Northwest regions where the visit took place.

34. 33 XL files and box files compounded with leak roof can result in a comfortable manipulation of important official documents. Recommendations Following these dreadful challenges of filing system in the procurement unit of the institution, we hereby proffer these under mentioned recommendations. • That the institution’s procurement unit should maintain an appropriate filing system where documents should be chronologically kept and easily retrievable for subsequent uses . • The filing apparatus which includes; cabinets, XL files and box files should be made available to enable safer records keeping and management process. • Routine maintenance on the institution’s building should be undertaken at a regular interval in order, to avoid roof leakage and damage of office equipment and important documents. Management Response We take the ACC’S concern seriously and acknowledge the poor filing system at the procurement unit. The lack of a proper filing system has resulted in difficulties in locating important documents, and we recognize the need for improvement in this area. We also understand and appreciate the concerns regarding the inadequate storage options for the bundles of documents. The current cabinets, XL files, and box files are insufficient to accommodate the volume of documents, leading to files being laid on the gro und. This creates potential risks such as damage, loss, or misplacement of important files. Furthermore, the revelation that the office is subjected to leakage during rain showers was indeed alarming. We understand

6. 5 EXECUTIVE SUMMARY The Office of the Administrator and Registrar - General is a highly critical and important office in the country. Pursuant to Cap 256 of the Laws of Sierra Leone 1960, the Office of Administrator and Registrar General in Sierra Leone is responsible for the registration of all legal instruments such as conveyances, leases, mortgages, agreements, Deed of Gifts, Vesting Deeds, Statutory Declarations, Deed of Partition, Power of Attorneys and other instruments. It is also responsible for the registration of entit ies such as business registration (sole proprietors and partnerships), maintain the Register including keeping a record of change of addresses/other particulars. A thematic Review of the Office of the Administrator and Registrar General on Records and Financial Management was conducted by the Anti – Corruption Commission (ACC) with a view to identify weaknesses in the practices and procedures of the establishment th at may provide opportunities for corruption or to ascertain that expected internal controls are in place and effectively working. The review proffers recommendations on ways to address identified weaknesses and enhance service delivery. The review is part of the general mandate of the Commission to review practices and procedures of all MDAs including the office of the Administrator and Registrar General. The review focuses on records keeping, retrieval or accessing of records and their s ubsequent disposal. It also looked at the effective use of resources with regards revenue generation and utilization. The report contains findings and recommendations and compliance matrix.

50. 49 Finding Records classification within the OARG is highly comp lex with contradictory mix of non - sequential and sub - series filing systems. The team discovered that all units maintain ledger book as a paper – based record keeping system to record information about clients/applicants but even so, information are not separated in the ledger book making it difficult to group them into various categor ies of each unit. Following this era of paper – based records management system, in the various filling cabinets, documents were not serially and categori c ally store d per unit. For instance, within the business registration unit, there exist various revenu e streams which includes; registration of new business, change of business address, change of nature of business etc. Therefore, in a perfect world, it is expected that, whatever documents generated in these categories should be recorded, filed and store s eparately under business registration unit. However, on the contrary, our review did not realize such practice to give to records classifications and separations. Again, at the central archive, the same practice dully occurs.

56. 55 Based on observation, it was discovered that records are kept randomly in the IP unit without any form of identification or separation in the filing system. The team learnt that the IP unit does not have a system interface to carry out search and so it has to be done manually for names and or logos. IMPLICATIONS In the absence of a work plan , critical activities in the unit will not be identified, focused upon and aligned to the institutions strategic plan to support its functions and goals. Lack of separation of records/documents makes it cumbersome to search for the documents when they are needed. Manual search can consume a lot of time/efforts and records can be lost in bulk chunks and piles of documents. Records keeping in the IP unit have to take into consideration Regulatory compliance to avoid future problems/litigation. RECOMMENDATIONS The team recommends that the IP Unit should develop annual work plan to catalogue its planned activities/objectives which should be aligned to the institutions strategic plan. The team also recommends that documents/records should be uniquely separated, labeled and filed sequentially to ensure and maintain originality, quick/accurate and effective retrieval of information and where necessary the disposal of unwanted records.

66. 65 Recommendation The team recommended that going forward, management of the OARG should maintain appropriate records management systems in the region (Makeni) and avoid laying official documents on the floor. 6.9 PORT LOKO DISTRICT (PORT LOKO TOWN) 6.9.1 Area of Fucus: Staff Strength The staff strength of an organization or institution play a significant role in the overall performance of that organization or institution. Considering the enormity of the work of OARG, the review team sought to know the staff strength of the North - wester n region. Findings Our review revealed that, the OARG office in Port Loko is grossly understaffed with only two staff. Therefore, considering the volume of work in the region, we learnt that two staff cannot effectively and efficiently undertake all the functions. Implication Two staff in the OARG office in a whole region will extremely affect the timeliness, accuracy, and quality of work. Recommendation The team recommends that, the OARG in collaboration with Human Resource Management Office (HRMO), should request for additional staff in Port Loko to boost staff strength in the region for effective and efficient service delivery.

36. 35 Finding During the review process, the team discovered that, the F inance or A ccount U nit of OARG does not maintain petty cash, utterly. According to the F inance/ A ccount O fficer is that, this absence of petty cash had become an institutional norm not only for this current Administrator general but also, the previous one. However, this does not mean that the institution is not meeting smaller expenses but used cheque form of payment. Implication Using cheque to remit petty cash transactions would be very inconvenient and impracticable. Recommendation We recommend that the management of OARG should establish a petty cash system, design policy for managing the cash and establish accurate, accountable and transparent recording procedures . Management Response Management noted the concerns raised thereon in respect of the accounts unit not maintaining petty cash for the office for the payment of smaller transactions. Management will review the previous system of writing cheques for trivial transactions and move to a new system of allowing the accounts unit maintaining a smaller amount of cash as petty cash for trivial transactions b ut use cheques for huge transactions payment.

42. 41 revenue stream from which taxes were collected ( small arms) and as a result, their income record always outweighs OARG cash book record. On that note, those additional revenue streams by NRA have always created huge difference in reporting. More importantly, with all the several revenue streams of NRA, what is mor e striking was in August, when OARG cashbook exceeded NRA revenue records. Additionally, no further explanation was provided to the team for the huge decline of revenue mobilization by NRA. However, all these records contain ed in the above table were provided by OARG through the account unit. After huge efforts made by the team to clearly understand revenue generation records for the period under review, the NRA could not provide any records to enhance the review process. Also , the team realized that OARG does not receive any percentage (%) of the total revenue collected by NRA to run its administration instead, the institution’s budget is entirely funded by the government of Sierra Leone thr ough the Ministry of Finance. Implication Unavailability of revenue records by either the OARG or NRA for the period under review do not provide adequate knowledge on revenue generation and reporting. Recommendation It is therefore recommended by the team that data on revenue generation should be recorded and file accordingly to enable easy accounting and reporting.

30. 29 vetting and approval . We appreciate the audit team’s diligence in identifying these issues, and we assure you that we are committed to rectifying the situation. We apologize for any inconvenience or negative impact caused by the absence of a procurement o fficer and plan during 2019 and 2020, and we thank you for bringing it to our attention. Your feedback is invaluable in helping us improve our procurement processes and ensure the effective functioning of the institution. 6.3.3 Area of Focus: Procurement Activity outside the Work Plan To be in adherence with not only procurement plan but also, other work plans are significant and give credence to best practices, if institutio ns are to implement and achieve timely results. Finding Despite the reality that in both 2019 and 2020, there was neither a procurement staff nor single plan to assist the institution fulfil its mandates. Therefore, this administrative jeopardy could one way or the other affect (s) smooth functioning of the OAR G. However, one thing that was obvious, was the fact that there was a procurement plan for the period 2021 financial year which forms the end year for the scope of our review exercise. With critical examinations of the 2021 procurement plan and executing docu ments unveiled that one procurement activity was undertaking which did not form part and parcel of the approved plan. In order words, the activity was carried out outside the approved work plan and, in any case, team could not be provided with neither a

39. 38 6.4.3 Area of Focus: Budget Preparation The preparation of annual budget involves several steps which includes; determination of the overall institutional targets, expenditure level and financial planning and forecasting. For the institution to achieve its mandates, the preparation of budget mus t be coordinated among all unit heads appropriately. Therefore, the review team want to know how participatory the budget preparation was, within the institution. Finding The team discovered that budget preparation is not participatory within the institution for the period under review. Even though, the current Account/Finance officer acclaimed that annual budget of the institution is prepare d through the involvement of unit heads. On the contrary, our review proved otherwise, utterly, the review team could not find any evidential documentation upon which budget preparations were participatory for the years (period under review) and current time. This shows that, top managem ent do not have confidence on its staff from various unit. Implication Since budget preparation is not participatory, it cannot give clear direction on which aspect or unit money can be spent to gain immediate results and which can complement the achievement of results in other unit of the institution. As such, the budget can not be spent in a way that better reflects the strength, need and aspiration of the institution.

40. 39 Recommendation It is recommended by the review team that, going forward management should ensure participatory budget preparation for appropriate allocation of resources, manage cash flow more efficiently, monitor performance and progress of the institution. Management Response Management noted the concerns raised thereon in respect of unit heads not fully involved in the budgetary processes for the period under review and management wants the team to know that the budgetary processes of the OARG is fully participatory. The following are evidenced to show the participations of unit heads and regional heads: i. Minutes of Budget Meetings ii. Signed attendance of budget participants iii. Forward budget of units or regional heads All of these documents are available in the account’s unit. 6.4.4 Area of Focus: Revenue Generation Reconciliation Revenue reconciliation is very important because it describe the process of comparing revenue figures collected from two or more sources to identify discrepancies or error in reporting. On that note, the review team would like to know whether total revenu e collected by NRA correspond to OARG cash book.

47. 46 6.5.3 Area of Focus: Records Digitalization It is the process of digital imagining or scanning to enhance the conversion of paper – based records into electronic documents which simplify the tedious burden of records management. Finding During the review process, the team realized that there was no automated digital records management system to reduce the manual work of handling records or files. Further discussions with the management of OARG clearly unveiled that, efforts had been emplo yed to install digitalization system of records but severely constraint with funding challenge. This challenge has greatly slowed the digitalization process, said management. Implication The lack of converting paper documents to digital files can increase the likelihood of loss of documents, age – related deterioration and in an event of fire outbreak and leakage of roof in the office, it will also lead to physical damaged of documents wit hout any means of recovering. Recommendation The team recommend that management of OARG should adapt records digitalization process to boost efficiency, easy retrieval, increase security etc. of documents. 6.5.4 Area of Focus: Shortage of Staff A staffing shortage occur when there is lack of employees in an institution to implement activities that would underpin the achievement of the overall goal.

61. 60 the OARG offices in the North – west and North – east regions in Port Loko and Makeni towns respectively. 6.8.1 Bombali District (Makeni) 6.8.2 Area of focus: Marriages One of the functions of the OARG is to conduct marriages (both Christian and Muslim) and to register and keep records of same. Based on the aforesaid, the review team enquired from the OARG regional staff whether they do conduct marriages at regional level. Finding The review team discovered that the OARG offices in the regions does not conduct marriages (both Christian and Muslim) even if members of the public request same because they lack the required capacity to do so. However, the office does register marriages and issue certificates to people who want to register their marriages. Implication The implication is that the full activity of the office is curtailed and hence members of the public do not benefit from the OARG office in the regions in respect of the conducting of marriages. This could probably reduce the revenue generation in this re gion as well. Furthermore, over centralization of marriages ceremonies at HQ will make it difficult for clients intending to get married secure dates for their ceremonies; this may create the risk of clients having to bribe officials or official soliciting advantage to be allocated dates for their ceremonies.

19. 18 6.1.5 Area of Focus: Understaffing It is a situation where in an institution employs few staff to carry out specific functions. Finding Our review discovered that, the internal audit unit of the OARG is grossly understaffed with only one staff who happens to be the Senior internal auditor. Therefore, considering the volume of work in the institution, we learnt that the senior internal auditor alone cannot effectively and efficient undertake all audit functions. Implication Undertaking audit functions by one staff in the OARG will extremely affect the timeliness, accuracy and quality of work. Recommendation The team recommends that, in collaboration with Human Resource Management Office (HRMO) and Ministry of Finance, the management of OARG should request for one additional internal auditor to boost the strength of the unit for effective and efficient internal auditing. Management Response This concern is well noted and it will be discussed by both management of the OARG and the Ministry of Finance. 6.1.6 Area of Focus: Poor Records Management Finding The team discovered that internal audit Unit of the OARG does not maintain accurate records of documents for subsequent use. This was because, chunk of document found within the auditor’s purview at the

52. 51 Implication Failure in classification and separation of records and files may create an interlocking burden to retrieve a file particularly when it is needed for subsequent purpose. Recommendations The team recommend as follows that; • Each unit developed records classification schemes that are simple and logical, enables categories to be easily differentiated from each other, which will be presented to senior management for endorsement. • Management of OARG should ensure that each unit practice classification of records and files thereby simplifying the process of retrieval, save time and efforts. 6.5.6 Area of Focus: Physical Movement of Documents This is the movement of files or documents from one staff to the other, or from one office to another. This process can be a bit cumbersome in its nature. For best practices, it is required to monitor the movement of these files or documents and there are number of ways for which this movement of files can be monitored, either through file movement slip or way book. This is bec ause files can get lost without the knowledge of staff. Considering the relevance of this institution on records management, the tea m would like to know if the physical movement of files from one staff or office to another are being monitor ed or track ed with evidence .

59. 58 6.7.2 Area of focus: Whistle blowing Whistleblowing is an act whereby an employee or any other person or persons discloses information about an organization which they reasonably believe that has evidence(s) of a violation of any law, rule, or regulation, or gross mismanagement, a gross waste of funds, an abuse of authority, or a substantial and specific danger to public health or safety. In other words, whistleblowers are normally referr ed to as informants. While many people applaud their activities, others view them as controversial or even term them as betrayals. However, whistleblowers help report crimes ranging from varying proportions which is difficult if not impossible for law enforcement agencies to discover on their own. These crimes can have a significant financial impact on the government, businesses, tax payers and the wider populace as the case may be. Whistle blowing is very essential for the following reasons; it helps in combating fraud, prevents issues from escalating, reduces losses, avoid reputational damage, helps in awareness raising and so on. It is in line with the above benefits of whistle blowing that the review team sought to know if there is any whistle blowing mechanism in place at the AORG. Findings The review team was informed by the ARG that there is no whistle blowing mechanism at the OARG but that the ARG has put in place several mechanisms to forestall any of the corruption risks as highlighted above.

9. 8 Poor Filing System The team discovered that there was a poor filing system of the procurement unit to keep track of official documents. Following these dreadful challenges of filing system in the procurement unit of the institution, we hereby proffer these under mentioned recommendations. • That the institution’s procurement unit should maintain an appropriate filing system where documents should be chronologically kept and easily retrievable for subsequent uses. • The filing apparatus which includes; cabinets, XL files and box files should be made available to enable safer records keeping and management process. Routine maintenance on the institution’s building should be undertaken at a regular interval in order, to avoid roof leakage and damage of office equipment and important documents

10. 9 1. 0 BACKGROUND AND INTRODUCTION The Anti - Corruption C ommission (ACC) was established with the primary aim to prevent, investigate and prosecute corrupt offenders and to also provide accurate information to the general public on the dangers of corruption in our society. The preventive aspect of the ACC is provided for in section 7 and 8 of the Anti - corruption Act of 2008 as amended. The ACC has benefitted from funds from OSIWA to enhance the effectiveness and e fficiency of the prevention department. Part of the fund was used to conduct the Thematic Review of the Office of the Administrator and Registrar General on Records and Financial Management. The Office of the Administrator and Registrar - General is a highly important office to land owners, the business community and other stakeholders and the general civil populace. It is mandated to ensure an efficient and effective administration and registration of instruments and as the official Administrator of Sierra Leone . The Office of Administrator and Registrar General in Sierra Leone is responsible for the registration of all legal instruments such as conveyances, leases, mortgages, agreements, Deed of Gifts, Vesting Deeds, Statutory Declarations, Deed of Partition, Powe r of Attorneys and other instruments pursuant to Cap 256 of the Laws of Sierra Leone 1960. It is also responsible for the registration of entities such as business registration (sole proprietors and partnerships) (Companies are now registered at the Cooperate Affairs Commission), maintain the

55. 54 Using wooden cabinets for very bulky documents can lead to moisture on documents and even cracks on cabinet. It can also make room for molds and insects which will lead to damage of documents RECOMMENDATIONS Files must be stored systematic ally and in chronological order having in mind the two main principles of archiving; Provenance and Original Order which relates to the preservation of contextual information about archive. Preserving the original form of the records, providing access to r ecords for future generations, and providing a permanent record of the organization’s . activities The RT recommends that a policy must be developed on how files should be moved to the archives . Secured metal cabinets is preferred to that which is currently in existence for the storage of documents. 6.7 Trademark a nd Intellectual Property Sierra Leone is a member of the World Intellectual Property Organization (WIPO) and the African Regional Intellectual Property Organization (ARIPO). Sierra Leone is also a member of the World Trade Organizations (WTO) and is therefore bound by the agreeme nt on Trade - Related Aspects of Intellectual Property Rights (TRIPS). FINDINGS The review team discovered that there was no workplan for the IP unit for the period under review (2019, 2020 and 2021).

60. 59 The review team learnt that some of the mechanisms put in place by the ARG include the introduction of a securitized ID card to be worn by all staff on duty as well as the installation of CCTV cameras in the office environment Additionally, the review team was informed that the OARG has equally embarked on series of media engagement to sensitize the public with regards the way the public should engage with the OARG in a risk - free manner Implications Despite the OARG having in place all the mechanisms highlighted above as means to mitigate all the corruption risks mentioned above, it is evident that without whistleblowers, it is possible that stakeholders may find it difficult or impossible to detect c ertain illegal or unethical things happening under their noses. This is why a proper whistle blowing system is essential in the management of breaches in a quick and constructive way. Recommendation Based on the perceived merits of whistle blowing as already highlighted, the review team recommends that the ARG works with the relevant authorities to institute a well - protected whistle blowing mechanism to help in the discharge of their duties. 6.8 OFFICE OF THE ADMINISTRATOR AND REGISTRAR GENERAL O.A.R.G REGIONAL REPORT This R egional O ffices of the OARG were reviewed with the aim of comparing some of the key findings on the thematic review on records and financial management in Freetown. This review was conducted at

64. 63 Recommendation The team recommends that management of the OARG should investigate this abandonment of duty station by the staff, take necessary actions to affect discipline within the Human Resources (HR) landscape of the Institution. 6.8.5 Area of F ocus: Accountant Finding T he team found out that the OARG office in Makeni does not have an Accountant to enhance revenue collection, systematic financial record keeping and track expenses in the region. Implication Without an Accountant in the regional offices as seen in Makeni office, there would be potential pitfall on revenue generation, errors, and inconsistencies in maintaining accurate financial records. This would lead to poor bookkeeping and accounting practices. Recommendation It is recommended by the team that, OARG in collaboration with the Human Resources Management Office (HRMO) and Accountant General’s Department (AGD), should facilitate the process of ensuring that an Accountant is deployed to the regional office in Makeni who will lead and advice on financial operations in the region.

33. 32 will take appropriate corrective actions to prevent similar occurrences in the future. Once again, we apologize for any inconvenience or negative impact this may have had on the organization, and we thank you for bringing it to our attention. 6.3.4 Area of Focus: Poor filing system Good filing system is more than imperative to keep track of transaction records and when they are needed for an informed decision - making process, it can be easily retrieved without any harm or dilapidation. In this regard, the team further explores the filing systems of the institution. Finding The team discovered that there was a poor filing system of the procurement unit to keep track of official documents. On that note, files or documents are inadvertently stored which may create difficulties to search for them. Also, cabinets, XL files and bo x files were not enough to keep bundles of documents for subsequent uses . Due to that, some files or documents are boldly laid on the ground. With a closed discussion with the current “Procurement Officer”; we learned that; the office is subjected to leaka ge even with a little down pour of rain due to leak ing roof. This is perilous because over the years, this has cause damage to the floors, cables and even some equipment. Implications Poor filing systems may create difficulties to retrieve them especially, when they are needed for an informed decision - making process. Also, the lack of filing apparatus which includes; cabinets,

43. 42 Management Response Management noted the concerns raised thereon in respect of revenue reconciliation between NRA and OARG and management wants the team to know that reconciliation was done for 2019 and 2020 and it is a routine process for both NRA and OARG. Management wants the team to know that revenue reconciliation has been thing of the past as evidenced by the documents provided by the accounts unit for the period 2021 detailed the amounts collected by OARG and NRA on a monthly basis. Also, as you have b een informed by the account’s unit that, despite the huge revenue generated by this office, the OARG does not retain any percentage of its generation. 6.4.5 Area of focus: Asset Register and Coding Finding The team was not provided with a Fixed Asset Register and the team realized that most of the institution’s assets procured over the years in Freetown (Headquarter) were not coded. Implication Failure to have a valid asset register for an institution is a high corruption risk issue as it will pave way for smooth conversion of government properties or assets to private ownership. Recommendation We recommend as follows ; Management should ensure that all the institution ’s assets are coded to avoid misuse and to distinguish them from private use.

14. 13 internal auditing deals with issues that are fundamentally significant to the survival and prosperity of any institution. In sum, internal auditing helps an institution to succeed by assessing risks and improved on internal controls. 6.1.1 Area of Focus: Internal Audit Plan An annual Internal Audit plan provides a pathway through which an audit functions are carry out on a yearly basis. Therefore, Internal audit planning is very crucial for both internal and external audits. A good audit planning will help the auditor to minimize risks, improve audit efficiency, and meet its objective at the most maximum efforts. In summary, the internal audit plan is a list of audits engagements to be conducted in an institution within a specified period. Finding Following scope of the review, it was certain that the senior internal auditor who happen s to be the only staff in this unit failed to furnish us with an annual work plan that would have cataloged audit activities and areas of interventions in various unit s of the institution for the period under review. This clearly indicated that, no annual work plans were presented to the team for 2019, 2020 and 2021. Implication The absence of annual internal audit plan for the period under review, automatically, exposes the OARG to inadequate evaluation of the effectiveness of risks management, internal controls and compliance protocols as well as governance processes. This means that for the period under review, due attention was not given to internal audit which may probably provide maximum proclivity to undermine transparency and accountability.

26. 25 examined the attendance Register which speak to the fact that Staff always signing into the Register on a daily basis, and the above - mentioned Staff claimed that they make themselves available for the verification for which I believed it might be an oversi ght from the ACC team . 6.3 Procurement Unit Procurement generally involves acquiring goods, services and works from an external source, often via a Request For Quotations (RFQs), tendering or competitive bidding process. It is therefore, necessary to ensure that the goods, services and works procured are of high priorities and qualities. On that note, the need to establish procurement unit cannot be over - emphasized to give credence to best practice and allow efficient use of limited resources. The Office of the Administrator and Registrar General (OAR G) has a procurement unit charged with the sole responsibility of acquiring goods, services and works. Meanwhile, in every financial year, responsible official (Procurement Officer) in the OARG developed procurement plan w hich served as potential road map for the implementation of procurement activities. Thus, the establishment of the OARG’s procurement unit was in line with the provision in Section 29 of the National Public Procurement Authority (NPPA) Act requires procuring entities to prepare a procurement plan for each fiscal year with a view to achieving maximum value for public expenditures. Section 18 (1) of the National Public Procurement Act of 2016 stated that, a procurement committee shall be established in every procuring entity. Closely understood, the OARG had a functional procurement committee that usually took decisions regarding the procurement of

54. 53 risk of misplacing them. This will improve accountability and transparency in files management. 6.6. Archive An archive is a collection of data moved to a repository for long - term retention to be kept separate for compliance reasons. This can include a simple list of files or files organized under a catalogue structure depending on how the programs support the a rchiving. FINDINGS The team discovered that there are i rregular filing system/poor filing system at the OARG . Poor records management system can make it difficult to locate important documents. This is especially true when documents are not fil ed in any particular order or were generally misfiled. The review team discovered that there is no procedure to move fi les from HQ to the archives at W aterloo Street . The review team observed that the cabinets are wooden cabinets. IMPLICATIONS Poor records management/filing system can lead to excessive waste of time in sorting through messy/mixed up cabinets and valuable working spaces can be used to store paper work and files can be misplaced or buried in chunks. Where there is lack of procedure to move documents from HQ to archive can lead to movement been done haphazardly.

16. 15 that, there were no standards and framework developed for performing and promoting internal auditing in respect of verifications of deliverables related to procured items . Implications In the absence of physical verification of deliverables, loopholes for corruption and substandard work will not be identified. Additionally, lack of standardized framework and check list to conduct internal auditing on deliverables may successfully signals a weak internal controls system with regards to same. The essence of such control procedures is to evaluate the effectiveness of the procurement system, identify gaps and weaknesses that will lead to inefficiencies, errors , or fraud. Recommendations Following the review exercise, the team recommends as follows that; • T he Internal Audit Unit should develop a standardized framework and check list which will enable physical verifications of deliverables and/or consumables. • T he Internal Audit Unit must physically verify all deliverables from initiation to completion; produce a quarterly report on same for sound economic, efficient, and effective management of public funds. Management Response The Public Financial Management Regulations 2018 did not provide a direct or specific responsibility to the Internal Audit in receiving and checking stores (see section 180 (3) of the above regulations).

31. 30 supplementary plan that entails this particular procurement activity nor management resolutions that gives the authority for this activity to be undertaken. The table below gives a full - blown justification of the procurement activity in question. Description of Procurement Activities Service Provider Amount (Old Leones) Fumigation service A K Commercial Service 30,000,000 Implication The idea of undertaking procurement activity outside the plan does not represent best practice and by way of implication, it is budget belt tightening with tendency to suppress the implementation of significantly planned and approved activities. By that, i t may undermine achievement of the mandates of the institution. Recommendations We recommend as follows ; • Going forward the approved procurement plan should be followed accordingly by the procurement officer. • In a situation where an important procurement activity should be undertaken to boost operations and office environment of the institution but the activity is not included in the approved work plan, the procurement unit should develop a supplementary plan and seek approval by the procurement committee before implementation for the culmination of best practice.

12. 11 The Registrar - General is responsible for the registration of Intellectual Property and Trademark. 2.0 OBJECTIVE The purpose of the review was to track the processes and procedures involved in storing accessing, disposing of records , how funds are generated , utilized , ensure that OARG makes effective use of its resources and manages its records effectively. The review aims to identify weaknesses in revenue generation, budgeting , records management processes that will create opportunity for corruption and proffer recommendations to address those weaknesses. 3.0 SCOPE The review examined revenue generating areas, budgets and records management processes for the OARG for the years 2019, 2020 and 2021. The main focus on the review was on how records and finances are managed. Budget and other relevant documents were examined that have a bearing to the review. 4.0 METHODOLOGY The methodology for the review involved quantitative and qualitative research. 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.

24. 23 retirement package and other benefit to meet the contingency needs of these staff and their dependents in the future. Recommendation We recommend that the HR unit of OARG should ensure that these staff have their NASSIT number and facilitate the enrollment in to the contribution scheme. Management Response Above - mentioned Staff do have their NASSIT numbers excluding Mr. Abdul Rahman Mahdi Esq, State Counsel who is seriously sick and was flown out of the country to seek medical attention for ease of reference kindly find sample copies of NASSIT for each Staff . 6.2.4 Area of Focus: Physical Verification of Staff This was done to ascertain reasonable assurance regarding the existence of employees in the institution . Finding During the review exercise, the team undertook physical verifications of employees. The review unveiled that some staff in head quarter (Freetown) did not make themselves available for verification. Details of these staff are outlin ed below.

15. 14 Recommendation It is recommended by the team that, the Senior Internal Auditor (SIA) should prepare audit plan on a yearly basis, approved by the audit com mittee for operationalization in a bid to ensure due diligence and compliance mechanisms needed to improve on service delivery. Management Response The Annual Work Plan at the OARG is based on the risk factors as well as the existing Audit Universe. However, there are no significant changes on the Audit Universe at the OARG over the years. Therefore, the AWP provided to ACC staff is valid for the year s in question. 6.1.2 Area of Focus: Physical Verification of Supplies Section 6(4) of the GBAA 2005 states that the Internal Auditor has the following duties in the performance of its functions: (a) Ensure strict adherence to all control procedures introduced to safeguard the assets and records of Government; and (f) Review all contracts ensuring effective performance and value for money. Section 11 (2) (c) of the Public Finance Act, 2004 provides that: “...... internal auditors may investigate whether there are adequate measures and procedures for the proper application of sound economic, efficient, and effective management of public funds.” Finding s The Internal Audit does not conduct physical verifications of deliverables ; such as supply of procurement items and distributions, fuel allocation, etc. to ensure that the right specifications are delivered on time. These deliverables needed to be audited from initiation to completion to ensure value for money. Also , our review discovered

20. 19 time of our review were laid on the ground floor of his office. On that note, the internal auditor does not treat document with utmost seriousness. Implication The poor records management may lead to misplacement of significant documents which cannot be easily traced for subsequent use. Also, laying official document on the ground floor may possibly attract the spillover effect of water and any oily substance which may alter the security features of documents Recommendation The team recommended that going forward, the internal audit Unit of OARG should maintain appropriate records management systems and avoid laying official documents on the ground floor . Management Response The Internal Audit Unit at the OARG has a metal cabinet to keep records or files related to audit functions. However, the files or documents in question were subject of a review by the Internal Audit and returned to their respective Units thereafter. Therefore, the Internal Audit was displeased with the unprofessional attitude of the ACC staff who unceremoniously took a snap shot with no enquire from the Unit. 6.2 Human Resources Unit The HR unit in an institution seeks the welfare of employees in order, to increase productivity. Also, the HR in any institution deal with employee - related matters including such as recruitment and

17. 16 Moreover, there is a Directorate for Stores verifications at the Ministry of Finance and the Internal Audit at the OARG has been providing recommendations for an experienced Stores keeper. However, with the exception of a special assignment, our responsibilities are limited to the audit of procurement, Stores and Fuel rather than providing management functions. 6.1.3 Area of focus: Audit Reports The Internal Auditor’s report supports institutions to examine key risk factors by highlighting positives, negatives and proffered appropriate recommendations that will inform management about what needs to be improved, if effective and efficient service delivery is of high priority . It allows the institution to forestall potential future concerns as well as identifying current weaknesses. Finding At the time of the review, the team was not provided with neither soft nor hard copy of 2021 annual internal audit report. In addendum, the 2019 and 2020 annual report s presented by the internal auditor were not exhaustive and detailed . Implication Failure to produce annual internal audit report may not continually unveil weaknesses of the institution and can stringently undermine progress of the unit which will place the institution at the stake of internal controls problem . Recommendation We recommend that, the internal auditor should produce an annual audit report in order, to track weaknesses and proffered recommendations for an improved service delivery.

21. 20 selection processes, policy administration, training and development, benefit administration, new employee orientation, personnel records retention, salary administration, implementing labour laws, employee health and safety, employee discipline and grieva nce redress administration and other employee assistance programmes. 6.2.1 Area of Focus: Staff Performance Appraisal This is the regular review of an employee’s job performance and overall contribution to an institution. This performance appraisal should be done on both mid – year and annual basis to evaluate an employee’s skills and achievements. Finding The team observed that the HR unit of OARG does not undertake staff performance appraisal as an evaluation process to document how well the employee s are carrying out their job functions. Implication Failure to conduct periodic staff performance appraisal may debar management from acquiring the capacity strength of staff and measure the competency expectations set by institution for the performance of their job functions. Recommendation The team recommended that going forward the HR unit of OARG should conduct mid - term and annual staff performance appraisal to ensure systematic evaluation of employees, ascertain staff strength and measure expectations. Management Response From the inception stage of the process, the team from ACC was well informed on the situation on the ground that there were some lacunas

63. 62 6.8.4 Area of Focus: Staff Punctuality Staff punctuality is an important indicator of the level of commitment the staff places on his job. Staff absconding from work especially when they are posted to remote places is a well - documented phenomenon. So, the team reviewed the attendance register t o determine the punctuality of staff. Table: Showing Staff who Abandoned Duty Station Finding The ACC review team discovered particular staff who was transferred to Makeni office has abandoned his duty station. This was clearly understood after careful examination of the attendance register as against the staff list in the region. Also, the team could not receive or set hands on any official do cument serving as evidence for abandonment of post in respect of this staff. However, details of this staff are listed below in a table. Implication This indicates that the staff is been paid and not working and constitutes neglect of duty and is a just cause for termination of employment. Also, abandoning duty station create work vacuum and increase work burden on the current existing staff. No Name of Staff Substantive Designation Pin Code Salary Grade 1 Ibrahim Conteh Senior Registration officer 132123 8

13. 12 The review process was initiated by an inception meeting with management of The OARG. The review team examined information on: ➢ Approved budgeted activities for the years under review ➢ Actual allocation and disbursement ➢ Expenditure and accountability of allocations for the years under review ➢ Variances ➢ Bank statements ➢ Supporting documents of utilized budgets ➢ Physical verification on Staff and Assets both in Freetown HQ and the regions. 5.0 LIMITATIONS OF THE REVIEW Due to lack of funds/low budget at the time of the review, then team could not visit all the regional offices. A sample was taken to visit the offices in Port Loko and Makeni. 6.0 FINDINGS, IMPLICATIONS AN D R ECOMMENDATIONS 6.1 Internal Audit According to the Institute of Internal Auditor (IIA), "Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an institution ’s operations. It helps an institution accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes." Furthermore,

18. 17 Management Response The Internal Audit provided with ACC a summary of the status of the 2019 and 2020 final report by means of an email. The Internal Audit did not receive any acknowledgement on documents received by the ACC staff, and in addition, ACC did not state how detai led and exhaustive they may need the report. However, 2021 annual report is available. 6.1.4 Area of Focus: Audit Committee An audit committee is a body that takes care of an institutional financial reporting with respect to the internal controls in place to ensure accuracy. Also, this committee monitors the institution’s overall processes and ensures they comply with standards, guidelines and national laws and regulations. Finding The review team discovered that, there was no established and functional audit committee in the OARG . Implication Non – functional audit committee provides weak oversight of the financial reporting process, the OARG audit process and systems of internal controls as well as compliance with laws and regulations. Recommendation The team recommends that management of the OARG should establish a functional audit committee to strengthen internal controls system for an improve service delivery . Management Response This issue is noted and it will be discussed by both management of the OARG and the Ministry of Finance

37. 36 6.4.2 Area of Focus: Budget Funding Budget is a financial plan of any institution that project the future income and expenses. In that vein, the team would like to know how budget of the institution is prepared, and at the same time, how the budget is funded? Findings A close discussion with the finance officer of the Institution revealed that, the overall budget was usually prepared through participation with all the Units. However, the team could not see any evidence of participation by the various units with regards to budget preparation. Again, it was discovered that every financial year, the OARG prepares budget which is always funded by government of Sierra Leone through the Ministry of Finance. To better understand this, the table below describe the amount approve d by government and how much were allocated in respect of various fiscal years. Financial Year Approved by Government (NLe 000) Allocated/Disbursed (NLe 000) Unallocated Variance (NLe 000) 2020 3,122 2,911 211 2021 4,045.1 1,820.2 2,224.9 2022 4,245.1 2,122.5 2,122.6 From the above table, it is clear that government has not allocate d or disburse d all the monies which were ap proved for the institution from 2020 to 2022 financial years. Alas, in 2021 financial year, Government allocation was not even 50% of what was initially approved and in 2022, similar pattern continued. These depressing financial

22. 21 with the work of the former HR Officer. Notwithstanding, Since the Senior Human Resource Officer present took up Office they said issues has been addressed, during the review process the team from ACC were given samples of IPAS for both Junior and Senior Staff for review. For ease of reference kindly find samples of IPAS. 6.2.2 Area of Focus: Personnel File s These contain significant history and records of employees by the HR unit of an institution. This records or history includes but not limited to ; qualifications, transfer letter, promotion, Identification card, medical report, NASSIT number, disciplinary actions etc. Finding During the review exercise, the team observed that some of the personnel files were not updated because of the unavailability of several significant documents. Among the se documents missing in the personnel files such as; employees NASSIT number, ev i dence of educational qualification, medical report, staff appraisal, transfer letter, confirmation letter etc. Implication Incomplete or un – updated personnel file s extremely indicated poor records keeping of employees’ information and clearly exhibit weak nature of the HR unit of OARG for the period under review. Recommendation It was recommended by the team that, the HR unit of OARG should work assiduously to updates all personnel file by taking into

44. 43 E nsure that the Finance Department should develop comprehensive asset register and t he Internal Auditor should be responsible for the verification of the assets register at a frequent interval . Management Response Management noted the team comment and reiterate that, the asset register has been reviewed and updated with the assets bought in the period under review taken into consideration and it is available in the account’s unit for ease of referencing. 6.5 Transversal Findings, I mplic ations and Recommendations with in the Professional Wing s of the OARG Good records and information management enable institution to keep and retrieve document when requested, facilitate informed decision - making process, track performance , and examine service delivery. These are general findings, implications and recommendations that cut across various unit s in the institution. These units include ; marriage, business registration, estate, conveyance and intellectual properties. Therefore, below are detailed discoveries of the review process in respect of the various units highlighted. 6.5.1 Area of Focus: File Numbering This is the process of name sorting and provide brief descriptions of files in chronological order to inform decision making process and enhance improvement in records management. Finding The team discovered that all the unit uses the number from the receiving way - book on a first come first serve basis as file referencing

81. 80 23 Management should ensure that all the institution’s assets are coded to avoid misuse T hat the Finance Department should develop comprehensive asset register and the Internal Auditor should be responsible for the verification of the assets register at a frequent interval % of coded assets The team was not provided with a Fixed Asset Register and the team realized that most of the institution’s assets procured over the years in Freetown (Headquarter) were not coded. 100% coded assets Inspect sample of assets. Director of Finance and Records 24 It is recommended by the review team that, the management of the OARG should provide enough space and which will encourage the increment of cabinets for safe keeping of records. Provide storage facilities the team learnt that there was inadequate office space and cabinets to keep records of files Approved storage facility provided Verify storage facility Records Manager 25 The team recommends that management of OARG should adapt records digitalization process to boost efficiency, easy retrieval, increase security etc. Digitalize the records management system During the review process, the team realized that there was no automated digital records management system to reduce the manual work of handling records or files Digitalize records management systems implemented Verify digital records systems Records Manager

8. 7 Personnel File s Personnel files not updated. It was recommended by the team that, the HR unit of OARG should work assiduously to updates all personnel file by taking into consideration the missing documents to enhancing a comprehensive and accurate records keeping of employees. Staff Without NaSSIT number Some staff are without NaSSIT numbers. We recommend that the HR unit of OARG should ensure that these staff have their NASSIT number and facilitate the enrollment in to the contribution scheme. Physical Verification of Staff Some staff did not show up for physical verification In collaboration with the Human Resources Management Office (HRMO) and Accountant General’s Office, the management of OARG should ensure that these staff who failed to attend physical verification should be unlisted from government payroll effective immedi ately. PROCUREMENT Procurement Plan No procurement plan and Procurement Officer . Following this risky administrative practice for the periods (2019 and 2020), is recommended by the team that going forward, the procurement officer in collaboration with unit heads should develop procurement plan in line with the annual work plan of the i nstitution. Also, the head of the institution should ensure that, the procurement officer is functional at regular basis to help the institution meet its operational requirements needed as support to achieve overall goal and objectives. Procurement Activity outside the work plan No procurement plan for 2019/2020 We recommend as follows; • Going forward the approved procurement plan should be followed accordingly by the procurement officer. • In a situation where an important procurement activity should be undertaken to boost operations and office environment of the institution but the activity is not included in the approved work plan, the procurement unit should develop a supplementary plan and seek approval by the procurement committee before im plementation for the culmination of best practice.

74. 73 6. We recommend that the internal auditor should produce an annual audit report in order, to track weaknesses and proffered recommendations for an improved service delivery Annual I nternal A udit report. The review team was provided with neither a soft nor hard copy of the 2021 annual internal audit report. In addendum, the 2019 and 2020 annual reports presented by the internal auditor were not exhaustive and detailed. Approved annual internal audit report produced for 2022 and 2023 Examine the Annual internal audit report. For 2022 and 2023 Senior Internal Auditor 7. The team recommends that the management of the OARG should establish a functional audit committee to strengthen the internal controls system for an improve service delivery An Audit Committee The review team discovered that there was no established and functional audit committee An Audit Committee established Examine the correspondence that established the audit committee. Registrar General 8. The team recommends that the management of the OARG should establish a functional audit committee to strengthen the internal controls system for an improved service delivery A functional Audit Committee. The review team discovered that there was no established and functional audit committee The Audit Committee is functional. Examine quarterly minutes of Audit Committee meetings. Registrar General

77. 76 13 We recommend that the HR unit of OARG should ensure that this staff has their NASSIT number and facilitate enrollment into the contribution scheme. . % of OARG staff with NASSIT registered with NASSIT. the review team discovered that there were five (5) full - time staff without NASSIT numbers either they deliberately failed to submit it to the HR officer or do not have it at all. These staff comprised of various categories working in the institution with details below. 100% of OARG staff enrolled with NaSSIT Verify sample of staff Human Resource Manager PROCUREMENT UNIT Recommendations Indicator Baseline situation/ Challenges ACC’S Target Means of Verification (MOVs) Current Progress Measure Responsible Department/ O fficer 13 Following this risky administrative practice for the periods (2019 and 2020), is recommended by the team that going forward, the procurement officer in collaboration with unit heads should develop a procurement plan in line with the annual work plan of the institution Procurement Officer There was no procurement officer and plan for the period 2019 - 2020 Procurement Officer Recruited Verify the Recruitment Letter of the Procurement Officer. Verify the Procurement officer Registrar General

85. 84 33 the review team recommends that the OARG works with the relevant authorities to institute a well - protected whistle blowing mechanism to help in the discharge of their duties. Institute a protected whistle blowing mechanism The review team was informed by the ARG that there is no whistle blowing mechanism at the OARG but that the ARG has put in place several mechanisms to forestall any of the corruption risks as highlighted above Effective whistle blowing mechanism. REGIONAL Recommendations Indicator Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/ Officer 34 It recommended that the OARG put in place all necessary mechanisms to empower regional offices to start conducting marriages (both Christian and Muslim). % of regional offices empowered to conduct marriage and issue certificate . The review team discovered that the OARG offices in the regions do not conduct marriages (both Christian and Muslim) even if members of the public request same because they lack the required capacity to do so. However, the office does register marriages and issue certific ates to people who want to register their marriages. 100% regional offices empowere d to conduct marriage and issue certificate . Physical Verification of regional offices empowered

75. 74 9. The team recommends that, in collaboration with the Human Resource Management Office (HRMO) and Ministry of Finance, the management of OARG should request for one additional internal auditor to boost the strength of the unit for effective and efficient int ernal auditing. # of additional internal audit staff recruited. Our review discovered that the I nternal A udit U nit of the OARG is grossly understaffed with only one staff who happens to be the Senior internal auditor. Therefore, considering the volume of work in the institution, we learned that the senior internal auditor alone cannot effectively and efficiently un dertake all audit functions. One additional internal audit staff has been recruited. Verify the one additional staff. Inspect the recruitment letter of the additional internal Audit staff recruited. Registrar General 10 . The team recommended that going forward, the internal audit Unit of OARG should maintain appropriate records management systems and avoid laying official documents on the ground floor. Filed and shelved working papers The team discovered that the internal audit Unit of the OARG does not maintain accurate records of documents for subsequent use Working papers properly filed and shelved. Inspect working paper files and shelves/cabinets. Registrar General

83. 82 28 the team recommended that the leadership, in collaboration with heads of unit of the institution should develop and adopt systems for the physical movement of files either, through file movement form/slip or a way - book sign by both the sender and recipient staff to track every detail of files and avoid the risk of misplacing them Developed a file movement system Adopt a mechanism for physical movement of files The team discover that there was no mechanism in place to track files from one point to the other during the process of verification An Approved and functional file movement system Established mechanism for physical movement of files Verify the file movement system Records Manager 29 It is recommending that a policy must be developed on how files should be moved to the archives. Develop policy on files movement and archives The review team discovered that there is no procedure to move files from HQ to the archives at Waterloo Street. Approved policy on file movement and archives Verify the file movement system 30 Files must be stored systematically and in chronological order % of files store systematically in chronological order The team discovered that there are irregular filing system/poor filing system 100% of files store in chronological order Physical verification of files in store.

86. 85 34 We recommend that management should ensure that all the assets in the regions are coded with an indelible ink to avoid misuse and to distinguish them from private assets % of regional offices with coded assets. The team was provided with a Fixed Asset Register but realized that majority of the assets in Makeni office were procured over the years in Freetown (Headquarter). Coding was done with a delible ink creating possible risk for diversion to private use 100% of regional offices with coded assets. Physical Verification of regional offices Assets. Registrar General 35 The team recommends that management of the OARG should investigate this abandonment of duty station by the staff, take necessary actions to affect discipline within the Human Resources (HR) landscape of the Institution. # of abandon staff discipline by management The ACC review team discovered particular staff who was transferred to Makeni office has abandoned his duty station All abandon staff discipline Physical Verification of disciplinary report Regional Managers 35 It is recommended by the team that, OARG in collaboration with the Human Resources Management Office (HRMO) and Accountant General’s Department (AGD), should facilitate the process of ensuring that an Accountant is deployed to the regional office in Makeni who will lead and advice on financial operations in the region. % of regional offices with Accountant. The team found out that the OARG office in Makeni does not have an Accountant to enhance revenue collection, systematic financial record keeping and track expenses in the region 100% of regional offices with Accountan t. Physical verification of Accountant deployed in regional offices. Human Resource Manager

73. 72 3. The Internal Audit Unit must physically verify all procurement deliverables.; % of procurement deliverables Verified by Internal Audit. The Internal Audit does not conduct physical verifications of deliverables; such as supply of procurement items and distributions, fuel allocation, etc. to ensure that the right specifications are delivered on time 100 % of deliverables verified. Examine a sample of delivery notes for 2022 to 2024 to confirm Internal Audit Verification. Senior Internal Auditor 4. Internal Audit to produce a quarterly report on the same on deliverables verified. Quarterly deliverables verification report The Internal Audit does not conduct physical verifications of deliverables; such as supply of procurement items and distributions, fuel allocation, etc. to ensure that the right specifications are delivered on time Quarterly deliverables verification report produced. Examine a sample of the Quarterly deliverable’s verification report. Senior Internal Auditor 5. The Internal Audit Unit should develop a standardized framework and check list which will enable physical verifications of deliverables and/or consumables. Deliverables Varication tool The review also discovered that, there were no standards and framework developed for performing and promoting internal auditing in respect of verifications of deliverables related to procured items Approved deliverables Varication tool Examine the deliverables Varication tool Senior Internal Auditor

76. 75 HUMAN RESOURCES. Recommendations Indicator Baseline situation/ Challenges ACC’S Target Means of V erification (MOVs) Current Progress Measure Responsible Department/ O fficer 11 The team recommended that going forward the HR unit of OARG should conduct mid - term and annual staff performance appraisal to ensure systematic evaluation of employees, ascertain staff strength and measure expectations. % of staff appraised annually. The team observed that the HR unit of OARG does not undertake staff performance appraisal as an evaluation process to document how well the employees are carrying out their job functions. 100% of staff appraised annually Examine annual staff appraisals for 2022 and 2023. Human Resource Manager 12 It was recommended by the team that, the HR unit of OARG should work assiduously to update all personnel files by taking into consideration the missing documents to enhance a comprehensive and accurate records keeping of employees. % of personnel with updated files. During the review exercise, the team observed that some of the personnel files were not updated because of the unavailability of several significant documents. Among these documents missing in the personnel files such as; employees NASSIT number, evidence of educational qualification, medical report, staff appraisal, transfer letter, confirmation letter etc. 100% of personnel files updated. Examine sample of personnel files. Human Resource Manager

79. 78 FINANCIAL MANAGEMENT Recommendations Indicator Baseline situation/ Challenges ACC’S Target Means of Verification (MOVs) Current Progress Measure Responsible Department/ O fficer 18 It is recommended by the review team that, going forward management should ensure participatory budget preparation for appropriate allocation of resources, manage cash flow more efficiently, monitor performance and progress of the I nstitution % of Unit heads participate in the preparation of budget for 2022, 2023 and 2024 The team discovered that budget preparation is not participatory within the institution for the period under review 100% of Unit heads participated in the preparation of budget Obtain and sample of departmental budgets to the budgets to 2022, 2023 and 2024. Director of Finance 19 Our review discovered that revenue reconciliation by both NRA and OARG were not available for 2019 & 2020 fiscal year Monthly revenue reconciliation between 2019 and 2020. It is therefore recommended by the team that data on revenue generation should be recorded and file accordingly to enable easy accounting and reporting . Monthly revenue reconciliation between NRA and OARG for 2019 and 2020 done Verify Monthly revenue reconciliation between NRA and OARG for 2019 and 2020 done reconciliation Report. Director of Finance

82. 81 26 In collaboration with the Human Resource Management Office (HRMO), the management of OARG should ensure that staff who had resigned or died are replace in order, to improve on the efficiency and effectiveness of service delivery. # of additional staff recruited and replaced It was observed that most of the units in the institution are understaffed to carry out their activities. Also discovered that many staff had either resigned or died without replacement and that hamper work progress within the institution. 100% of vacant position filled Verify list of vacant position filled Records Management 27 That each unit developed records classification schemes that are simple and logical, enables categories to be easily differentiated from each other, which will be presented to senior management for endorsement Management of OARG should ensure that each unit practice classification of records and files thereby simplifying the process of retrieval, save time and efforts. # of units developed records classification schemes that are simple and logical # of units practice classification of records and files retrieval processes The team discovered that all units maintain ledger book as a paper – based record keeping system to record information about clients/applicants but even so, information are not separated in the ledger book making it difficult to group them into various cat egories of each unit. And documents were not serially and categorically stored per unit All Units All Units Physical Verification of units records classification scheme Examination and Verification of units classification Practices Records Manager

7. 6 The following table/matrix contains the key findings and recommendations. Office of the Administrator and Registrar General INTERNAL AUDIT FINDINGS RECOMMENDATIONS N o annual work plans were presented to the team for 2019, 2020 and 2021. It is recommended by the team that, the Senior Internal Auditor (SIA) should prepare audit plan on a yearly basis, approved by the audit committee for operationalization in a bid to ensure due diligence and compliance mechanisms needed to improve on service delivery. Physical Verification of Supplies The Internal Audit does not conduct physical verifications of deliverables . Following the review exercise, the team recommends as follows that; • The Internal Audit Unit should develop a standardized framework and check list which will enable physical verifications of deliverables and/or consumables. • The Internal Audit Unit must physically verify all deliverables from initiation to completion; produce a quarterly report on same for sound economic, efficient, and effective management of public funds. Audit Report No internal audit report for 2021 We recommend that, the internal auditor should produce an annual audit report in order, to track weaknesses and proffered recommendations for an improved service delivery. Audit Committee There was no established and functional audit committee in the OARG. The team recommends that management of the OARG should establish a functional audit committee to strengthen internal controls system for an improve service delivery. Poor Records Management The internal audit Unit of the OARG does not maintain accurate records of documents for subsequent use. The team recommended that going forward, the internal audit Unit of OARG should maintain appropriate records management systems and avoid laying official documents on the ground floor. HUMAN RESOURCES Staff Performance Appraisal No performance appraisals done The T eam recommended that going forward the HR unit of OARG should conduct mid - term and annual staff performance appraisal to ensure systematic evaluation of employees, ascertain staff strength and measure expectations.

23. 22 consideration the missing documents to enhancing a comprehensive and accurate records keeping of employees . Management Response Files have been updated 6.2.3 Area of Focus: Staff Without NASSIT Number Finding After careful examination of the compre hensi ve staff list of OARG, the review team discovered that there were five (5) full - time staff without NASSIT number either they deliberately failed to submit it to the HR officer or do not have it at all . These staff comprised of various categories working in the institution with details below. Table 1: Shows Staff Working at OARG without NASSIT Number No Names of Staff Gender Designation Pin Code 1 Umar I. Koroma M Senior Records Assistant 128180 2 Abu Dumbuya M Office Assistant 175337 3 Thomas Macarthy M Office Assistant 104292 4 Simeon L D. Thomas M Estate Office 175331 5 Abdul Rahman Mahdi M State Counsel Registrar 131530 Implication These staff without NASSIT number will not benefit from monthly payment of NASSIT contribution and this will automatically affect pension calculation and, at the same time, impede the provi sion of

87. 86 36 The team recommended that going forward; management of the OARG should maintain appropriate records management systems in the region (Makeni) and avoid laying official documents on the floor. Established regional records management system. The team discovered that the OARG O ffice in Makeni does not maintain accurate records of documents for subsequent use. At the time of our visitation, there were inadequate office cabinets to keep files and as a result, some documents were laid on the bare floor. Please see photo below. Approved records managem ent systems. Verify Records systems Regional Manager 37 The team recommends that, the OARG in collaboration with Human Resource Management Office (HRMO), should request for additional staff in Port Loko to boost staff strength in the region for effective and efficient service delivery. # of staffs recruited in P ort L oko R egional O ffice The review revealed that, the OARG office in Port Loko is grossly understaffed with only two staff. Therefore, considering the volume of work in the region, we learnt that two staff cannot effectively and efficiently undertake all the functions. Additional staff recruited at the Port Loko Office Verify staff recruited Human Resource Manager 38 The team recommended that going forward, management of the OARG should maintain appropriate records keeping systems in the region (Port Loko) by ensuring that all files are label accordingly. Established regional records management system in P ort L oko. The team discovered that the OARG office in Port Loko does not label records or documents to enable easy identification and retrieval process for subsequent use. Approved records managem ent systems. Verify records systems Regional Managers

78. 77 14 Following this risky administrative practice for the periods (2019 and 2020), is recommended by the team that going forward, the procurement officer in collaboration with unit heads should develop a procurement plan in line with the annual work plan of the I nstitution Annual Procurement Plan for 2022 ,2023 and 2024 There was no procurement officer and plan for the period 2019 - 2020 Approved Annual Procurement Plan for 2022 ,2023 and 2024 Examine the Annual Procurement Plan for 2022 ,2023 and 2024 Procurement Officer 15 T he approved procurement plan should be followed accordingly by the procurement officer % of planned procurement Procurement Plan not followed by management 100 % of planned procurement Verify procurement against the procurement plan. Procurement Officer 16 P rocurement unit should develop a supplementary plan and seek approval by the procurement committee before implementation Approved supplementary procurement plan procurement unit should develop a supplementary plan and seek approval by the procurement committee before implementation supplementary procurement plan developed and approved Verify approved supplementary budgets for a sample of supplementary procurements. Procurement Officer 17 That the I nstitution’s procurement unit should maintain an appropriate filing system where documents should be chronologically kept and easily retrievable for subsequent uses. Filed and shelved Procurement Documents The team discovered that there was a poor filing system of the procurement unit to keep track of official documents. Procurement Documents properly filed and shelved. Inspect Procurement Documents files and shelves/cabinets. Procurement Officer

84. 83 TRADEMARK AND INTELLECTUAL PROPERTY Recommendations Indicator Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/ Officer 31 The team recommends that the IP Unit should develop annual work plan to catalogue its planned activities / o bjectives which should be aligned to the I nstitutions S trategic P lan. Developed annual work plan The review team discovered that there was no workplan for the IP unit for the period under review (2019, 2020 and 2021). Approved Annual work plan Physical verification of Annual Work Plan Trademark and Intellectual Property STANDARD OPERATING PROCEDURES (SOP) Recommendations Indicator Baseline situation/ Challenges ACC’S Target Means of V erification (MOVs) Current Progress Measure Responsible Department/ Officer 32 The review team therefore recommends that the AORG work within the provisions of the Acts to develop the necessary SOPs to guide its day - to - day activities. Develop Standard Operating Procedures to guide the day today activities The review team was informed that the institution does not have SOPs but rather depends on the various Acts that speak to the various activities of the institution. Additionally, the review team was also informed that since all documents that are dealt wit h by the OARG are statutory instruments and therefore there is no need for the use of SOPs. Approved SOP Verify Approved SOP

41. 40 Findings Our review discovered that revenue reconciliation by both NRA and OARG were not available for 2019 & 2020 fiscal year. This was because, the team did not receive any document from neither NRA nor OARG staff in support of the claim. On the contrary, the tea m realized that revenue reconciliation was only available for 2021 fiscal year. Therefore, the table below depicts revenue reconciliation between NRA and OARG for the 2021 financial period. Table: Revenue Generation Reconciliation for 2021 Financial Year. Months MDA Cash Book (Le) NRA (Le) Variance (Le NRA - MDA Cashbook) January 714,789,000.00 717,807,000.00 3,018,000.00 February 532,860,100.00 535,642,700.00 2,782,600.00 March 502,933,000.00 504,492,300.00 1,559,300.00 April 355,349,000.00 357,438,500.00 2,089,500.00 May 317,161,325.00 318,715,500.00 1,554,175.00 June 281,917,500.00 284,805,000.00 2,887,500.00 July 240,108,000.00 245,649,650.00 5,541,650.00 August 265,583,000.00 261,099,400.00 - 4,483,600.00 September 308,227,000.00 309,960,000.00 1,733,000.00 October 314,199,500.00 317,225,500.00 3,026,000.00 November 334,974,000.00 340,180,700.00 5,206,700.00 December 311,694,000.00 401,846,550.00 90,152,550.00 TOTAL 4,479,795,425.00 4,594,862,800.00 115,067,375.00 From the table above, it is indicated that revenue generated by NRA surpasses OARG cashbook record. A discussion with Finance/Account Officer of the OARG revealed that, NRA have other

80. 79 20 It is recommended by the team that the Ministry of Finance should regularly meet its financial obligations to OARG in order, to foster effective and efficient implementations of activities to enhance the achievement of results and progress. % of approved budget of OARG funded by ministry of finance It was discovering that approved budget of the institution is not fully funded over the period under review 100% of Approved Budget funded by the M inistry of F inance . Verify budget approval and funding Director of Finance 21 We recommend that the management of OARG should establish a petty cash system. Established petty system The review process, the team discovered that, the finance or account unit of OARG does not maintain petty cash Approved petty cash system in the finance unit Examine established system RECORDS MANAGEMENT Recommendations Indicator Baseline situation/ Challenges ACC’S Target Means of verification (MOVs) Current Progress Measure Responsible Department/ Officer 22 Management should ensure that all the I nstitution’s assets are coded to avoid misuse T hat the Finance Department should develop comprehensive asset register and the Internal Auditor should be responsible for the verification of the assets register at a frequent interval Up to date Fix Asset Register. The team was not provided with a Fixed Asset Register and the team realized that most of the institution’s assets procured over the years in Freetown (Headquarter) were not coded. Up to date Fix Asset Register developed. Approved Asset register 100% of Asset registered verified Examine the fixed asset register. Records Manager /Director of Finance

72. 71 Description of Progress No Compliance Moderate Compliance Significant Compliance Full Compliance Score Range (0% - 49%) (50% - 79%) (80% - 89%) (90 - 100% ) Color Code Area of Focus INTERNAL AUDIT Anti - Corruption Objectives Institute T ransparency and A ccountability P rinciples in the M anagement of P ublic F unds Recommendations Indicator Baseline S ituation/ Challenges ACC T arget Means of verification (MOVs) Current Progress Measure Responsible Department/ Officer 1 The Senior Internal Auditor (SIA) should prepare audit plan on a yearly basis. Annual Internal Audit Plans. No annual work plan was presented by the Internal Auditor to the team for 2019, 2020, and 2021. Annual Internal Audit Plan developed. Examine the Annual Internal Audit plans for 222, 2023 and 2024. Senior Internal Auditor 2. Annual Internal Audit plan to be approved by the audit committee for operationalization. Internal Audit plan approved by the Audit committee. No annual work plan was presented by the Internal Auditor to the team for 2019, 2020, and 20 Approved Internal audit plan. Verification of approved audit plan for 2022 and 2023 and 2024. Senior Internal Auditor

4. 3 LIST OF ABBREVIATIONS ACC - Anti - Corruption Commission ARG - Administrator and Registrar General BR - Business Registration CA - Change of business Address CCTV - Close Ci rcuit Television Etc - Et Cetera GBBA - Government Budget and Accounting Act 2005 HQ - Head Quarter HR - Human Resources HRMO - Human Resource Management Organization ID - Identification IIA - International Internal Audit IP - Intellectual Property MDA’s - Ministries, Departments and Agencies NaSSIT - National Social Security and Insurance Trust NPPA - National Public Procurement Authority NRA - National Revenue Authority OARG - Office of the Administrator and Registrar General OSIWA - Open Society Initiative for West Afr ica RFQ - Request for Quotation SIA - Senior Internal Auditor SOP - Standard Operating Procedure

25. 24 Table 2: Shows Staff Who Were Not Seen f or V erification No Names of Staff Gender Designation Pin Code 1 Muminatu Jalloh F Senior Records Assistant 128 217 2 Umar I. Koroma M Senior Records Assistant 128180 3 Unisa M. Kamara M Records Assistant Level 1 10 1652 4 Samuel E. Koroma M Office Assistant Level 1 127812 5 Abdul Rahman Mahdi M State Counsel Registrar 131530 6 Ibrahim Sheriff M Office Assistant Level 2 131180 7 Samuel T. Koroma M Office Assistant Level 2 175343 8 Salamatu L E. Turay F Registration Officer 128596 9 Fatmata Mustapha F Registration Officer 132133 10 Simeon L D. Thomas M Estate Officer 175331 11 Margret Sumana F State Counsel Registrar 131532 12 Daniel E. Johnson M State Counsel Registrar 365674 Implication These staff who were not present for the prolong verification exercise, were considered ghost employees and it is therefore, waste of public fund to pay employees who are not active o n service delivery. Recommendation In collaboration with the Human Resources Management Office (HRMO) and Accountant General’s Office, the management of OARG should ensure that these staff who failed to attend physical verification should be unlisted from government payroll effective immediately. Management Response Worthy of note is that the Office of the Administrator and Registrar General doesn’t have ghost Staff as the team from ACC duly cross

3. 2 6.4.4 Area of Focus: Revenue Generation Reconciliation ................. 39 6.4.5 Area of focus: Asset Register and Coding ................................ 42 6.5 Transversal Findings, Implications and Recommendations within the Professional Wings of the OARG ... ... ... ... ........................... .... 43 6.5.1 Area of Focus: File Numbering ................................ ................ 43 6.5.2 Area of Focus: Office Space and Cabinets ............................... 45 6.5.3 Area of Focus: Records Digitalization ................................ ...... 46 6.5.4 Area of Focus: Shortage of Staff ................................ .............. 46 6.5.5 Area of Focus: Classification/Separation of Records ................ 47 6.5.6 Area of Focus: Physical Movement of Documents ................... 51 6.6. ARCHIVE ................................ ................................ .................. 53 6.7 TRADEMARK AND INTELLECTUAL PROPERTY ................... 54 6.7.1 Area of focus: Standard Operating Procedures (SOPs) ............ 56 6.7.2 Area of focus: Whistle blowing ................................ ................. 58 6.8 OFFICE OF THE ADMINISTRATOR AND REGISTRAR GENERAL O.A.R.G REGIONAL REPORT ................................ . 59 6.8.1 Bombali District (Makeni) ................................ ......................... 60 6.8.2 Area of focus: Marriages: ................................ ......................... 60 6.8.3 Area of Focus : Asset Register And Coding ............................ 61 6.8.4 Area of Focus: Staff Punctuality ................................ ............. 62 6.8.5 Area of focus: Accountant ................................ ........................ 63 6.8.6 Area of Focus: RECORDS MANAGEMENT ............................ 64 6.9 PORT LOKO DISTRICT (PORT LOKO TOWN) ......................... 65 6.9.1 Area of Fucus: STAFF STRENGTH ................................ ......... 65 6.9.2 Area of Focus: Records Keeping ................................ ............. 66 6.9.3 Area of Focus: Revenue Collection ................................ .......... 66 6.9.4 Area of focus: Financial Management and Related Issues ....... 67 7.0 CONCLUSION ...............................................................69

2. 1 TABLE OF CONTENTS LIST OF ABBREVIATIONS ................................ ................................ .... 3 EXECUTIVE SUMMARY ................................ ................................ ....... 5 1.0 BACKGROUND AND INTRODUCTION ................................ ........ 9 2.0 OBJECTIVE ................................ ................................ ................. 11 3.0 SCOPE ................................ ................................ ........................ 11 4.0 METHODOLOGY ................................ ................................ ........ 11 5.0 LIMITATIONS OF THE REVIEW ................................ ................. 12 6.0 FINDINGS, IMPLICATIONS AND RECOMMENDATIONS 12 6.1 Internal Audit ................................ ................................ ............ 12 6.1.1 Area of Focus: Internal Audit Plan ................................ ........... 13 6.1.2 Area of Focus: Physical Verification of Supplies ...................... 14 6.1.3 Area of focus: Audit Reports ................................ ..................... 16 6.1.4 Area of Focus: Audit Committee ................................ ............... 17 6.1.5 Area of Focus: Understaffing ................................ .................... 18 6.1.6 Area of Focus: Poor Records Management .............................. 18 6.2 Human Resources Unit ................................ ............................... 19 6.2.1 Area of Focus: Staff Performance Appraisal ............................. 20 6.2.2 Area of Focus: Personnel Files ................................ ................. 21 6.2.3 Area of Focus: Staff Without NASSIT Number ........................ 22 6.2.4 Area of Focus: Physical Verification of Staff ............................. 23 Table 2: Shows Staff Who Were Not Seen For Verification ............... 24 6.3 Procurement Unit ................................ ................................ ........ 25 6.3.1 Area of Focus: Procurement Plan ................................ ............. 26 6.3.3 Area of Focus: Procurement Activity outside the Work Plan ..... 29 6.3.4 Area of Focus: Poor filing system ................................ ............. 32 6.4 Finance Unit ................................ ................................ ................ 34 6.4.1 Area of Focus: Petty cash ................................ ........................ 34 6.4.2 Area of Focus: Budget Funding ................................ ................ 36 6.4.3 Area of Focus: Budget Preparation ................................ .......... 38