A Member of the Heads of Internal Audit Forum

Strengthening Civil Service Accountability and Performance
1.
2.
2.1
3.
4.
5.
6.
Internal Audit ................................................................................................................................ 2
Accountability in the Civil Service. .............................................................................................. 2
Background to the current problems on Accountability ....................................................... 3
Comparison of organisation and individual performance drivers................................................. 5
Accountability Proposals - A ........................................................................................................ 8
Accountability proposals - B ...................................................................................................... 11
Conclusion .................................................................................................................................. 14
This document is the response from the Heads of Internal Audit to the proposals outlined in
the Accountability document. In reviewing the document we have considered accountability
in the private and public sector and provided some practical suggestions accepting that
there are limitations given the current economic circumstances. The proposals are
commented upon in tabular form. An excellent document was produced by the Institute for
Public Policy Research (IPPR) in the UK “ Accountability and Responsiveness in the Senior
Civil Service” and it summarises actions taken to address the key issues in other
countries.
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1. Internal Audit
Strong Governance is one of the corner stones of an effective organisation. A key element of this is
having an effective Internal Audit function in place with an equally effective and independent Audit
Committee. The Mullarkey Report sought that all departments put such processes in place and they
have essentially been in place since 2004. The focus initially has been on internal financial controls
but in more recent times, Risk Management and Governance is also being considered by Internal
Audit Units. Internal Audit Units through their work hold the organisation and managers to account.
They seek that good management practises and strong financial controls are embedded in
Departments. They call to account managers where processes and procedures are considered weak
and seek that they address they issues. Essentially Internal Audit is a key accountability function in
all departments, one that can provide constructive challenge and improve delivery.
Internal Audit delivers a very practical and useful service and the Heads of Internal Audit across
government departments are keen to ensure that their role in ensuring open and effective
accountability is noted and strengthened going forward.
2. Accountability in the Civil Service.
As the Accountability paper indicates there are varied definitions of accountability that can be
applied to the Civil Service. These can include accounting, ethical, political, personal/organizational,
democratic
and developmental accountabilities. Accountability applies to everybody, be they
Ministers, Civil Servants or indeed Citizens of the State.
Regrettably in recent times there have been failures of accountability in both the Private and Public
Sectors but also in the world of Irish politics. Professor Niamh Brennan puts it quite well when she
says that most of the risks that organizations or indeed countries face are managed by a small
number of very senior people. This applies to both the private and public service. This clearly
indicates you need to address the problems with the few as opposed to looking at the issues with the
many. The problems have occurred because certain actions were taken but also because other
preventative/policy decisions were not.
“It is not only what we do, but also what we do not do, for which we are accountable."
Moliere.
Some of the inaction by senior Civil Servants was as a result of their roles being too politicised,
relationships too close and lack of a culture of constructive challenge. There was and still is an
implicit view that senior Civil Servants should not question Government policy even if this is done
behind closed doors. The ability to question such polices should be open to Secretary Generals and
indeed Assistant Secretaries/CEO’s.
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2.1
Background to the current problems on Accountability
a. Private Sector
The banking crisis has demonstrated a clear lack of governance and accountability in certain parts of
the private sector. These supposed pillars of the commercial world demonstrated poor governance
and leadership capability in managing their organizations. They were certainly not exemplary
models of “accountability” even if in theory they had strong practices in place. Companies in the
private sector (especially publically quoted companies) can have a short view of the business driven
by a need to meet shareholder expectations for dividend and share price growth. This differs greatly
from Japanese and German companies that seek to build long term high quality organizations to
meet the current and future needs. Ie building capability is equally important as building
profitability. There has been a focus on short term profiteering by Boards and Senior Executives and
in some cases this has been contributed to by ineffective governance practices and their application
(Irish Nationwide, AIB, Quinn group, Bloxham brokers etc).
Civil Service organizations are long term structures and survive for hundreds of years unlike many
of the organizations in the private sector. The ability to manage and sustain large organizations over
such time frames is made more difficult where the inherent drivers of accountability (profit in the
private sector) are absent. The key strength that private companies have is the use of boards and
these are a key foundation of good governance and accountability. They do not guarantee an
effective organisation, they do (where effective) hold people to account.
b. Civil Service
Although there have been many reforms over the years, there is certainly scope to improve
accountability further in the Civil Service. Examples of failure would certainly point to banking
regulation, the housing market and some aspects of the health services etc. The questions that
need to be answered are whether these failures arise because of
(a) Poor accountability by senior civil servants
(b) A political process that encourages short term local politics and some ineffective government
practices (including weak committees).
(c) Civil Service bureaucratic processes including policy development
(d) Poor leadership/accountability by Ministers in their department leading to ineffective long term
policies.
(e) Silo management of cross department problems where no lead is taken to address the problem.
(f) A focus on outputs as opposed to outcomes
(g) Lack of capabilities at a senior level in the Civil Service
There is always a danger that good practices that have stood the test of time will be abandoned (
throw out the baby with the bath water) and that we implement radical reform for no other reason
than it satisfies the Media and Ministers appetite for short term reform (look at what I have
delivered syndrome). Any reform must be balanced to ensure that Civil Servants remain apolitical
and that changes bring about quality outcome for the citizens in the long term and also strengthen the
capacity and capability of the Civil Service. There is little point in having short term success if it
damages the long term outputs/outcomes and destroys the morale and future capability of the Civil
Service. The private sector are vocal in suggesting how the Public Sector can be reformed, often
they fail to see that they are the main contributors to virtual bankruptcy for the country. The failure
for the Civil Service is that the structures were not sufficiently strong or robust to defend against
poor policy direction by Government and indeed the commercial world. It should be about making
sure that the Civil Service has capable, intelligent managers, that have sufficient confidence in their
legal positions (tenure of office ) that they can constructively challenge without fear of being
sidelined or promotion being hampered. Ministers often fail to appreciate that many of the
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problems stem from their own short term political agendas and to some extent exaggerated election
manifestoes
Lord Gus O’Donnell (previous Cabinet Secretary in the UK) indicates that the current Government
in the UK is pushing further Civil Service reform as they misguidedly believe that the Civil Service
is trying to stimey the reform.
“No one could argue that this Government has been prevented [by the civil service] from pursuing
radical policies,” Lord O’Donnell said. “Just look at health, education and welfare. They are not
short of radical policies. The issue is whether they are the right policies. Have they been formulated
with good evidence and if, when they are implemented, will they improve peoples’ lives? “
c. Political process
The nature of Irish politics means it is partisan, locally based and short term in nature. While politics
may have 5 year windows and to some extent this drives a short term focus, it is essential that policy
development takes a more medium to long term approach in line with the lives of citizens. Ie Health
systems need to be capable of dealing with people across the age spectrum (0 years old to 80 years
old +). The current political process suffers from being
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Partisan politics in the Dáil and in the Committees
Senate has limited powers.
Lack of effective process in the Committees (weak policy critique and changing of policies,
debates guillotined).
Poor strategic policy development. Ie Tax breaks for property in a buoyant market
Silo management , Crime is a result of socio economic conditions and needs to be addressed
by Justice , Education, Health, Social Protection etc Departments
Not in my back yard politics, ie no pylons or incinerators here
Lack of transparency in government programme objectives and deliverables.
Political , ie reduce tax prior to an election, don’t deliver on election manifesto,
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3. Comparison of organisation and individual performance drivers
Private
Company
Public Company
Civil Service
(ie )Kerry group
(ie )Dunne’s Stores
Board &
Committees in
place to
provide
governance
and oversight
Usually no
external Board,
unless a very
large group.
Owner has final
say.
Yes, mixture of Executive
and experienced non
Executive Directors. Non
executives give
independence and may have
specialist knowledge of the
sector.
Number of Committees
made up of Board members
with access to external
advice
Effective Audit Committee
and Audit Unit to
implement good practice
Chair and Non Execs review
operational performance of
Exec’s annually so greater
focus on their performance
Business
goals/targets
External
scrutiny
Targets set by the Set by the senior Exec but
Owner
must be acceptable to the
Board. Board can change
these.
Banks ,
Regulators,
Media
Publish annual report with
details of financial and other
progress.
Subject to an annual general
meeting and scrutiny by
shareholders. (Controlled by
institutional investors) .
No external Board to
provide oversight or direct
the Sec Gen or Mac.
Minister does direct the
policy of the Department,
(however insular and silo
view of the Departments
function)
Audit Committees in most
organisations, not as strong
a focus as in private
industry
Little by way of
independent scrutiny on
normal business operations.
This scrutiny is provided by
the Secretary General &
Mac on themselves. This
would not be independent
review
Policy set by the
Government programme
and amended by the
individual Minister.
Amended by requirements
set by the EU or by
political expediency ie
Insolvency legislation,
Charitable Regulator
legislation etc
Minister is questioned in the
Dáil on policy areas. These
tend to be political issues
and can be batted away by a
Minister adept in his/her
area.
Estimates & different
legislation reviewed by
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Banks , Regulators, Media.
Subject to Combined Code
of governance and stock
exchange rules.
different Dáil Committees.
Questionable effectiveness
as little change to the
budget or policies proposed.
Appropriation Account
reviewed by Public
Accounts Committee
– no major sanction
Reporting/
Transparency
May need to
register accounts.
Answer media
questions
Annual report + mid year
results, tend to be financial.
Key Driver of
performance
Owner of the
business, usually
involved in
recruitment of
key staff and all
key business
decisions
Shareholders and Board
Control
CEO and other
senior executive
directors
Focus on
results
CEO and
Executives
motivated to
deliver results
Board has control.
Essentially institutional
investors control the board
Senior Executives control
day to day operations.
CEO and Executives
motivated to deliver results
by levels of pay and
performance system.
Owner directed
but maybe
devolved to a
CEO, Owner
always involved
CEO and Execs usually
selected by closed
competition
Strategies and targets
determined by the Board.
Strategy usually originates
from senior Exec but Board
can and do amend.
Business
strategy
Bank
Regulator
media has considerable
power to sway direction of
policy
Strategy Statement
published
Estimates and
Appropriation Account
published.
Less rigorous than annual
reporting by a Public
Company
Minister primarily. Policy
focus can be lead by issues
brought up by the PAC,
Troika, and Media.
Media can drive the agenda
by topical issues. Ie patients
on trolleys.
MAC has operational
control but little open and
transparent scrutiny.
Key focus on ensuring
Minister is protected and
Dáil
Minster has control of
overall function.
In reality operational
control by Secretary
General and MAC
Results driven by demands
of the
Minister/Government.
Little by way of systematic
review of delivery of
strategic goals and business
plans as these are not
effectively transparent
Strategy statements are the
most part unclear. While it
can be argued they guide
direction the overall
evidential policy to support
the strategy is weak.
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Changes
Changes made
quickly
Changes made reasonably
quickly , operationally by
senior Exec,
Implications
other
organisation
Competitors &
Customers
mainly
Shareholders , Competitors
& Customers Stock
exchange
Regulator
Accountability
focus
Stronger for all
senior managers.
Strong, however ,
institutional investors may
control the organisation and
in Europe less likely to sack
CEO
Failure to
deliver
Control of
resources
Removed,
usually with
good farewell
package.
Yes but directed
centrally
F Finance – Y
CEO usually removed.
Yes but directed centrally
Finance – Y
Staff – Y
Staff – Y
IT – Y
IT – Y
Changes can be made. The
policy direction can be
refocused by
Government/ministerial
direction.
Delivery changes can be
slow as they move through
legislative and bureaucratic
processes.(Dail , Senate etc)
Implications for
Departments
Other departments
EU
Regulator
Media
Citizens
Accountability is mainly at
Ministerial level.
There is some
accountability below but it
could be improved , ie
MAC, level
Accountability also to
Committees, this tends to be
politically motivated in
some cases
Limited sanction although
this could be improved by
publishing the names and
business plans of all senior
managers and the progress
delivering against it. The
danger is that the agenda is
driven by media and
political agendas which bear
no relationship to actual
performance.
Limited control as DPER in
reality controls this
function.
The corollary is also true ,
there is a certain equality
brought about by DPER
controlling these functions ,
ie everyone is told No
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4. Accountability Proposals - A
Proposed steps to
encourage
accountability
Selecting the best
candidate whether
internal/external
Heads of Internal Audit View
We would support the recruitment of selecting the best candidate
provided this is what the Civil Service gets. Certainly a mix of
internal and external staff provides an influx of new ideas and can
help change the status quo. Care needs to be taken as external
candidates are much better at spinning a good story yet may not
deliver a quality product.
Some research on the outputs and outcomes from selecting the
best candidate would provide evidence of the success of this
process. Anecdotal evidence suggests that external candidates
have unrealistic expectations of what they can deliver (given the
constraints on resources) and become frustrated. In a number of
recent cases they have left their roles and moved back to the
private sector. There is also the question of why some candidates
decide to move to the public service if they are so valuable in their
current roles. One would have to question the ability of TLAC
and PAS in effective recruitment, little or no exit interviews are
carried out and at best their results are no more than average.
In the French model there is a special training regime put in place
to recruit, educate and promote staff with the necessary
capabilities to deliver effective public services
Open up the top
reaches of Government
to management talent
from the private sector
Fixed terms contracts
In principle this is a good idea and it should be supported up to a
point as it will encourage some culture change and reform. The
monetary benefits to attract the “supposed go getters” of the
private sector would need to be significantly higher. They don’t
tend to be interested in the routine work of the Civil Service and
many perceive it doesn’t look good on their CV. In the private
sector organisation tend to have a mix of internally promoted
candidates with some external recruitment. In many cases staff are
promoted as opposed to being recruited. The success delivered by
external recruitment is questionable and needs to be evidence
based. Anecdotal evidence suggests that many jump from job to
job without remaining in place to see the results of their work
The French have built a core of high quality people to take over
senior roles, perhaps this is an option to look at
The notion of fixed term contracts originates from the private
sector. Publically quoted companies have tended to appoint CEO’s
etc for periods of time as opposed to indefinite duration. Recent
evidence would caution against adopting this model. The banking
model and indeed many publically quoted companies have been
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led astray by their short term focus. It may work better in the
private sector where they are given the resources to deliver on the
targets and there is less cross functional shared responsibility. The
other edge of this sword is that policy making is not short term and
should not be political; contracts focusing on the short term will
lead to short term solutions that do not ultimately fix long term
problems.
Unifies career
Agreed
structure
Top level Civil Service Creating another layer (senior Civil Service) may seem like a good
to oversee performance idea but there is little evidence that it has worked in the UK. It
gives a central focus to the Civil Service but giving the power to
manage the Secretaries General may well place too much power in
a single person and to some extent fails to address the problem of
performance across the entire Civil Service.
Creation of corporate
centre role in relation
to leadership ,
organisation and
assessment of
individual
performance of senior
management
A better solution is to have an Government Oversight Board put in
place (Fiscal Council + chair of the PAC, + Chair of the individual
Dáil Committee + 2 retired private sector CEO) to agree on the
strategy, business plan, smart goals , policies and monitor these.
70% : 30% public private mix. Consider the Public Sector Board
suggested by the Taoiseach in 2010. Must be non political
This in theory sounds good, a senior civil servant to oversee the
development of the civil service may give direction but it is
questionable based on current practices if there is a Department
that is capable of delivering on this. The focus at the moment and
for the foreseeable future is budget management and this is the key
driver for performance (sadly). This is really not a good idea,
another layer with little to show for it. A Corporate Board is a
more effective solution
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Statutory set of public
service values
No evidence that the centre has sought to build capabilities
into the broader Civil Service. Strategic Management
theories provide evidence that strong and performing
organisations have a great focus on building organisations
with capable leaders that have vision, technical and man
management skills, motivation and experience. Why would
one expect that to change?
 There is little evidence that it has been a resounding
success in the UK, Australia etc. These countries still have
civil service accountability reform agendas
 Politics will still get in the way for the most senior civil
servant as they are always mindful of their political
masters goals(even if they say they are not)
Agreed. The public values and codes are very important. One of
the perennial problems is that such codes are verbose and tend to
be written in long documents. A more user friendly medium would
encourage this to be read as opposed to being filed away (unread).
A living and breathing set of values as opposed to paper rhetoric
There is a danger of different signals being sent by values
espoused in the code of conduct and proposal to implement short
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term contracts. Care needs to be taken as short term contracts
(decided upon by the Government) can lead to a short term
approach.
Policy advice can be
brought in to assist the
Minister
This seems like a good idea. Ministers need policy advisers
(perhaps from academia) who can provide evidence based research
on policy. These could co ordinate with the policy developers in
the core departments. The danger always exists that academic
research may not always be practical nor politically acceptable.
Equally the advisers may go native and end up duplicating on
policy development.
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5. Accountability proposals - B
Proposal
Greater definition of the
relationship between
Civil Servants and
Ministers
Comment
This is a good idea,
although one must be
aware that the Minister has
the power to direct action
by a Civil Servant and
what Civil Servant will say
No. or indeed can say No
Sharper clarity and
differentiation between
the roles of the Minister
and Civil Servants
In principle this seems like
a good idea. We see
problems in separating the
political and short term
nature of politicians from
those of the Civil Servants
Stronger lines of
internal /managerial
accountability
It is important that the
progress or lack thereof is
fairly administered, is
transparent and is
reasonable. It must all be
published
The clear allocation of
roles and responsibilities
would assist in ensuring
greater responsibility. This
has been done to some
degree for CEO’s ie
Equality Authority etc.
A similar allocation of
roles and responsibilities
would assist in greater
accountability
Audit View
Yes, proceed but be practical about
how this is done. Other countries
have had problems doing this.
Assist as follows
Clarity of Accountability Y
Sufficiency of control Y
Clarity of consequences N
Sufficiency of information N
This only needs to be done for the
senior civil servants, Secretary
General, Assistant Secretary/CEO.
Publish information about role and
responsibility and delivery of key
players on website
Assist as follows
Clarity of Accountability Y
Sufficiency of control Y
Clarity of consequences N
Sufficiency of information N
Yes this would be positive if it is
practical. Secretary General,
Assistant Secretary/CEO grades
should have their business plans
and their roles and responsibilities
published annually. The
constraints and reasons for not
succeeding should also be
presented.
Should be called to attend PAC etc
5 year contract will encourage
short terms approach. Secretary
General should have a 10 year
contract but be capable of being
removed by the Government
Oversight Board.
Assist as follows
Clarity of Accountability Y
Sufficiency of control Y
Clarity of consequences N
Sufficiency of information N
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Greater focus on
governance
arrangements
Safeguard Public interest
This is one of the failures
in the private sector in
recent years. It is debatable
that effective governance
can be put in place unless
there is a strict set of
codes, they are enforced,
compliance is audited and
information published on
DPER website.
Publishing information is
one of the best ways to
ensure transparency and
encourage both
compliance and reform
Government Oversight Board
On a Civil Service basis there
should be a global board to review
departmental strategies, business
plans and senior Civil service
performance. This should include
a combination of public and
private representatives.
The ability to do this could
be brought about by
publishing information
about income and
expenditure in each entity
and how it benchmarks
against other similar
bodies in Ireland or the
UK.
Publish more information to
demonstrate if a body is spending
money efficiently and delivering
Putting formal structures
in place to promote co
joined working between
Departments
Align recruitment
/promotion practices
In general it is good to get
a mix of talent, be it
internal or external. The
recommendation also
presupposes that Civil
Servants lack the skills to
deliver some of the
functions. This is not
necessarily true and there
is lack of evidence to
indicate that the external
Assist as follows
Clarity of Accountability Y
Sufficiency of control Y
Clarity of consequences N
Sufficiency of information N
Appoint Citizens Ombudsman.
Appoint a Public Body Review
Group. The function of this body
is to independently review
Departments and direct
improvements to be made.
This would be a good idea but
shared responsibility is
questionable. Budgets get fought
over, staff resources are held
tightly. Secretary Generals will be
required by Ministers to focus on
core business and peripheral
objectives will be sidelined. It may
be better to have an A.Sec
appointed with co responsibility.
The Government Oversight
Board
The ability to select the Secretary
General should be non political.
The Governance Oversight Board
should be able to move Secretary
Generals around and remove them
if they are not delivering on
(achievable targets). Some
Secretary Generals should be
appointed from outside the country
for a period of time (ie UK,
Australia, Canada etc) if real
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Enable formal political
input into the
development of the job
specification of senior
level officials and their
performance assessment
candidates are
significantly better
meaning is to be given to the
reform.
Job specification should
be developed by TLAC ,
however the Government
Oversight Board should be
able to recommend
changes but these should
not be mandatory
Short term contracts focus on short
terms results and the longer term
outcomes get shelved. Get good
people, agree smart objectives,
evidence based policy and reward
them for delivery. Pay for real
effective outcomes and results.
You need experienced old heads
as well, they tend to remember the
last crisis.
The problem currently is that there
is a big gap between what a
Secretary General does or indeed
an Assistant Secretary and a
person from the private sector.
Therefore TLAC either put in
place a fast track course to up skill
external appointments to senior
roles or they simply will never get
any new external people into
positions at a senior level. It could
be useful if Civil servants went to
work for periods in the private
sector or there was a mentoring
system (course ) to get Assistant
Secretaries up to a high level
suitable for Secretary General
Have a training course for PO’ to
get to ASEC.
There is certainly no reason that
the Government could not make
their views known about the job
specifications but this should not
be mandatory.
Equally ministers should have
some say in the performance
appraisal of Secretary General but
a better solution is a government
Oversight board. The case for a
more senior sec gen appraising
other Sec Gens is not practical
A good idea
Legislate to change the
restrictions on the
evidence of civil servants
to Oireachtas committees
Reaffirm and reinforce
the Values of the Civil
Need to protect Civil Servants
somehow from the media and
politically driven agendas
It is difficult to have a
more private sector model
A good idea but measuring short
term goals and performance,
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Service
yet to retain the values and
ethics of the Civil Service
Regardless of legislating
Codes of standards etc it is
essentially driven by the
tone at the top. If you
espouse and encourage
private sector models, it is
difficult to maintain the
ethos and values.
putting in place 5 year contracts
does not encourage a long term
quality focus. It is all about short
term delivery often with poor
quality results.
Build structures to
underpin effective
horizontal governance
In such a case it is important that
there is a working group with an
Assistant Secretary that has a clear
joint delivery focus. There however
should be one lead department
Robust governance
framework.
Agreed.
It is essential that there is greater
accountability
 For departments managing
of agencies/
 For internal processes
6. Conclusion
We support greater levels of accountability across the civil service and we are supportive of some of
the proposed changes. Internal Audit Units and Committees have been demanding greater
accountability within the Civil Service for a number of years and are keen play a constructive part in
promoting greater levels of accountability. It is important that the internal capabilities (skills,
experience, competencies education, training etc) are developed across the Civil Service to ensure
that the leadership and management of the civil service is strong and effective. This has not been at
the forefront to date. Civil Servants have a strong culture of impartiality, are ethical, have a sense of
fair play and consider the good of all citizens. It is a really important that such characteristics are not
lost or lowered in any way by the “quick fix”. The private sector model has demonstrated that it is no
bastion of virtue, it has not applied good management practices or governance in recent times and to
be honest it has to be closely regulated to ensure it behaves. The private sector always believe they
could do it better, however running a country was and still is a totally different function.
We do not support any actions that lead to a short term focus and short term contracts can lead to
this. We do believe that building strong governance processes, policy development that focuses on
outcomes with strong independent scrutiny can lead to more effective service delivery and overall it
would improve accountability.
Internal Audit and Audit Committees have been delivering accountability across the Civil Service
for years; this can certainly be made more effective. The audit function must be placed in a position
where they can verify that there is effective governance and management practice in place and have
secure tenure to do. This requires that they have the appropriate status, skills, resources and support
from Government to do this.
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