RAMP Good Governance Framework As at 14 Oct 2013
No. / Issue / Action to Mitigate Risk / Responsibility / Target/Monitoring / Implementation Status at Oct 14, 2013 and Evidence / Remaining Steps, Target Date & Resources Needed /Element 1: Procurement
1.a / Risk of:
· Collusion during bidding process;
· Biased bid evaluation;
· Suppliers/contractors offering informal payments as incentives for favorable treatment. / Unless otherwise agreed, the Royal Government of Cambodia (RGC) shall use the services of an International Procurement Agent (IPA) for all procurement, financed wholly or partially by the International Development Association (IDA), to be undertaken under the project, except for procurement through the methods of direct contracting, procurement from UN agencies, and single source and sole source selection. / MEF / IPA(CA) commenced work on December 3, 2007. / EGIS International is supervising all Maintenance Contracts
All civil work contracts awarded / IDA civil works Contracts of year 2-3 are affected by flood. Requests for flood repairs are being prepared and submitted to IDA no later than 28 Oct 2013.
Request for addition work apr. 10 km in AWP-year 4 financed by IDA is being prepared.
ADB/AusAID/OFID
Procurement financed by sources other than IDA, including RGC, the Asian Development Bank (ADB) and the Australian Agency for International Development (AusAID), will not be undertaken through the IPA but by the Ministry of Public Works and Transport (MPWT) itself. / MPWT / Refer to current Procurement Plan for details / All procurement completed
For procurement of IDA financed contracts, the IPA shall prepare bidding documents, call and evaluate bids and recommend award. / IPA / Supervision of IPA by MEF and quarterly review meetings with IDA. / Refer to current Procurement plan for details / All procurement completed
For procurement of IDA financed contracts, the MPWT agencies shall continue to prepare procurement plan, and designs, bills of quantities, and technical specifications for IPA to incorporate in bidding documents. / Technical Research Centre (TRC) in General Department of Public Works (GDPW). / Schedule for production of first year designs agreed at appraisal. / All civil work contracts awarded
Implementation Advisor completed and contract was signed in May 2012 / IA to finalize the Guidelines for RAMP
1.b / Clear procedures and thresholds needed. / IPA to be instructed to follow the Manual on Standard Operating Procedures for Externally Assisted Projects (SOP) including the Externally Assisted Procurement Manual for Goods, Works and Services (PM), mandated by Sub-Decree No. 14 dated February 26, 2007.
The project is adopting the thresholds in the SOP/PM. / MEF. Done through IPA’s terms of reference. / Supervision of IPA by MEF with quarterly review meetings with IDA.
IDA to verify compliance during supervision missions and prior and post reviews of procurement. / IPA is following SOP/FM / completed
1.c / Insufficient procurement capacity of MPWT. / GDPW to engage one qualified and experienced national staff or recruit an individual consultant as Procurement Coordinator for the project, to coordinate procurement activities among MPWT, IPA, MEF, and IDA. The Procurement Coordinator will also provide on-the-job training to procurement practitioners in GDPW. / GDPW to prepare terms of reference (TOR) for national consultant if national staff cannot be engaged and IPA to recruit. / Agree TOR at appraisal. If consultant to be recruited, start recruitment by advance action immediately after negotiations with target of having the consultant in place by June 2008. / Procurement training was provided by Roughton Int National capacity development specialist during Oct-Nov 2012
Local Contractors and Consultants had been trained by the RI capacity development specialist in preparation of complying bids and GGF / Ongoing
1.d / Incomplete or delayed Procurement Plans. / Preparation of realistic annual Procurement Plan tied to annual work plan (AWP) and budget. / AWP and Procurement plan prepared by GDPW, Budget prepared by Department of Accounts and Finance (DAF) with oversight of Project Technical Committee (PTC) and approval by ICRRM. / Plan for first 18 months agreed by IDA at appraisal. Preliminary updated plan to be prepared annually in May/June (for initial round of MEF budget preparation) and final updated plan by December. PSC to endorse plan, IDA to monitor. / RAMP is regularly up-dating the approved Procurement plan / Ongoing
1.e / Risk of informal payments by contractors, suppliers and consultants during procurement and contract implementation. / All contractors, suppliers and consultants – firms or individuals, national and international – bidding for contracts under the project shall sign the Declaration on Ethical Conduct and Fraud and Corruption in the SOP/PM. Amend item 5 of the Declaration to read:
In connection with this procurement exercise and any contract that is awarded to us as a result thereof, no payments have been made or will be made by us, our associates, agents, shareholders, partners or their relatives or associates to any of the staff, associates, consultants, employees or relatives of such who are involved with the procurement process, contract implementation, and the issuance of progress payments on behalf of the purchaser, client or employer.” / IPA/GDPW through MEF instruction. / MEF to verify during regular supervision of IPA. / MPWT will ensures compliance in all bids and contracts prepared by them
Issues raised by IDA post-reviews has all been addressed / Completed
Include amended Declaration in all bidding documents, RFPs, and contracts. / IPA/GDPW. / IDA to verify compliance during prior or post reviews. / Declaration included in all bidding documents / Ongoing
2.a / Insufficient financial management capacity. / Proposed FM structure for MPWT Department of Accounts and Finance (DAF) including a senior FM advisor with experience in externally funded projects is assessed as adequate for FM of RAMP, subject to further capacity development. / MPWT to confirm that a senior FM specialist will be made available for FM of RAMP. / Confirm at appraisal. / Significant improvements made to RAMP FM through Component B1 inputs, / Register of ongoing improvements identified for Implementation Advisor FM Specialist to assist with
MPWT to prepare and implement time-bound training programs for DAF staff. / Agree by negotiations and implement by effectiveness. / FM trainings in QuickBooks and other financial skills have been provided to DoAF and other MPWT staffs in Oct – Nov 2012 / ongoing
2.b / Weak internal controls. / Ensure that MPWT/DAF uses SOP and Financial Management Manual (FMM) mandated by Sub-Decree No.14 on February 26, 2007. / GDPW to ensure compliance. / Agree at negotiations and mandate in legal agreement. MEF and IDA to verify use of SOP/FMM during supervision missions. / SFMM approved by IDA, improvements made under Component B1and DAF staff job descriptions updated to improve internal controls / Completed
2.c / Readiness of proprietary accounting software. / MPWT to decide which proprietary software package will be adopted for the project in DAF. MPWT DAF to install. / MPWT DAF. / Agree by appraisal.
Install by October 1, 2008. Correct use to be verified by IDA during quarterly FM supervision missions. / Software upgraded in Oct 2012 with trainings completed in Oct and Nov 2012
QuickBooks application in the DoAF RAMP finance is currently acceptable / Ongoing
2.d / Minimize cash transactions to ensure proper use of funds. / All progress payments to contractors, suppliers and consultants – firms, individuals, national and international – to be made by check or transfer to bank accounts. Retain evidence for audit and supervision missions. / MPWT/GDPW. Internal auditor to monitor and external auditor to report on compliance during annual audit. / MPWT DAF to monitor.
IDA FM staff to verify during FM supervision missions and review of audit reports. / Complying for amounts above US$500, as per SOP/FMM. / Ongoing.
2.e / Delayed or non-existent reconciliation of advances for operating costs and expenses. / Advances of operating expenses to staff or field offices to be reconciled within one week of the end of each month. / GDPW Project Director/Manager and financial officers. / IDA to verify compliance during supervision missions. / Procedures reviewed & revised under Component B1 completed / Completed
No further advances to be paid to staff or field offices until previous advance to those staff or offices is reconciled and cleared against documentary evidence. / GDPW Project Director/ Manager and financial officers. / IDA to verify compliance during supervision missions. / No issues raised in latest mission
2.f / Inconsistency in allowances paid to Government staff attending training, workshops and study tours. / Adopt the agreed action in 3(a) of the November 2007 Joint Country Portfolio Performance Review Action Plan. / MEF to review and propose for ADB/WB concurrence the rates which should be used by RGC staff on ADB/WB projects. / Rates to be agreed by October 2008. Until then, IDA rates may be used for overseas travel. Internal Auditor to monitor and IDA to verify compliance when reviewing SOEs and withdrawal applications. / Ceiling for reimbursement of hotel and per diem is equal to rates paid to IDA staff. / Ongoing.
2.g / Planning of training and workshops and establishment of cost guidelines and rules for reimbursement of expenses (the Project will not fund overseas training and study tours without prior approval of the IDA). / Establish Annual Training and Workshop Plan. The Plan will include training on Safeguards, road management capacity development, contract bidding procedures (for contractors), road safety, project financial management, internal audit and procurement. / GDPW, which shall follow training requirements detailed in the Project Appraisal Document. / Annual Training Plan cleared by IDA in March for review to enable submission to MEF in June (for MEF initial round of budget submissions). / Training planned for RAMP staff on Financial Management and ICT (using new e-Learning Centre) completed in Oct – Nov 2012 / ongoing
The Plan will include details of:
1. Cost estimates.
2. Eligibility rules for attending training and workshops. Attendees must:
· be engaged in work relevant to the training;
· be competent in the language used;
· after completion, report on and share their experiences for the benefit of the project.
3. Evidence that training, workshops and other similar activities:
· are in line with project aims and objectives;
· meet identified needs within the sub-component plans;
· have budget in line with planned expenditure.
4. Overseas training, if any, which will be subject to IDA prior approval of funding by the Credit. / GDPW to follow Working Group guidelines when issued (see below). / IDA to verify through its membership of Working Group.
Cost guidelines to be established for selected training/workshop activities:
· venue rental with refreshments/meals;
· sound and projection equipment hire;
· stationery/hand-outs;
· project-specific training and workshop materials;
· simultaneous translators;
· photocopying, reproduction, translation. / MEF/ADB/WB to establish working group with representatives from IAs to devise guidelines on aims, content and cost norms of training programs, workshops and study tours, and issue to IAs. / Rates to be agreed by October 2008. Until then, IDA rates may be used for overseas travel. Internal Auditor to monitor and IDA to verify compliance when reviewing SOEs and withdrawal applications. / The revised SoP has been issued by MEF for project implementation in May 2012.
SoP training has been provided to selected RAMP staff by MEF on 22-23 Nov 2012 .
RAMP to apply the rates / On-going
Define evidence to be submitted by attendees for reimbursement of expenses, which may include proof of attendance for period claimed with signed statement by the workshop or training organizer. / Working Group to define evidence and include in directive. MPWT/GDPW to ensure compliance. / Directive issued by October 2008. IDA to verify compliance when reviewing SOEs and withdrawal applications. / Being managed in line with SFMM / Ongoing, as training is undertaken
Reimburse against receipts except where covered by fixed allowances in MEF’s letter No. 2000. Evidence of payment to be kept for attendees’ per diem and allowances for audit and IDA supervision missions. / MPWT DAF. / MPWT to monitor and IDA to verify compliance when reviewing SOEs and withdrawal applications. / Being managed in line with SFMM / Ongoing
2.h / MPWT’s internal audit department scope of work does not cover projects. / MPWT will recruit a qualified and experienced audit consultant to train and accredit staff of the internal audit department, develop a project internal audit plan based on the risk enterprise framework model of MPWT, and prepare an internal audit manual for MPWT. / MPWT. / Agree TOR by negotiations. Start recruitment immediately after negotiations, sign contract by July 2008. IDA FM staff to verify consultant’s outputs and outcomes in MPWT.
2.i / Annual external audit. / Adopt new TOR for external audit (agreed MEF/IDA) with greater emphasis on internal controls and appoint auditor. / MEF to confirm that RAMP is included in first audit bundle, now in final stage of preparation. / MEF to confirm that RAMP is included in first audit bundle, now in final stage of preparation. / Forth external audit of RAMP for 2012 Financial Year completed. / The audit report submitted to IDA and ADB in July 2013