Audit in the context of the Framework Contract No: 30-CE /08-75 Specific Contract DG JLS
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1 Audit in the context of the Framework Contract No: 30-CE /08-75 Specific Contract DG JLS DRAFT AUDIT REPORT - PROJECT JLS/ 2005/NGO/015 Subject: Beneficiary audited: Audit of the grant agreement JLS/2005/NGO/015 signed between the European Communities and Life Together for the action entitled Police- Roma dialogue and reflection beyond prison walls (MIROV)" Life Together Registered address: 30. Dubna Ostrava Czech Republic Audit dates: 13 to 15 July 2010 Audit venue: 30. Dubna Ostrava Czech Republic Audit team: Paul Stockton (Audit Partner) Martin Daniel (Audit Manager) Duncan Butler-Wheelhouse (Audit Senior) Monika Modzesova (Audit Assistant) Beneficiary s representatives consulted: Name Kumar Vishnawathan Justina Kamena Katerina Cernikova Jana Andreova Position Director of Life Together & Project Coordinator Head of Finance Department Project Financial Manager Cashier& Payroll Manager Date of issue of the report: Signature of the Reporting Partner Paul Stockton, Moore Stephens LLP: Paul Stockton Partner Moore Stephens LLP 150 Aldersgate Street London EC1A 4AB This report is established by request of the European Commission. The views expressed in this report are those of the external auditors and in no way reflect the official opinion of the European Commission. This report has been prepared for the sole use of the European Commission in connection with its control of the funds granted and should not be used by other parties or for other purposes.
2 TABLE OF CONTENTS PART I EXECUTIVE SUMMARY... 2 PART II - DETAILED RESULTS THE AUDIT OBJECTIVES AGREED AUDIT PROCEDURE BACKGROUND INFORMATION ON THE GRANT AGREEMENT THE GRANT AGREEMENT THE BENEFICIARY PROJECT PARTNERS THE PROJECT FINANCING AND ACCOUNTING PROCEDURES ACCOUNTING SYSTEM USED IN PROJECT MANAGEMENT FINANCIAL MANAGEMENT OF THE PROJECT Bank account Interest on Commission pre-financing Value Added Tax (VAT) System of controls in place in relation to the project VERIFICATION OF THE FINANCIAL RESOURCES FOR THE OVERALL PROJECT EXISTENCE OF CO-FINANCING OF THE PROJECT EXISTENCE OF TRANSFERS TO PROJECT PARTNERS VERIFICATION OF THE EXPENSES FOR THE OVERALL PROJECT EXPENDITURE DECLARED AND AUDIT SAMPLE COVERAGE INELIGIBLE EXPENDITURE PER BUDGET HEADING Travel and subsistence allowances Overheads RECOMMENDATIONS TO THE BENEFICIARY CRITICAL VERY IMPORTANT IMPORTANT DESIRABLE... 8
3 PART I EXECUTIVE SUMMARY Project audited The audit covered expenditure under Grant Agreement JLS/2005/NGO/015 for the project Police- Roma dialogue and reflection beyond prison walls (MIROV) implemented by Life Together (Vzajemne souziti). The agreed project implementation period was for 18 months from 1 January 2007 to 30 June The Grant Agreement between Life Together and the Commission provided for a maximum of 80% of eligible project expenditure to be funded by the Commission, up to a maximum amount of 146, Total budgeted eligible project costs were 183, Key figures Life Together JLS/ 2005/NGO/015 (MIROV) Grant agreement dated 27 December 2006 Duration of the action 18 months Total budgeted eligible expenditure per grant agreement 183, Maximum Commission grant 80.00% 146, Amount paid by the Commission to date 146, Expenditure declared by the beneficiary 183, Unreported income/ surplus - Ineligible expenditure post audit Eligible expenditure post audit 183, Main findings The following costs, totalling are considered ineligible or require adjustment (see Section 5.2): Budget lines Reasons for ineligibility Amounts ( ) Travel and Expenditure relating to another project subsistence Expenditure recorded twice in cost claim Overheads Adjustment to overhead claim 9.27 Total Conclusions Following our audit of the project JLS/2005/NGO/015 - Police-Roma dialogue and reflection beyond prison walls (MIROV), we have concluded that out of project expenditure of 183, reported by the beneficiary, Life Together, 183, represents eligible and supported costs. Costs of are ineligible or have not been reported correctly. We have also made 2 recommendations for the beneficiary (see Section 6 for details). 2
4 PART II - DETAILED RESULTS 1. THE AUDIT 1.1. Objectives The purpose of the audit was to check whether The financial contribution from the European Commission was used exclusively for the purposes described in the application for a grant; Co-financing was genuine and in conformity with Commission rules; Expenditure was incurred during the period covered by the grant agreement; The declared expenditure was backed up with appropriate documentation, proof of payments and the existence of controls; The expenditure declared for project partners was reimbursed by the Beneficiary; The project's activities were implemented according to the project description annexed to the grant agreement; and if this was not the case, whether changes were justified; The documents submitted to the Commission (final narrative and financial reports) were genuine, accurate and complete; The declaration of expenditure included all revenue (if any) generated by the project or deriving from other sources; Multiple financing was excluded; The grant generated a profit for the Beneficiary; The conditions laid down in the grant agreement were complied with, including provisions on information and publicity; The beneficiary's management of the grant complied with the principles of sound financial management, economy and efficiency Agreed audit procedure Our audit was carried out at the offices of Life Together from 13 to 15 July 2010 by Duncan Butler- Wheelhouse and Monika Modzesova of Moore Stephens. Following the audit a report was drafted by Duncan Butler-Wheelhouse at Moore Stephens head office in London, and reviewed by Martin Daniel and Paul Stockton of Moore Stephens LLP, London. The beneficiary was initially notified of the audit dates by on 14 May The beneficiary agreed to these dates on 25 May The beneficiary provided us with all requested documentation during our audit visit. We worked with the full co-operation of the beneficiary during our visit. 3
5 2. BACKGROUND INFORMATION ON THE GRANT AGREEMENT 2.1. The grant agreement The Grant Agreement JLS/2005/NGO/015 provided for funding from the Commission to the project Police-Roma dialogue and reflection beyond prison walls (MIROV) implemented by Life Together ( the Beneficiary ). The agreed project implementation period was for 18 months from 1 January 2007 to 30 June The Grant Agreement between Life Together and the Commission provided for a maximum of 80.00% of eligible project expenditure to be funded by the Commission, up to a maximum amount of 146, Total budgeted eligible project costs were 183, The Commission made two payments to the Beneficiary as follows: Initial pre-financing 102, Final Payment 43, Total 146, The audit was performed in accordance with Article II.19 of the Grant Agreement The beneficiary The beneficiary, Life Together (Vzajemne Souziti), is a registered non-profit organisation, which promotes the well-being of the Roma Community within the Czech Republic, and also improved relations between the Roma community and the institutions of the Czech state and regional government, and the officials of these institutions. Mr Kumar Vishnawathan, the director of Life Together, was the Project coordinator, and had overall responsibility for the project Project partners There were no recognised project partners in the Grant Agreement. However, the project MIROV involved collaboration with MIROV prison authorities and local police forces The project Two key aims were set out for this project: 1. Humanising the prison environment targeting improved relations between and among prisoners and prison guards in Mirov prison. 2. Roma-Police trust-building work increasing familiarity and trust between police and Roma community members. In summary, the MIROV project aimed to improve conditions within the MIROV prison, particularly for Roma inmates, and also sought improved relationships between the police forces and Roma community members through a number of trust-building events and mediation between potentially divided groups. 4
6 3. FINANCING AND ACCOUNTING PROCEDURES 3.1. Accounting system used in project management Life Together held originals of all documentation to support the project expenditure incurred. The accounting system used by the beneficiary is ISO on which a full nominal ledger is maintained. Cost centres are used for various projects and there appeared to be sufficient controls in place to ensure that items of expenditure were properly authorised project costs Financial management of the project BANK ACCOUNT The beneficiary did not use a specific bank account for the project. Funds were received into a Euro denominated account (IBAN CZ ), and then transferred into the Czech Crown (CZK) account, both held at a local CSOB Bank branch. Payments made to suppliers were either paid out of the CSOB Czech Crown account for Life Together, or were made via cash disbursements (typically applied in the case of payments valued at less than CZK 5,000, approximately 200) and subsequent presentation of receipts to cover the expenditure INTEREST ON COMMISSION PRE-FINANCING Interest on Commission pre-financing of was declared by the Beneficiary and deducted from the final payment by the Commission VALUE ADDED TAX (VAT) The beneficiary, being a non-profit organisation, is not permitted by the national tax authorities to reclaim VAT incurred on input costs. VAT amounts paid have therefore been included in project expenditure claimed SYSTEM OF CONTROLS IN PLACE IN RELATION TO THE PROJECT The project was managed within the control systems used by Life Together for all financial transactions. Purchases were raised by project management staff or project members. In the case of larger purchases these would require the involvement of the central purchasing department of Life Together, however no such purchases were incurred as part of this project. According to Life Together guidelines for approval, all expenditures must be submitted and approved by at least two separate persons. Cash advances were approved by the project co-ordinator Kumar Vishnawathan. As Mr Vishnawathan is also the director of Life Together, in the case of any larger purchases these would also be approved by the elected deputy Chairperson of the organisation, currently Mrs Petra Juroscova. Final approval of all purchases also required the signature of either the cashier Mrs Jana Andreova for cash disbursements, or the project financial co-ordinator Mrs Caterina Cernikova. Once approved, and on signed confirmation of delivery of goods or services, purchases were paid for by the finance department. All transactions relating to this project were entered onto the general ledger with a specific project reference code so that these transactions could be easily separated for project-specific analysis. The project leader, Mr. Kumar Vishnawathan, had overall responsibility for the financial management of the project and worked in conjunction with the project financial co-ordinator, Mrs Caterina Cernikova, for preparation of the final financial statement. As part of the preparation of the final financial statement a review of costs incurred as compared with the final budget was carried out and any excess project costs were not submitted in the cost claim. 5
7 4. VERIFICATION OF THE FINANCIAL RESOURCES FOR THE OVERALL PROJECT 4.1. Existence of co-financing of the project All funds received for this project have been made available from either Life Together s existing funds or the European Commission. No other co-financing for the project was envisaged, or detected during our audit Existence of transfers to project partners There were no project partners. 6
8 5. VERIFICATION OF THE EXPENSES FOR THE OVERALL PROJECT 5.1. Expenditure declared and audit sample coverage The breakdown of the expenditure declared by the beneficiary and our audit coverage is included in Annex 1 to the report. In total, we checked 97% of the project expenditure declared by the beneficiary. Project staff costs were vouched to payslips and other available payroll records (contracts of employment, time records). In relation to other project expenditure declared, travel tickets and receipts, invoices and payment documentation were vouched with accompanying contracts, where applicable. Consistency with the agreed budget and compliance with the conditions for eligibility of expenditure were also checked Ineligible expenditure per budget heading TRAVEL AND SUBSISTENCE ALLOWANCES The following ineligible amounts, totalling were identified (see Annex 2 for detail of cost items): 1) Costs declared totalling (ref B65) were in fact related to another project (Daphne II) and had been incorrectly allocated to project MIROV; 2) A transaction of (ref B71) was mistakenly duplicated within the cost claim OVERHEADS The beneficiary was able to claim up to 7% of eligible direct project costs to cover its overheads and indirect expenses. Following the above ineligible direct costs identified, its overhead claim is adjusted by
9 6. RECOMMENDATIONS TO THE BENEFICIARY 6.1. Critical Very important Important Desirable 1. Copies of all correspondence with the Commission regarding the project, as well as all agreements and other official documents should be kept in a systematic and easily accessible set of records; 2. All receipts being submitted to the cashier as evidence of expenditure against cash disbursements should be numbered and submitted with a summary table identifying each receipt and giving the total value of all receipts. This will make it much simpler and less labour-intensive for the finance department to check that expenses claims are complete and accurate. 8
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