PERSONNEL RECORDS. Unit: Subject: Sarbanes-Oxley Act Review - Human Resources and Payroll Title: Risk and Control Identification Year end: OBJECTIVE

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1 Unit: Subject: Sarbanes-Oxley Act Review - Human Resources and Payroll Title: Risk and Control Identification Year end: POTENTIAL PERSONNEL RECORDS Personnel files contain accurate, valid and complete information. Required human resources and payroll documentation is retained for mandatory retention periods Content of personnel files is not prescribed in terms of a formalised policy and procedure. Personnel information is not available as and when required. Invalid, inaccurate or incomplete information is acquired and retained in the personnel files. Records are lost or prematurely destroyed. A company policy exists as a guideline for all the records / information that should be retained (complying to applicable laws and regulations) in each employee's personnel file. Personnel files should contain a standardised index / list of contents. A responsible senior employee should check / review the information for accuracy and completeness (and sign the personnel files as evidence of review). Access (physical and IT) to the employee records should be limited and only granted to authorised personnel. Records should be safeguarded in a strongroom. Records and documents can only be destroyed once the applicable laws and regulations regarding the retention of documents, etc. are considered.

2 POTENTIAL Confidentiality of human resources information is maintained. Human resource and payroll records are subject to proper security procedures. 103 Information contained in personnel files is not restricted to authorised employees only. Human resource and payroll records are not subject to proper security procedures. Confidentiality of sensitive information is not promoted: Human resource personnel divulge confidential information. Procedures preventing unauthorised access to payroll information (including payroll reports) should be enforced. Access (physical and IT) to the employee records should be limited and only granted to authorised personnel. Records should be safeguarded in a strongroom. A separate salaries and wages bank account should be maintained to ensure payroll confidentiality. Periodic security compliance reviews should be conducted to identify weaknesses in the payroll system. A company policy exists to prohibit the spreading of confidential information. Disciplinary actions must be taken against employees who violate any company policies including the spreading of confidential information. WORKFORCE PLANNING The demand for and availability of human resources should be forecasted. Shortages and surplus conditions should be identified. 201 The entity may be unaware of its current / future staffing The human resource implications of changes in strategic needs. The Company may not have sufficient employees with the appropriate skills to achieve its objectives. (The work force may be inadequate or excessive given corporate objectives). Company may hire employees in excess of / inadequate to meet its manpower needs. (Optimal staffing levels are not achieved). High operational costs may be incurred due to extensive use of overtime, contract or consulting resources. Poor matching of skills with job duties may exist. Inequitable workload distribution may exist. objectives and priorities, organisation, technology, legislation, products or programs, should be identified. The number, type, level, and location of human resources required to carry out organisational objectives and operational plans should be identified. Current, accurate inventories of basic employment data for all employees should be maintained. surplus conditions should be identified. Relevant career data inventories, including information experience, skills, and promotion potential for critical occupational groups and levels should be maintained. The impact of identified shortages and surpluses should be considered in the preparation of operational and financial plans. Action plans should be prepared to address imbalances in the numbers and / or skills of human resources which have been identified. 202 Imbalances in the number and skills of human resources may not be considered in the operational and financial objectives. The Company may not have sufficient employees with the appropriate skills to achieve its objectives. Action plans that include activities such as engagements, terminations, training, development and relocation should identify the costs of implementation, the implementation time frame, and the individuals responsible for implementation. Action plans should be monitored on a regular basis and the results assessed to ensure objectives are being met and to identify modifications to the plans that may be required.

3 POTENTIAL Maintain employee turnover at an acceptable level. 203 Non-competitive compensation levels and employee benefits resulting in company being unable to retain staff. Human Resources should perform benchmarking exercises to test and evaluate company benefits against other market related institutions. The results of benchmarking exercises should be recorded and reported and kept for future reference. LEGISLATIVE ENVIRONMENT (Regulatory Challenges) Compliance with applicable laws, regulations and company policies. 301 Management or supervisory personnel are unaware of or ignore legal and regulatory requirements, and company policies. Employment laws and regulations may be violated resulting in fines, penalties or litigation. Management, supervisory personnel and Human Resources staff should read, and sign as evidence of awareness, legal and regulatory requirements, media circulations and company policies, on an on-going basis. Management and supervisory personnel should sign a document, on a yearly basis, as proof that they are aware of the contents, understand and adhere to legal, regulatory requirements, Employment Equity Act, Basic Conditions of Employment and company policies and procedures. Non-adherence to the requirements should result in appropriate disciplinary action being instituted. A senior, independent manager should review these signed documents as proof that personnel are aware of and adhere to company policies and legal procedures. All signed documentation should be filed and safeguarded for future reference. Maintain records that demonstrate compliance with applicable laws and regulations. Compliance with the Basic Conditions of Employment Act Records are not retained to demonstrate compliance with applicable laws and regulations. Working conditions of employees do not meet minimum standards: Provisions relating to working hours are not applied e.g. the rule of a 40-hour working week, meal intervals, maximum amount of overtime hours is exceeded. Minimum wage / salary / rate per hour basic conditions are not applied. Provisions relating to leave (annual, sick, maternity and family responsibility) are not applied. A company policy exists as a guideline for all the records that should be retained (complying to applicable laws and regulations, e.g. Archive act & retention of documents guidelines) for each employee. Compliance with the Basic Conditions of Employment Act is monitored by management.

4 POTENTIAL Compliance with the Occupational Health and Safety Act. Compliance with the Employment Equity Act. Compliance with the Labour Relations Act Health & Safety in the work place is not established. Smoking laws not implemented in the work place Unequal opportunities. Unfair discrimination occurs in the workplace. Company does not plan for access to building & toilet facilities for "handicapped" people. All staff are not considered for training Fundamental "worker's rights" of employees are disregarded. Unfair dismissals. Labour organisations may call for strikes or work slowdowns. Inappropriate action is taken by the company in response to labour action. Risk management should ensure that the company abide to all applicable health and safety laws and regulations for the workplace and enforce all these health and safety laws and regulations. Notifications should be placed where required. Disciplinary actions must be taken against employees, contractors and other parties who violate any health and safety regulations. Compliance with the Employment Equity Act is monitored by management. Company should have alternative access to buildings for handicapped people and adequate toilet facilities for them. The company should adhere to the applicable laws and regulations for the correct work force ratios. Compliance with the Labour Relations Act is monitored by management. Company should ensure that actions taken against strikes and slowdowns comply with relevant labour laws and legislation in conjunction with the legal department.. EMPLOYEE RELATIONS The grievance and arbitration process should be used as a tool for timely, efficient, and effective disposition of disputes. 401 Productivity may be reduced due to untimely and inefficient resolution of grievances. The Company may be subject to unfavorable publicity when grievances are handled externally. The cost of dispute resolution may escalate when grievances are handled externally. Managers should be aware of the organisational climate, employee attitudes, and causes of grievances. Employee grievances should be administered expeditiously. Dispute dispositions should be communicated and resolutions implemented. Disciplinary activity should be monitored and reviewed to highlight potential areas of concern requiring management attention. EMPLOYEE RECRUITMENT AND SELECTION Employee Authorisation

5 POTENTIAL The requirement to employ is formally motivated. 501 The requirement to employ is not formally motivated and communicated to the person authorising the new employment position. The authorising process is not formally provided for in the units policies and procedures. The authorising process is not performed in terms of prescribed company policies. The authorising official is not appropriate and sufficiently senior. Formal procedures exists to address the exact requirements for a new employment position and should be communicated to all managers that motivate these new positions. No new employment position should be authorised unless a proper motivation is communicated and received by Human Resources. The motivation should formally include the following information: a) Required skills profile, b) position grading, c) date required and d) job description. Formal company policy and procedures exists to address the authorising process. There should be a formalised authorisation and review process performed by an appointed senior Human Resources official. The authorisation process should include a signature as proof of review that procedure was followed. The need for the position, job requirements and selection criteria should be clearly defined (in terms of a detailed position specification). 502 Employment equity and equality of access requirements may not be met. Changes in operational or business plans, new technology, or new services which may require employees with different skills may not be considered in the replacement process. The need for filling a vacant position should be reviewed before staffing activities begin. The number, type, level, and work location of persons sought and when they are required should be specified. A description of the purpose of the job, the main tasks to be carried out, and the terms and conditions of employment should be documented and made available to persons with recruitment responsibilities. The selection criteria should be based on the job requirements, experience, personal characteristics desired, and application of employment equity directives. Employee Recruitment and Selection Authorised employment requests are communicated timeously to the recruiting function. Recruitment activities should maximise the likelihood of attracting qualified candidates at a reasonable cost, within a reasonable period of time, and with due regard to equality of access. The appropriate profile of potential employees are sourced for consideration by the recruiting activity Authorised employment requests are not communicated timeously to the recruiting function. The cost of recruitment may not be cost justified. Recruitment activities may not be focused on qualified audiences or candidates. Appropriate and relevant sources for potential candidates are not identified. Potential candidates who have not been screened and interviewed are not timeously identified. Formal company policy and procedures should be developed to address timeous communication to the recruiting function for all authorised employment requests. Alternative methods for filling a position including internal versus external recruitment, advertising, and use of agencies should be considered. The area of search should be sufficient to attract qualified candidates at a reasonable cost. Turnaround time for filling positions should be reasonable.

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