Procurement Capacity Assessment and Recommendations. November PNG: Maritime and Waterways Safety Project

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1 Procurement Capacity Assessment and Recommendations vember 2012 PNG: Maritime and Waterways Safety Project

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3 Proposed Project Name: Maritime and Waterways Safety Project Executing Agency: National Maritime Safety Authority Proposed Amount: US$48.4 million Source of Funding: ADB (ADF $41.5million, Government of PNG $6.9 million) Assessor: D. Mizusawa, PATE Date: 2 and 22 August 2012 Expected Procurement The planned procurement will comprise (i) replacement of 99 and installation of 33 new navigational aids (navaids), (ii) additional safety information infrastructure, i.e. installation of 5 new automatic identification system (AIS) base stations and transponders as well as relocation of 3 existing units, installation of 4 additional tide gauges and extensive hydrographic surveys, and (iii) consulting services to support project implementation and safety awareness program. Assessment of the National Environment The procurement primarily consists of: (i) international competitive bidding for the replacement and installation of new navaids and maintenance of the navaids, hydrographic surveys and survey equipment, and consulting services; (ii) national competitive bidding for a preconstruction survey (prior to the replacement/installation of the navigational aids), AIS installation work and its maintenance, tide gauges installation work and their maintenance, and 2 vehicles for the project implementation unit (PIU); and (iii) shopping for a small boat for hydrographic survey. The national framework applies to all government departments at the central and provincial level. It does not apply, other than voluntarily, to public bodies which are state-owned enterprises. The procurement framework in Papua New Guinea (PNG) consists of 2 main elements: Part VII of the Public Finances (Management) Act 1995 (PFMA), as amended; and Parts of the Financial Management Manual 2005 (FMM, which is part of Financial Instruction 1/2005, adopted under the PFMA). These are accompanied by a Good Procurement Manual (GPM), also adopted in One of the practical difficulties with the GPM is that, while it provides useful information on many procurement issues, that guidance is not always referable to the PFMA or FMM. The information relates primarily to other procurement systems (notably international financial institution guidelines) and has been imported into the GPM with cosmetic changes. As guidance, this might be helpful to some extent but many of the issues described in the GPM have no basis in the legal framework. The public procurement environment in PNG has improved in recent years. However, the overall procurement environment remains weak. The Central Supply and Tenders Board (CSTB) is the main entity responsible carrying for public procurement on behalf of government departments for goods, works and services that exceed Kina 300,000 ($145,650 equivalent), which must under law be put to public tender. The CSTB is by law assigned to control and regulate procurement, including monitoring of procurement performance and compliance. To date, this is not being done because of capacity and resource constraints. Provincial authorities wishing to undertake procurement which exceeds Kina 3 million must also go through the CSTB. Although the CSTB is intended to be an independent body, it falls under the Finance Department and reports to the Minister of Finance. Training programs that are now offered to CSTB staff, and other central, provincial and district-level government procurement staff, which

4 2 has had some impact in improving overall capacity. Currently, there are no mandatory national level standard bidding documents (SBDs) applied by procuring entities although the CSTB has produced a comprehensive set of SBDs which are awaiting adoption and roll-out. In the interim, the CSTB website provides 3 SBDs (goods, works and consultancy services) which are in effect copies of the World Bank documents. The quality of specifications is often, especially when standard specifications cannot be copied, and evaluation and award criteria tend to be poorly defined. Also the CSTB currently lacks the capacity to carry out procurement audits and compliance checks. The GPM includes provision on conflict of interest and makes reference to the anti-corruption provisions of the Criminal Code. Public Servants are also subject to the Code of Ethics which also deals extensively with corruption issues and conflicts of interest. A draft procurement assessment report was prepared in early 2010 on behalf of CSTB, which identified a number measures that could be taken to strengthen procurement, which included the foling: Strengthening existing procurement laws (there is currently no separate procurement law in PNG) Strengthening rules on minor procurement Extending the legal framework to cover all procurement using public funds (public bodies such as state-owned enterprises are currently exempt for public procurement laws) Increasing compliance with existing laws Consolidating and updating existing procurement manuals Improving the quality of technical specifications Improving transparency on bid award decisions Improving the complaints process Ensuring completeness of procurement records Providing better support the development of competitive procurement markets Improving the procurement control mechanism Increasing independence of CSTB Improving legal provisions for targeting corruption An Australian Agency for International Development (AusAID) procurement diagnostic of the Transport Sector carried out in April 2011 also identifies a number of key weaknesses associated with national procurement laws and processes including: The absence of a full range of methods in appropriate circumstances and based on strict conditions of use, including the current prohibition on selected tendering (e.g., prequalification) The absence of appropriate procedures for consulting services The need for time limits to be appropriate for the procurement in question and for extensions where necessary The inadequately detailed qualification criteria appropriate for different types of contract The imprecise evaluation criteria The failure to set a time period for publication of contract award notices The ineffective enforcement/complaint review mechanisms The AusAID assessment also finds that compliance and enforcement mechanisms are very weak. The legal framework and various manuals are subject to many instances of noncompliance that go unchecked. Internally, there is no evidence of disciplinary proceedings for failures to comply and, from the perspective of bidders, there are few avenues through which they can enforce their rights under the legal framework. The only viable avenue of appeal is

5 3 through the Ombudsman Commission which is identified as a possible forum but there are no formal procedures in place. General Agency Resource Assessment NMSA has no dedicated procurement unit. Individual department heads handle all procurement related activities (from preparation of specifications via monitoring and filing all procurement activities to registering and tracking warranties). There is little in-house procurement expertise with the experience in one internationally funded project. 1 There is no systematic process in NMSA to identify procurement requirements, nor is there a referencing system for procurement files. The department heads initiating and supervising procurements maintain individual filing systems. Agency Procurement Processes NMSA is required by law to fol national procurement processes outlined above. For major procurement (anything over Kina 300,000), the public tendering system would be required to be used which requires all tenders to be processed through CSTB. NMSA would also be required to fol government procurement processes for goods, works and consulting services as outlined in the PFMA, the GPM and the FMM. The process described in the Good Procurement Manual is similar to the Asian Development Bank (ADB) procurement guidelines for developing technical specifications, bid documents, advertising the tender, forming a tender evaluation committee with qualified personnel to assess bids and awarding the contract based on the committee decision. The PFMA and the GPM al for Certificate of Inexpediency which empowers the CSTB to certify that the inviting of tenders is impracticable or inexpedient, and therefore contracts maybe awarded without foling the tender process in periods of natural disasters, defense and health emergencies and periods of civil unrest, to enable procurement to be undertaken urgently. Process Control and Oversight, Records Keeping and Audit The public procurement process is controlled by the CSTB. The CSTB is required to work in conjunction with Auditor General s Office and Finance Inspections Division, Department of Treasury to ensure compliance with legislation and procedures. Primary responsibility for procurement rests with the head of the procuring agency, failure to comply with procurement regulations can result in hefty fines and up to 7 years imprisonment. If during investigations or audits the CSTB suspects criminal activity they may refer further action to: (i) the integrity panel - if the matter involves disputes or recommendations for blacklisting, (ii) the public service commission if the matter involves public servants, (iii) ombudsman commission if a leader is involved as defined in the leadership code, and (iv) independent consumer and competition commission if the matter involves collusive practices. Detailed records on tenders are required to be kept for up to 7 years by the CSTB, these include: (i) meeting agenda for all supply and tenders board meetings, (ii) meeting minutes signed by all of the supply and tenders board members present at the meeting in question, (iii) a contract file for each contract entered into, (iv) a contract register, and (v) a conflict of interest register. The contract file must include bid documents, advertisements, tendered offers, recommendation reports, board minutes supporting recommendations and a copy of the signed contract. The CSTB is subject to an annual audit by the Auditor General Office. The procuring agency must also retain documents relating to the contract and subsequent payment to suppliers which is also subject to annual audit by the Auditor General s Office as well as 1 AusAID. 2011/2012. Upgrade of Global Maritime Distress and Safety System (GMDSS).

6 4 scheduled internal audits. Summary Assessment and Recommendations Issue The proposed project will require several contracts for the provision of navigational aid, safety information infrastructure and related consulting services. In accordance with the PFMA, all contracts over Kina 300,000 must be processed through the public tendering system. Procurement Method Recommendation ADB Procurement Guidelines should apply to the project with emphasis on ensuring that requirements are not excessively stringent so as to discourage qualified international and national contractors. Overall Assessment Given the absence of a dedicated procurement unit and lack of procurement experience, overall procurement capacity within NMSA is and there would be procurement risks. Recommendations Given capacity within NMSA, it is recommended that a PIU be established in NMSA to support and oversee project procurement activities. The PIU will be staffed by an international procurement specialist and a NMSA procurement officer. The international specialist will provide the NMSA procurement officer and other staff with on-the-job mentoring and training experience, so that after project completion, the national officer and other staff can be absorbed into NMSA to carry out procurement functions. ADB will continuously provide NMSA with procurement training activities. 2 Specific Recommendations. Project Implementation Capacity Constraint Recommendations Action Responsibility and comment Long procurement approval timeframes At the project level, the PIU will proactively monitor the securing of procurement approval decisions. PIU General Recommendations, NMSA Capacity Capacity Constraint Recommendations Action Responsibility and comment Limited Procurement Capacity: lack of specialist skills for undertaking procurement activities. PIU to recruit international procurement specialist. NMSA to mobilize a procurement officer and an accountant. The government and NMSA to agree on the proposed consulting service. NMSA to obtain approvals for mobilizing the staff from Department of Personnel 2 On 13 August 2012, a COSO staff consultant provided NMSA staff with a procurement workshop.

7 5 Poor compliance: limited internal audit resources and capacity. NMSA and development partners to provide a comprehensive training program on procurement procedures. NMSA to agree to al its staff to participate in procurement training activities offered by development partners, including ADB. PIU to establish procurement procedures that are acceptable to ADB for project procurement activities. NMSA to engage an internal auditor. PIU to liaise with the internal auditor. Management and ensure budgets. NMSA and development partners to identify training needs and coordinate training program. NMSA to develop a staff development plan and commit to it. PIU to review existing procedures and improve the procedures if necessary. NMSA PIU

8 6 Appendix 1: General Procurement Environment Assessment 1. Is there a procurement law? Low.. The procurement legal framework in PNG consists of 2 main elements: Part VII of the Public Finances (Management) Act 1995 (PFMA), as amended; and Parts of the Financial Management Manual 2005 (FFM), which is part of Financial Instruction 1/2005, adopted under the PFMA. These are accompanied by a Good Procurement Manual (GPM), also adopted in Are the laws and regulations clear and concise? 3. What does the law (or regulations applicable to procurement) cover? 4. Does the law cover the procurement of consulting services? 5. Does the law differentiate between processes for consulting services and Goods/Works? 6. Does the law require advertisement of all procurement opportunities High. One of the practical difficulties with the GPM is that, while it provides useful information, that guidance is not always referable to the PFMA or FMM. The issues described there have no basis in the legal framework. High. Low. There is an absence of an appropriate procedure for consulting services. High.. Average.. 7. Are contract awards advertised? Average.. There is no reporting requirements or obligation to provide information on successful tenderers. 8. Are there restrictions on goods Average. works and services on the basis of origin? 9. Does the law or relevant legislation and regulations provide acceptable provision for the participation of state owned enterprises? 10. Are there restrictions on the nationality of bidders and consulting firms invited? 11. Are foreign bidders and consultants forced to offer through or with local partners? 12. Is there a domestic preference scheme? 13. Is there a national standard mandated for use for quality control purposes? 14. Are any agencies exempt from the High. High. There are no provisions on how State owned enterprises can participate. High. explicit mention in the legal framework of the principle of non-discrimination and no particular protection or provision for suppliers with any degree of foreign affiliation or ownership or related to their location or size. Average. Foreign bidders are encouraged to partner with local companies. Average. There is a lack of basis or authority for the application of domestic preferences and the means of applying them. Low.

9 7 law? 15. Is the default method for procurement open competition? 16. Is open procurement easily avoided? 17. Do the rules and regulations require pre-qualification? 18. Do the rules and regulations require registration? 19. Are there systematic procurement process audits? 20. Is there a national procurement manual or guide? 21. Do the laws and regulations mandate the use of standard documents? 22. Have these standard bidding document s been approved for use on ADB projects? 23. Do the regulations require the collection of nation-wide statistics on procurement? 24. Is consolidated historical procurement data available to the public? 25. Do the procurement laws and regulations contain provisions for dealing with misconduct? 26. Is fraud and corruption in procurement regarded as a criminal act? 27. Have there been prosecutions for fraud and corruption? 28. Is there an alternative disputes resolution process independent of Low.. High., through the use of Certificates of Inexpediency (COI). Low. Pre-qualification is not undertaken as it is prohibited under the PFMA. Average. High.. Government auditing arrangements are still in the process of being developed: specialized procurement audits have been undertaken by Auditor General. NMSA has no dedicated procurement unit and no internal auditor, Procurement experience in NMSA is limited. High. There are multiple manuals which are not entirely consistent. Low.. Absence of national level mandatory national standard bidding documents means that there are a number of significant issues which are either not regulated at all or regulated incompletely such as bid validity, bid securities, pricing and price adjustments, insurance, currency provisions for bidding and payment purposes, performance securities, liquidated damages. High.. standard bidding documents exist in NMSA. High.. There is no reporting requirements or obligation to provide information on successful tenderers. High., however CSTB does publish an Annual Report which contains some information. There is no reporting requirements or obligation to provide information on successful tenderers. There is a lack of or no aggregated procurement statistics. Low. The GPM includes provisions on conflict of interest and makes reference to the anti corruption provisions of the Criminal Code. Public Servants are also subject to the Code of Ethics which also deals extensively with corruption issues and conflicts of interest. These foresee disciplinary proceedings against corrupt officials including imprisonment. Low.. High.. Compliance and enforcement mechanisms are very weak. High. There is no requirement on contract dispute settlement.

10 8 government and courts? 29. Does the law al for sovereign immunity to the EA for claims against it? 30. Do the regulations al for black listing (disbarment) of firms and individuals and if they do? 31. Which body oversees procurement? 32. What powers does the oversight body have? 33. Is there a nationwide procurement training plan? 34. Is there a procurement accreditation or professionalization program? 35. Are major projects identified within an agencies appropriation or budget? 36. Is the procurement cycle tied to an annual budgeting cycle? i.e., can procurement activity only commence once a budget is approved? 37. Once an appropriation or budget is approved will funds be placed with the EA or can the EA draw them down at will? 38. Can an EA draw directly from a loan or imprest account or will it spend budgeted funds with the borrower claiming reimbursement? 39. When an EA is implementing a project using funds from the national budget has a delay in funding significantly delayed procurement? Low. Low. There are no suspension/debarment procedures. High. CSTB controls and regulates procurement, including monitoring of procurement performance and compliance. To date this has not been done due to capacity and resource constraints. CSTB is not able to oversee procurement due to its tender board role. Although the CSTB is intended to be an independent body, it falls under the Finance Department and reports to the Minister of Finance. High. High.. High. career stream for public procurement in public services. Average. Average. There is an absence of a legal requirement to carry out procurement planning (as opposed to a recommendation in the GPM). There is also no requirement to publish annual procurement plans and no other form of advance notice (disclosure). As a result, procurement planning is ineffective and the procurement plans and acquisition plans required by GPM, either do not exist or are drawn up in most instances too late (e.g. at the beginning of the year when the associated works should be carried out). NA. NA. High.

11 9 Appendix 2: Agency Questionnaire Risk Ratings Extremely High High Average Low I. Specific Assessment and Ratings Question Answer/Finding Risk A. ORGANIZATIONAL AND STAFF CAPACITY A.1. How many years experience does the head of the procurement department/unit have in a direct procurement role? There is no Procurement Department/Unit in NMSA A.2. How many staff in the procurement department/unit are: Procurement done individually by Manager Navigation Safety Department, Manager Information and Communication Technology, Senior Hydrographer, Senior Radio Inspector i. Full Time? ii. Part Time? By all above mentioned iii. Seconded? A.3. Does the procurement staff have English language proficiency? A.4. Are the number and qualifications of the staff sufficient to undertake the additional procurement that will be required under the proposed project? A.5. Does the unit have adequate facilities, such as PCs, internet connections, photocopy facilities, printers, etc., to undertake the planned procurement? A.6. Does the agency have a procurement training program? A.7. Does the agency have a Procurement Committee that is independent from the head of the agency? A.8. Does the agency have a procurement department/unit, including a permanent office that performs the function of a Secretariat for the Procurement Unit, and which serves as the main support unit of the Procurement Committee?? A.9. If yes, what type of procurement does it undertake?

12 10 Question Answer/Finding Risk Individuals under A.2. report to Executive Manager Maritime Operations, NMSA A.10. At what level does the department/unit report (to the head of agency, deputy etc.)? A.11. Do the procurement positions in the agency have job descriptions, which outline specific roles, minimum technical requirements and career routes? A.12. Is there a procurement process manual for goods and works? A.13. If there is a manual, is it up to date and does it cover foreign-assisted projects? A.14. Is there a procurement process manual for consulting services? A.15. If there is a manual, is it up to date and does it cover foreign-assisted projects? A.16. Are there standard documents in use, such as Standard Procurement Documents/Forms, and have they been approved for use on ADB funded projects? A.17. Does the ToR fol a standard format such as background, tasks, inputs, objectives and outputs? A.18. Who drafts the procurement specifications? A.19. Who approves the procurement spe9ifications? procurement positions, but job descriptions as suggested exist for staff under A.2. performing procurement tasks t with NMSA, but with Central Supply & Tender Board (CSTB) Revised last Jan Manual does not include Aid/Donor Agency procurement arrangements. If Aid/Donor Agency agreement with Government of PNG provides exemption from Public Finances (Management) Act, procurement may be undertaken in accordance with the agreement. Consequently, procedures in the CSTB Manual may not apply. Manager Navigation Safety Department, Manager Information Technology, Senior Hydrographer, Senior Radio Inspector Executive Manager Corporate Services Executive Manager Maritime Operations General Manager/Chief Executive Officer (CEO)

13 11 Question Answer/Finding Risk A.20. Who drafts the bidding documents? Manager Navigation Safety Department, Manager Information and Communication Technology, Senior Hydrographer, Senior Radio Inspector A.21. Who manages the sale of the bidding documents? CSTB A.22. Who identifies the need for General Manager/CEO consulting services requirements? A.23. Who drafts the terms of reference (ToR)? A.24. Who prepares the request for proposals (RFPs)? B. INFORMATION MANAGEMENT B.1. Is there a referencing system for procurement files? B.2. Are there adequate resources allocated to record keeping infrastructure, which includes the record keeping system, space, equipment and personnel to administer the procurement records management functions within the agency? Concerned NMSA managers, e.g., Manager Navigation Safety Dept., Manager Information and Communication Technology, Senior Hydrographer, Senior Radio Inspector Concerned NMSA managers, e.g., Manager Navigation Safety Dept., Manager Information and Communication Technology, Senior Hydrographer, Senior Radio Inspector. Records are kept individually.. Records are kept individually. B.3. For what period are records kept? Since establishment of NMSA B.4. Are copies of bids or proposals retained with the evaluation? B.5. Are copies of the original advertisements retained with the precontract papers? B.6. Is there a single contract file with a copy of the contract and all subsequent contractual correspondence? B.7. Are copies of invoices included with the contract papers? C. PROCUREMENT PRACTICES Goods and Works

14 12 Question Answer/Finding Risk C.1. Has the agency undertaken foreign-assisted procurement of goods or works recently (last 12 months, or last 36 months)? (If yes, please indicate the names of the development partner/s and the Project/s.) C.2. If the above answer is yes, what were the major challenges? C.3. Is there a systematic process to identify procurement requirements (for a period of one year or more) C.4. Is there a minimum period for preparation of bids and if yes how long? C.5. Are all queries from bidders replied to in writing? C.6. Does the bidding document state the date and time of bid opening? C.7. Is the opening of bids done in public? C.8. Can late bids be accepted? C.9. Can bids be rejected at bid opening? C.10. Are minutes of the bid opening taken? C.11. Who may have a copy of the minutes? C.12. Are the minutes free of charge? C.13. Who undertakes the evaluation of bids (individual(s), permanent committee, ad-hoc committee)?. AusAID: Upgrade of Global Maritime Distress and Safety System (GMDSS), 2011/2012 Preparation of specifications; procurement processes; Lease agreements with Telikom; Logistics: access to site and availability of helicopters. CSTB, NMSA, Bidders yes For NMSA: Permanent committee members: Executive Manager Corporate Services, Executive Manager Maritime Operations, Manager Navigation Safety Department. Ad-hoc/temporary committee member: Principal Legal Officer

15 13 Question Answer/Finding Risk Executive Manager Corporate Services: financial matters, specifications; Executive Manager Maritime Operations: technical and financial matters/ specifications; Manager Navigation Safety Department: Technical matters/specifications. C.14. What are the qualifications of the evaluators with respect to procurement and the goods and/or works under evaluation? C.15. Is the decision of the evaluators final or is the evaluation subject to additional approvals? C.16. Using at least three real examples, how long does it normally take from the issuance of the invitation for bids up to contact effectiveness? C.17. Are there processes in place for the collection and clearance of cargo through ports of entry? C.18. Are there established goods receiving procedures? C.19. Are all goods that are received recorded as assets or inventory in a register? C.20. Is the agency/procurement department familiar with letters of credit? C.21. Does the procurement department register and track warranty and latent defects liability periods? Consulting Services C.22. Has the agency undertaken foreign- assisted procurement of consulting services recently (last 12 months, or last 36 months)? (If yes, please indicate the names of the development partner/s and the Project/s.) C.23. If the above answer is yes, what were the major challenges? C.24. Are assignments and requests for expressions of interest (EOIs) advertised? C.25. Is a consultants selection committee formed with appropriate individuals, and what is its composition (if any)? Evaluators is forwarded to NMSA Board for approval/decision. Rehabilitation of 63 navaids: 5 months Installation of 3 tide gauges: 6 months Installation of Maritime VHF Communication Network: 13 May 2011 t at NMSA; Done by contractor. t at NMSA; Done by contractor., done by contractor. Procurement Department exists Activities done by individuals mentioned under A.2., but procurement of consulting services from own resources., through CSTB

16 14 Question Answer/Finding Risk C.26. What criteria is used to evaluate EOIs? C.27. Historically, what is the most common method used (QCBS, QBS, etc.) to select consultants? C.28. Do firms have to pay for the RFP document? C.29. Does the proposal evaluation criteria fol a pre-determined structure and is it detailed in the RFP? C.30. Are pre-proposal visits and meetings arranged? C.31. Are minutes prepared and circulated after pre-proposal meetings? C.32. To whom are the minutes distributed? C.33. Are all queries from consultants answered/addressed in writing? C.34. Are the technical and financial proposals required to be in separate envelopes? C.35. Are proposal securities required? C.36. Are technical proposals opened in public? C.37. Are minutes of the technical opening distributed? C.38. Do the financial proposals remain sealed until technical evaluation is completed? C.39. Who determines the final technical ranking and how? C.40. Are the technical scores sent to all firms? C.41. Are the financial proposal opened in public? C.42. Are minutes of the financial opening distributed? C.43. How is the financial evaluation completed? C.44. Are face to face contract negotiations held? C.45. How long after financial evaluation is negotiation held with the selected firm? C.46. What is the usual basis for negotiation? C.47. Are minutes of negotiation taken and signed?

17 15 Question Answer/Finding Risk C.48. How long after negotiation is the contract signed? C.49. Is there an evaluation system for measuring the outputs of consultants? Payments C.50. Are advance payments made?, usually 10 % C.51. What is the standard period for payment included in contracts? 30 days C.52. On, how long is it between receiving a firm s invoice and 1 week making payment? C.53. When late payment is made, are the beneficiaries paid interest? D. EFFECTIVENESS D.1. Is contractual performance systematically monitored and reported? D.2. Does the agency monitor and track its contractual payment obligations? D.3. Is a complaints resolution mechanism described in national procurement documents? D.4. Is there a formal non-judicial mechanism for dealing with complaints? D.5. Are procurement decisions and disputes supported by written narratives such as minutes of evaluation, minutes of negotiation, notices of default/withheld payment? E. ACCOUNTABILITY MEASURES E.1. Is there a standard statement of ethics and are those involved in procurement required to formally commit to it? E.2. Are those involved with procurement required to declare any potential conflict of interest and remove themselves from the procurement process? E.3. Is the commencement of procurement dependent on external approvals (formal or de-facto) that are outside of the budgeting process? E.4. Who approves procurement transactions, and do they have General Manager/CEO procurement experience and qualifications?

18 16 Question Answer/Finding Risk E.5. Which of the foling actions require approvals outside the procurement unit or the evaluation committee, as the case may be, and who grants the approval? a) Bidding document, invitation to pre-qualify or RFP, CSTB b) Advertisement of an invitation for bids, pre-qualification or call for, CSTB EOIs c) Evaluation reports d) tice of award, CSTB e) Invitation to consultants to negotiate f) Contracts E.6. Is the same official responsible for: (i) authorizing procurement transactions, procurement invitations, documents, evaluations and contracts; (ii) authorizing payments; (iii) recording procurement transactions and events; and (iv) the custody of assets? E.7. Is there a written auditable trail of procurement decisions attributable to individuals and committees? (i) Project Officer (ii) General Manager/CEO (iii) Finance Manager (iv) Project Officer II. General Ratings Criterion Risk A. Organizational and Staff Capacity to B. Information Management C. Procurement Practices to D. Effectiveness E. Accountability Measures OVERALL RISK RATING