2024

ANTI-CORRUPTION COMMISSION OF SIERRA LEONE

An independent institution established for the prevention, investigation, prosecution and punishment of corruption, corrupt practices and to provide for other related matters. 

Contact us on: +23278832131 or info@anticorruption.gov.sl
Address:  Integrity House, Tower Hill, Freetown Sierra Leone, West Africa.

System & Processes

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1. 0 R E V I E W O F T H E P R A C T I C E S A N D P R O C E D U R E S O F T H E N AT I O N A L T E L E C O M M U N I C AT I O N ( N AT C O M ) S I E R R A L E O N E

46. 45 • Professional fees The table below shows comparative analysis of budget line items as compared with actual and total amount on payment vouchers to ascertain the variances for FY 2019 .

5. 4 15.0 REGIONAL OFFICES ....................................................................................... 84 15.1 Staff Composition and Functionalities ................................................................. 84 15.2 Budgetary Support to the Regions ..................................................................... 86 15.3 Monitoring, Surveillance and Outreach Activities. .................................................. 86 15.4 Regional Office Fuel and Petty Cash .................................................................. 87

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92. 91 Vision: A corrupt free Sierra Leone which will ensure that the Socio - economic needs of its citizens are met. Mission: Leading the fight against corruption through Public Education, Prevention, Enforcement and compliance for the benef it of all ci tizens. Core V alues: Ø Integrity Ø Professionalism Ø Coalition building and partnership

14. 13 The Review Team observed that the loan repayment agreement was prepared by UADF instead of NATCOM. The Review Team could not identify any member NATCOM being part of the agreement as signato ry. The amount stated as monthly repayment was too small because it would take UAFD over five years before the loan was fully repaid, even if they had honored their agreement. No evidence was provided to show approval from the Board for the gra nting of t he loan and the writin g off of the loan as bad debt. • The Management of NATCOM should stop treating the item as expense but rather a long - term loan as there was an agreement of repayment. • T here should be a comprehensive loan policy • The Interna l Audit D e partment should conduc t a full - blown investigation on the entire loan process.

31. 30 Protection Agency (EPA) to develop policy that would guide the security and operations of all activities of the Commission. 5.10.1 Annual Work Plan Findings During the period under review, it was observed by the Team that, the Unit ha d never de veloped an Annual Work Plan. Implications Lack of an Annual Work Plan may not provide clear directions by the Unit and that will automatically impede achievement of the Commission’s goal. Also, it signified that all activities were implemented b ased on ne ed and in a haphazard manner. Recommendation It is recommended by the Review Team that, an Annual Work Plan be formulated by the Unit indicating list of activities, timelines and budget consideration. Management response The unit has developed an annual work plan which is now effecti vely in use. 5.10.2 Annual Activities Report Findings In the course of the review, the Team clearly found out that there had not been a single annual report prepared by the Unit illustrating yearly successes. I mplication Failure to provide an annual activity report can make it very difficult to map out progress made by the Unit at a given period. Recommendation It is recommended by the Review Team that going forward; the Unit should prepare an annual activity r eport that would capture trends of activ ities implemented according to the Annual Work Plan. Management response Recommendation noted.

89. 88 Implications • Delay in replenishment would undermine the effective running of the office. • A single individual co ntrolling pe tty cash without a Finance Officer would lead to abuse or corruption. • Five million Leones (Le5,000,000) for fuel was not sufficient for the effective running of the offices especially against the backdrop of current fuel price rise and the dist ribution quo ta particularly f or districts without electricity or those seriously challenged for electricity was not realistic.. • Lack of contractual agreement leaves both parties vulnerable to abuse . • Unsigned sheets were indications of dubious acts. This al so went for sheets that were intact while the supplies had been delivered . Recommendations All petty cash should be properly managed and accounted for. The petty cash fund should undergo periodic reconciliations, with transactions also recorded on the financial s tatements. Mana gement Response • Recommendation is noted and action will be taken accordingly. • Nonetheless, it is mandatory by the Zonal offices to submit monthly reconciliation report on the usage of the petty cash and fuel for replenishment . • The said F inance R econcil iation R eport is mostly done by the General Service Office (GSO) who is assigned to provide financial assistance to the zonal office respectively .

77. 76 12 .3 Qualification of Storekeeper Storekeeping is a delicate job that required tr ained and qualifi ed personnel to undertake such tasks. However, the Team observed that the Storekeeper had no knowledge or the pre - requisite qualification for discharging his duties. Implication Lack of a trained and qualified storekeeper wo uld hinder e fficient and effe ctive service delivery in storekeeping. Recommendation Management should ensure that the storekeeper be provided with the required training in the discharge of his functions for effective and efficient service delivery. Mana gement Respo nse Management h as already identified a training and development plan for the Storekeeper to enhance his skills and competence to perform his duties effective. Additionally , a succession planning for the said position has been established in a n event when the staff is ill , on leave or retired etc. 1 2 .4 Monitoring and Supervision Findings The Review Team observed that there was less and/or no supervision on the activities of the storekeeper. At the time of the review, documents relating to the review s cope were not pro vided, so the Team took samples of store documents for 2021. The following irregularities were captured from samples of store vouchers inspected as follows: • Items supplied that were never approved by both the requesting departm ent and the issuing departmen t as shown below : .

79. 78 The above tables show poor monitoring and irregularities in store requisition and issuing procedures. It was evident that the storekeeper had been issuing out goods fr om the store with out approval from his supervisor in one instance or approval by the head of department in another. Moreover, there were series of contraventions from modern day’s stores management on the sides of the Commission as items reques ted were dea lt in directly wi th the storekeeper who then made the issue without following the due procedures. The Team also observed that all requisition vouchers inspected bore the same serial number of 01349 , which implied that the requisition and issue vouchers wer e not sequentiall y numbered and /or the same voucher was used to request for multitude of heterogeneous items from the store. Furthermore, there was no policy on store management procedures Implication Lack of proper monitoring and supervisio n in stores management can le ad to poor performance and would create opportunities for pilferage or wrong handling of items. Additionally, using different requisition vouchers bearing the same serial numbers of 01349 for multiple requests was tantamount t o misappropr iation, and waste of the Commission’s resource Recommendation The Management of NATCOM should ensure that the storekeeper follows the due processes on store requisition and issues. Moreover, the Commission should develop a policy on stores ma nagement and ensure it strict adherence. Also, Management should investigate the consistency in the serial number to prevent fraud. Management Response Recommendation noted for appropriate action 1 2 .5 Store Bin Card The Team observed that the storeke eper never m aintained and / o r worked with a store Bin Card. Even though there was a store requisition and issuing voucher, yet stocks were inaccurately recorded and distributed. This tool enabled the storekeeper to be accountable and maintain records on every item i n store for ease of reference.

76. 75 The Team also realized that most items procured did not go through stores as they were delive red directly to t he end user(s) and the store keeper took charge later. Limitation • As a result of the limited storage space, items stored may become damaged, destroyed or cause stored items to deteriorate. • By passing the normal store procedure affects the entire inventory process as there were all indications and /or possibilities that the store keeper will not take accurate records of items. Recommendation Management should ensure that a secured, conducive location is provided as storage to e nable free mo vement and docume ntation of materials. This would enable materials to be easily traced. Management Response Management has already made provision for bigger storage space in the new Commission building to enable free movement and documentati on of materia ls. All other rec ommendations are highly noted. 1 2 .2 Staffing Storekeeping is a delicate job and required more than one personnel to undertake such task. However, it was realized that the Storekeeper had no deputy and /or assistant in disc harging his d uties. Implicat ion The absence of an Assistant storekeeper would stall the entire work process as there will be no assistance to help in that direction. Recommendation Management should ensure that the Storekeeper is provided with store cle rks to assist the store keeper in the discharge of his/her functions for effective and efficient delivery of service. Management Response Recommendation noted for appropriate action

26. 25 chart were not clearly defined and erroneous. It clearly showed a possible need for expansion and edit ing. For example, the Human Reso urces and Administrative Departments is clustered with many Units which were supposedly to be a stand - alone and /or separated but they report to the Director of Human Resources and Administration. Implication It would lea d to confl icts in reporting. Rec ommendation The Commission should immediately review its Organizational structure by separating clustered departments distinctly showing reporting lines. Management Response Recommendation is noted and action will be tak en accordi ngly . 5. 6 Board Stru cture Findings The Board lacked the necessarily structures (Board Committees) such as Audit Committee, Board Appointment Committee and Remuneration Committee which are relevant for an independent and a strategically focuse d Board. Implications Without th ese structures the Board’s ability to make an independent, reliable, expert and professional decision will be undermined. Recommendations We recommend that these structures which enhanced corporate governance be establishe d and are given the free hand to advice on decision making processes which are related to the relevant structures. Management Response Recommendation accepted in good faith . The Board already has sub - committees and will put into practice in setting up the necessary committees as prescrib ed .

24. 23 Implications • Failure to conduct a due diligence correctly in the commencement of its Management can be a violation of the fiduciary duty of Management to the Government. • There were strong indications that the tra nsition pe riod created conduciv e environment for misappropriation of funds. Recommendations • The current Management should conduct a thorough stock taking of the Commission and present a detailed report on the transition detailing cash and bank balances, d ebtors and creditors, assets and their net worth. • Any instance of misappropriation or corruption during the transition should be investigated by ACC . Management Response Recommendation noted for appropriate action 5.3 Strategic Plan F indings The Revie w Team obs erved that was an exist ing five year strategic plan (2017 - 2021) and that the Commission had already commenced the development of the (2022 to 2027) Strategic Plan which was currently in the draft stage. I mplication Having a strategic plan in pl ace enable d and/or provided a sen se of direction to the Commission to outlined measurable goals and for the Commission to track progress towards goals. Recommendation The Management of the Commission should ensure that activities in the strategic plan (20 17 - 2021) a re exhaustive and attai ned within the time frame. Also, the draft Strategic Plan should only be operational in the prescribed year. Management Response Recommendation is noted.

52. 51 Management Response • The Admin and HR department have and has maintained a proper filling system in which we have filling cabinets within the Department that has stored and maintain ed h ardcopies documen t in a much more secured and safer way. • However, due to insufficient space within the department and the HQ office as a whole , the Commission does not currently have specific archive room to store hardcopies documents for the entire offic e. • Nevertheless , the Commission has already made provision for archive room in the new NATCOM building. The Admin and HR management team is currently working to develop policy on Records Management which will cover both soft copies and hard c opies docume nt and the period at which they are to be kept within the office and the achieve room. 9 . 4 Staff List F inding Examination of the payroll and staff list showed variances between the two documents. The table below shows names of staff that are on the payroll but not o n staff list Staff Khadijatu Haja Abdul - Tejan Mustapha Kawa Hassanatu Kanneh Furthermore, the under mentioned names were on the staff list but not on the payroll provided to the team. Staff Marian N. Yarjah Magdalene W illiams T here were also ob served discrepancies in the way names were spelt and recorded as illustrated in the table below .

32. 31 5.10.3 Policy /Regulation Development Findings • The Team was informed that five (5) policies/ regulations had been developed by the Unit together with oth er department in 2020 It went through Parliamentary approval and became statutory instrument so that, the Unit can regulate mobile network operators and guide their daily operations in providing quality telecommunica tion servi ces for the masses. • However, these policies were not presented for verification and there were no indications that they were being implemented. Implication Lack of full implementation of most of these policies may undermine quality telecommunic ation serv ices. Recommendation The Rev iew Team recommends that, all the policies developed and enacted through Parliament should be fully implemented to regulate mobile network operators and boost quality telecommunication services. Management response Recommenda tion noted. 6.0 FINANCIAL M ANAGEMENT Section 17 (1) of the Telecommunications Act 2006 states that “The Commission shall keep proper books of account and proper records in relation to them in a form approved by the Auditor - General.” 6.1 Fin ancial Pol icy and Procedural Manual Fin dings The Review Team was not provided with any financial manual of the Commission for the period under review despite the fact that, they work in line with the statutory financial instruments in carrying out their d uties. The team was informed of a financ ial manual which was in a draft stage commencing 2021, but yet to be verified by the team.

64. 63 • Also, Management must ensure that the Procurement Unit is directly supervised by and/or reports to the vote controller, rath er than to t he Director of H uman Resources and Administration. Management Responses • The Director General, summoned the Procurement unit together with Members of the Procurement Committee insisting and reiterating the provisions of the public Procurement Act 2016 as amended that sti pulates that the Procurement unit reports to the vote controller. • The Recommendation is noted that Procurement unit should be a standalone unit as stipulated by the PPP Act 2016 as amended. 11 .4 Staff Capacity Section 16 (1) of the Procu rement Regulatio n 2020 states that “A Procurement Unit and a subsidiary Procurement Unit shall report to a subsidiary Procurement Committee or to a Procurement Committee through the main Procurement Unit.” Also, sub section (4) states that “A P rocurement U nit shall includ e staff with appropriate technical skills and where a procuring entity has significant volume of specialized procurement or procurement activity requires significant technical input.” Additionally, sub section (5) stipulates th at “Staff of a procurement u nit shall be appointed in accordance with the normal procedures applicable to a procuring entity, taking into account the certification and approval requirements issued by the Authority.” Section 17 (1) of the National Public Pro curement Act (NPPA) 2016 sta tes that “Procurement - related functions shall be carried out by procurement persons, trained, and knowledgeable in accordance with the guidelines, and qualification requirements established by the Authority.” Also, Section 19 (1 ) of the Pub lic Procurement Act 2016 states that “A Procurement Unit shall be established in each procuring entity, staffed with persons trained and knowledgeable in procurement and charged with carrying out, on a continuous basis, fun ctions related to pro curement”. Finding(s) The T eam observed that of the three (3) staff in the Unit, only the Procurement Officer has vast and experienced in Procurement while the other two (2) staff acquired their Procurement training from NPPA. Implication(s)

63. 62 Recommendation • The Management of NATCOM should ensure that the Procurement Committee restore full commitment in discharging their duties and ensure that all procurement activities foll ow the due p rocesses as dema nded by law to promote transparency and accountability in public procurement of goods, services and works. • Furthermore, Management should certify that the Procurement Committee members sign attendance list and Minutes according ly in respec t of any bid ope ning and/or evaluation process. Management Responses • The Commission’s Procurement Committee is Functional and it does meet whenever there a major Procurement decision to be made. • We will ensure that all Minutes and attendan ce of Procur ement Committee meetings are signed accordingly. 11 .3 Procurement Unit Section 19 of the National Public Procurement Authority Act of 2016 stated that, “ a Procurement Unit shall be established in each procuring entity, staffed with persons t rained and k nowledgeable in procurement and charged with carrying out, on a continuous basis, functions related to procurement .” Finding • The Review Team observed that there was a Procurement Unit established at NATCOM but attached to the Administration an d Human Reso urces Department . • However, the Team realized that the Procurement Unit report was supervised directly by the Director of Human Resources and Administration, who happened to be an active member in the Procurement Committee. Implication Since th e Procuremen t Unit is direct ly under the supervision of the Administration and Human Resources department, it meant that the Unit did not have total control over its mandate and there was possibility of influence. Recommendation • The Management of NATCOM s hould ensure that the Procur ement Unit is detached from the Administration and Human Resources department and be a standalone unit.

30. 29 up to Le200,000,000.00 (Two Hundred Million Leones) for advice and/or for giving an opinion in a given case, unlike what Retainers a re paid ye arly. • There are currently four (4) pending matters in the High Court for the Commission and our Retained lawyers have been actively attending on each hearing. Thus, if put on a case - by - case basis, the litigation cost will amount to or exceeds Le 200,000,00 0.00 (Two Hundred Million Leone s) per case, since these are High Court matters. Furthermore, Retainers can be called upon anytime within twenty - four (24) hours for advice by NATCOM and shall be readily available for that purpose. • To reiterate, NA CTOM curre ntly has four pending matters i n the High Court all attended to by our Retainers. • The Legal Department was never visited for verification/clarification of certain issues since the Team’s attendance at the Commission. Such, we find this amazing as to where this perception derived from. T here is an existing retainership agreement between NATCOM and our Retained lawyers and available for view on request. • There are amendable options for the department to increase its staff level to five (5) and above. But this is not viable without considera tion of Retained lawyers. There will also be cost implications as these staff will be employed at senior management level (deputy directors), with salaries and associated benefits of deputies, costing over Le1.5 bi llion Leon es per year. This is the reason for the retention of Retainers as cost of Retained lawyers on yearly contracts is far less than fortifying the department with more staff. The current staff act as a backup and liaison officers between the Commiss ion and th e Retainers. • There are existing annual review reports for years 2020/2021 respectively but never requested for by your Team. 5.10 Policy and Governance This directorate was established in June 2019 to replicate what other sister regulators in the sub - re gions of West Africa were doin g in terms of policy and governance relations. The major mandate of the Unit are to liaise with Ministries, Departments and Agencies (MDAs), mobile network operators and District/City Councils to resolve issues relat ing to roy alties at community level and ensure coordination and supervision of regulatory services. Additionally, this Unit leads the formulation of Memorandum of Understanding (MoU) and work with mobile operators, television operators, MDAs especially t he Environ mental

65. 64 Without the requisite sk ills effectivene ss and efficiency will be adversely affected. Recommendation(s) Staff in the Procurement Unit needs to be trained (upgraded) by Management in procurement processes. Management Responses • Staff of the Procurement unit together with a staff from Admin and Finance Department underwent a training session organized by NPPA. • However , the Procurement unit staff really needs contemporary upgrade on processes and procedures, ethics, Project Management, Contemporary procedures and approa ches, negoti ation skills and many more. 11 .5 Records Management (Filing System) Section 32 (1) of NPPA 2016 states that the procuring entity shall preserve all documentation relating to the procurement processes, in accordance with applicable rules conce rning archiv ing of governmen t documentation, but at a minimum for a period of six years following the date of final completion of the procurement contract, or from the date of rejection of all bids or cancellation of the proceeding, as the case may be. Fi nding(s) • The Team observed i n relation to the above section that proper filing system of procurement documents were not maintained. The Team also observed that procurement documents were all bungled up in files rather than it being separated and filed as W orks, Servic es and Goods. • Ad ditionally, the Team observed that the Procurement Unit did not keep copies of procurement documents as they relied on the file copies at the Finance Department. Implication(s) Inappropriate and incomplete filing of procurement documents m ay lead to cumbe rsome retrieval of documents with maximum tendency to encourage unauthorized access to records by other officials which can subject the institution to security breach, physical damage, loss of credibility and confidentiality. Recommendati on( s ) The Procur ement Unit must retain and maintain appropriate filing systems and/or records management to ensure effective storage, retrieval and use of records with due regards to security, integrity and confidentiality.

61. 60 they are requ ired. A good procurement pla n will describe the process in the identification and selection of suppliers/contractors/consultants. According to Section 29 (1) of the NPPA 2016, all procuring entities shall undertake procurement planning, with a view to achi eving maximu m value for publ ic expenditures and the other objects of this Act. Finding(s) • The Review Team was presented with the Procurement Plans 2018, 2019 and 2021 as prescribed by S29 (2) above. • However , it was observed that the 2019 and 2020 plans were exactly the same. It wa s highly unlikely that an institution of this nature would have the same procurement plan for two consecutive years. It suggests that much effort has not been placed in preparing the annual procurement plan. Implication The abs ence of a we ll thought out P rocurement Plan would prevent the Commission from prioritizing its procurement needs and achieving value for money. Recommendation(s) The Procurement Officer should prepare a standardize procurement plan as prescribed by the Ac t. Managem ent Responses • T here is an existing annual procurement plan of which the Procurement unit which it uses to execute the Commission Procurement Activities. • The procurement plan for 2019 and 2020 are totaling different, the activities might appea r the same for goods and s ervices but with different amounts, procurement methods and threshold are attached 11 .2 Procurement Committee Section 18 (1) of NPPA 2016 states that “a Procurement Committee shall be established in every procuring entity”. Also, accord ing to S18(8 ) ‘ a Procurement Committee shall make necessary arrangements to ensure that timely information on the execution, and conclusion of contracts by a Department or Division of a procuring entity,

23. 22 Management Response The Internal Audit Department functionally report directly to the Board and a dministratively to management. 5.0 CORPORATE GOVERNANCE 5.1 Handing Over Notes/Status Report Finding s The cur rent Management was ap pointed in 2018 after the national Presidential and Parliamentary elections. The Review Team enquired about the handover process by the previous Management. No detailed handover notes / status reports from the previous Manag ement were presented to the Revi ew Team. The previous Management failed to properly give an account of its stewardship and the status of the company at the time of leaving office. On the other hand, the current Management was complacent in ensuring that there was a proper handover proc ess. Implications Handing over ensures ease of transition. Without a proper transition, the Commission is vulnerable to misappropriation. Recommendations A mechanism should be put in place for a detailed handing over note to be prov ided to the Internal A udit Department by any administration in the event of a transition. Management Responses Recommendation noted and the Commission will follow the due process. 5.2 Due Deligence on Natcom b y the Current Management Finding s The cur rent Management failed to perform due diligence or stock taking on NATCOM when taking over from the previous m anagement. Even the assets of the Commission were not verified and details of cash and bank balances at the time of taking over were n ot made av ailable to the Review Team.

54. 53 • The Review Team was not provided with printed copies of the Biometric registration and the manual method (ledger) to ascertain recording of staff attendance, punctuality and movem ent. • The Rev iew Team was not presented with any evidence that there was a mechanism in place to generate reports from the ledger or the biometric registration for monitoring purposes that would ensure appropriate actions were taken where necessary. Implic ations Witho ut an effective s ystem to monitor staff regularity, staff will be paid for work not done. Recommendations • Management should ensure that they establish an effective system of staff attendance register. Monthly reports should be generated and mo nitored. • The Human Resources Department should ensure that staff movements are captured in the Biometric system and not just limited to clocking in when reporting for duty. • Management should also consider reinstituting the biometric registration systems as covid 19 re strictions are gr adually lifted Management Response During the peak of Covid19 pandemic in Sierra Leone, the Commission’s senior management team made a resolution to stop the use of the Biometric registration during the peak of Covid19 pandemi c to avoid p hysical contract. Nevertheless, a manual method (ledger) was adopted as an alternative to record staff attendance as well as to determine punctuality and staff movement. Evidence of staff attendance book is available for the said period for fu rther assess ment. The Commis sion has reinstated the use of biometric registration system immediately after the lifting of Covid19 restrictions. The departmental quarterly report covers staff attendance. As recommended, forthcoming, a monthly notification will be pro vided to all empl oyees who constantly report to duty late without reasonable justification. 9 . 6 Performance Appraisal F indings • According to the Performance Management Policy of NATCOM , “The Commission shall conduct a Performance Review twi ce per year for each employee . A review may

22. 21 Recommendation • The Human Resource Department must ensure that adequate staff are recruited for the Audit Department with the prerequisite qualifica tions and experience. • Additionally, it is recommended that capacity building should be extended to the two - support staff of the Audit Department to enhance their productivity in discharging their duties. Management Response With the Commission becoming a n Authority which will eventually lead to expansion of it functions. The recommendation is welcoming as the department will need additional staff more especially Senior Audit Manager and Audit Manager to meet the expansion needs by the Authority. 4.7 Rep orting Line of the Int ernal Auditor Internal Auditors are required to report functionally directly to the Board , or a sub - committee of the Board (the Audit Committee), and not to Management except for administrative purposes. However, there are certain t hings that Internal Au dit should report to Senior Management of an entity on performance evaluation for instance staff annual increment. Finding(s) The team observed that the Internal Audit Department reported to the Audit and Finance Committee, and Manag ement. Implication • I f Internal Auditors should report directly to the head of entity, it would affect their independence and objectivity of their work. • Failing to report directly to the Audit Committee makes the work of the Internal Audit Depa rtment bec omes meaningless as it would be compromise d by Management. Recommendation The Director of Internal Audit and Risk Management should ensure they report directly to the Audit Committee so as to avoid conflict of Interest, maintain objectivity and their ind ependence in the disch arge of their duty.

56. 55 Recommendation The Human Resources Manager must ensure all staff files were regularly updated and all gaps identified by the team are regularized. Management Response Recommendation is noted and action will be taken accordi ngly . 9 . 8 Staff Qualification Finding • In the process of comparing staff prerequisite and/or qualifications to their positions, the Team observed that most staff did not have the required qualification(s) that best suited th eir position s. • The Team also observed that some staff qualifications did not match with the wor k designated. Implication • Inequalities between job designed and qualification would affect the growth of the organization and hence marginalization, policy bre ach and demo nization will be on the rise. • Also, hiring unqualified staff would affect the company’s goodwill, market value, work system and would lead to poor decision - making skills. Recommendation • The Management and the Board should ensure a comprehensi ve Human Res ource Audit is co nducted by the Internal Audit Department. Moreover, the HR should ensure that all staff should submit their original qualifications for verification. • Also, the HR Unit should ensure, employees whom are without the prerequisite qualificatio ns for their resp ective positions are to be trained on the job and/or provided trainings. Management Response Recommendation is noted and action will be taken accordingly. Nonetheless, a comprehensive training and development plan for all staf f has been d eveloped to ensur e employees skills and competences are set to achieve the aims and objectives of the Commission.

67. 66 The inconsistencies were occurred when Request for quotations were used on several occasions but presently the Co mmission debr iefs all unlucky suppliers respectively in writing upon conclusion of the process. 11 . 7 List of Supplier/ Vendors Supplier’s evaluation is the process of evaluating ( scanning) and approving potential suppliers by quantitative assessment. This is to ensure a portfolio / or data of best - in - class suppliers are available for use. Choosing the right supplier depends on a wide range of factors such as va lue for money , quality, relia bility, and service. Finding(s) • The Procurement Unit has a Suppliers’ Data, or Vendors List, which is an acceptable practice in procurement. • The Team however observed that the Procurement Unit at NATCOM had supplier database but that a ch unk of the vendo rs that made up the list were supplied to the Commission by NPPA. Implication(s) The Procurement Unit of NATCOM may not have profound supervision and control over the suppliers acquired from NPPA. Also, it may not help the C ommission in structuring the supplier base and improving the efficiency of the supply chain. Issues of conflict of interest may arise in these kinds of arrangements. Recommendation The Procurement Unit should have an effective supplier database for ease o f reference f or the procureme nt of goods and services. Also, the Procurement Unit should advertise and recruit their own vendors based on technical qualifications. Management Responses • On a yearly basis the Commission disseminates advertisement sourcin g suppliers for goods works and service but at the end the turnout is unusually very low. • The Public Procurement Manual 2020 2 ND edition states that NPPA should have a masters Supplier database and secondly it also states that you can acquire a supplier’s database fro m any establishe d institution. eg Nassit ,NRA

42. 41 Implication Limited or no input of lower cad re staff o f all departments in the budgetary process may lead to unrealistic budget. Recommendation The Management of the Commission must ensure that the budgetary participatory process is inclusive of both Management and lower - level staff. Management R esponse Th e Commission noted the co ncern of ACC Recommendation and we shall adhere to it. 8 . 2 Budget Committee A Budget Committee is an official group that creates and oversees the standards and best practices to implement and update an organization's spending a nd resource allocation pl ans while maintaining fiscal responsibility. Budget Committees play a key role in the success or demise of a company or other entities that rely on generating and spending cash flows in order to remain operational. Fin dings ▪ Ther e was no evidence to show that an independent Budget Committee to guide and regulate the budget process for the periods under review. ▪ A Minute of a Finance and Budget Committee was presented to the Review Team to show that such Committee existe d. ▪ Howeve r , the effectiveness of t he Committee was not guaranteed as no policy or terms of reference with regards it operations were presented to the Review Team. • Furthermore, there was no evidence to show that there was an assigned and/or stationed budge t officer from the Budget Bureau of the MoF to guide the budget process. Implication Without a functional Budget Committee, the budget process will be difficult to achieve and there maybe challenges in aligning and/or incorporating activities from the Str ategic Pla n.

27. 26 5. 7 Board Remuneration/Expenses Findings • The Board Remuneration was determined by State House. There was no given format or policy on how the remunerations were determined. Further it was unclear as to what constitu ted legiti mate expenses of the Bo ard that should be funded by the Commission. • Consequently, the Review Team observed that there were no budget line for the Board activities and it was also observed that most of the funded Board activities had no bearin g to the w ork of the Commission. Implications Without proper guidelines on Board remunerations and expenses, funding of Board activities was open to abuse. Recommendations • A policy on Board remuneration and what constituted legitimate expenses of the Bo ard should be developed and stric tly implemented by the Commission. • Management should ensure that Board activities were properly planned and budgeted for and should be related to their function and the Commission. Management Response The issue of remuner ation is b eyond the Board’s contr ol but all other recommendations will be strictly adhered to. 5. 8 Development of Regulatory tool Findings The Act mandates the Commission to develop a number of regulations in order to effectively regulate the telecommu nication i ndustry. The Review Tea m observed that the Commission failed to provide any evidence that this had been done. Implications Failure to develop the necessary regulations as provided by Section 9 of the NATCOM Act created a situation where discreti onary deci sions are made in Regul ating the Industry. This i s Prone t o Corruption.

33. 32 Implication • In the absence of a financial policy and procedural manual adopted, Management and Board members likely to ope rate under a set of assumptions and disc retions that may or may not be accurate or productive. • The financial management, risk the mitigation and the alignment of financial operation with the overall mission of the organization will be distorted. Recomme ndation Th e Management of NATCOM should ensure that a financial manual policy and Procedural manual is established and if so, the draft financial manual should be finalized and effected. Management Response The draft Finance manual has been approved, impl emented an d available for inspection. 6.2 Area of Focus: Petty Cash Findings • The team observed that petty cash float was allocated to the various departments at the head quarter in the tune of ten million (Le10,000,000) Leones and five million (Le5,0 00,000) Le ones to e ach regional office o n a replenishment basis and /or impress system . • Nevertheless, no policy on petty cash disbursement was presented to the team, though monthly reconciliation and/or retirement are done before a float was given. There were also delays in reimbursement of fl oats. Implication ▪ The absence of a petty cash policy would prevent the Finance Department to balance the need for effective control over acquisition of goods and services of low value. ▪ Delay in reimbursement affect ed timely implementation of activities. Recommendation The Management of NATCOM should en sure a policy on petty cash is effective and reimbursement should be timely.

34. 33 Management Response ▪ The policy on petty cash disbursement is included in the finance ma nual and i ts implementation has been op erational prior to the manual’s approval. Training has a lso been done on petty cash management ▪ The delays on the disbursement process have been minimized and the finance department will ensure that reimbursement will be timely in due course. 6.3 Area o f Focus: Revenue Generation Section16 (1) of the Telecommunications Act of 2006 states that “ The activities of the Commission shall be financed by a fund consisting of – (a) moneys appropriated by Parliament for the purposes o f the Commission; (b) moneys accruing to the Commission in the course of its operations, including license fees, fines and other monetary sanctions imposed by the Commission; and (c) loans obtained from reputable financial institutions .” Further more, Sect ion 11A (f) of the Telecommun ications Act (Amended) of 2009 states “ by the insertion after subsection (3) of Section 16 of the following subsection (4) the moneys accruing to the Commission under paragraph (b) of subsection (1) shall be divided a s follows: a) One - third for the financin g of the activities of the Commission b) One - third for the purchase of equipment and other capital expenditures, and c) One - third to be collected by the National Revenue Authority and paid into the Consolidated Fund. Ther efore, in assessing the implementation of the above provision, the following were observed: Findings The table below shows the various revenue streams and respective revenue generated for the period according to Commission’s Financial Statement and Budget Analysis:

59. 58 Implication Proper monitoring, evaluation and control of fleet cannot be carried out effective ly and effic iently as it shou ld be the case when there is no yardstick and standards for comparison, regulating and making informed judgment on fleet management procedures. Recommendation(s) • Accountable tools such as Logbooks, Vehicle Movement Register /Tracking Sy stem, Vehicle Req uest Form, Maintenance Reporting Template etc. should be developed by the Fleet officer and be operational at all levels of the Commission. • The fleet officer should ensure that files are maintained for vehicles • A credible data base of all automobiles under the purview of Commission should be developed, and regularly updated. • The Commission should ensure that a policy and/or contract be established with garage(s) through the Legal Department. • The Senior Driver and Supervisor Tran sport and Es tates should esta blish a movement book/or form for drivers for monitoring. • Proper monitoring and control procedures including checklist, Standard Operating Procedures and where possible the use of GPS for tracking all assets and fuel management should be i ncorporated and i mplemented going forward. Management Response Recommendation is noted and action will be taken accordingly . 10 .2 Fuel Management The Commission stock level 21,000 liters fuel was supplied by NP Wilberforce on a monthly bas is. Payment was either made in advance or at a later date. The Team observed that, there was no formal agreement between the supplier and the Commission. With respect to fuel request procedures, it was observed that no technical knowledge was used to det ermine the q uantum of fuel a vehicle or motorbike can consume per kilometer covered. We noted that there was no fuel reconciliation report with fuel suppliers on fuel allocation to the Commission. Also, no fuel reconciliation report was provided to the T eam with reg ards the usage o f fuel by the Commission.

66. 65 Management Responses • The Procure ment unit has em ployed strategic filling as was advised by the Anti - Corruption Commission during the several interviews we had during the Period under review. • Presently, we file categorically using Goods Works and services and using procuremen t methods. • The procurement unit has been provided with a multi - purpose printer and three double door cabinets for the purpose of appropriateness. 11 .6 Debriefing to | Unsuccessful Bidder Section 27 of the NPPA state that procuring entity shall immedi ately, after a successful bi dder has been identified, inform the unsuccessful bidder(s) of the reason for which their respective bids were unsuccessful. By the provisions of Sec 28 (1) , , Subject to this Act, documents, notifications, decisions and other co mmunication referred to in t his Act to be submitted by the procuring entity to a bidder, or by a bidder to the procuring entity, shall be in writing Subsection 3 of section 56 of the NPPA act of 2016 stated that, notice of award shall be given to other bid ders at the same time the su ccessful bidder is notified, specifying the name and address of the proposed bidder and the price of the contract Finding(s) The Review Team observed that most of the notifications sent to suppliers were not signed. Therefore, it was by no mistake to conc lude that most of these unsigned documents were prepared upon request. Implication(s) Failure to sign suppliers’ notification letter may not provide credence to best procurement practice and feedback mechanism. Recommendatio n(s) The Revi ew Team recommen ds that for proper accountability and transparency, the Procurement Unit should always communicate in writing to all bidders whether successful or not which must be filed to ensure appropriate documentation process. Management Responses T he Procurement u nit always debriefed unfortunate suppliers on all major procurement issues especially when NCB and ICB are used.

41. 40 The team could not get any reconciliation statement from the stationed NRA officer with respect to the payment plan made. The NRA officer could not provide the team any further information reques ted from h im as he referred us to hi s supervisor. Implication Failing to provide or withholding information contravenes the ACC Act Recommendation The NRA should embark on a robust debt collection so as to minimize and/or get a zero - balance debt. Manag ement Resp onse No response 8 .0 BUDGET AND BUDGETARY MANAGEMENT Section 20 (1) of the Government Budget and Accountability Act (GBAA)of 2005 states that “ There shall continue to exist within the Ministry, a unit to be known as the Budget Bureau which sha ll, under the supervision of the Fi nancial Secretary, be responsible for the preparation and monitoring of the budget in collaboration with the Budgetary Agencies ”. 8 .1 Budget Participation Participative budgeting is a budgeting process in which the p eople who are in the lower levels o f management are involved in the budget preparation process. Unlike the imposed budgeting process, participative budgeting shares th e responsibility with low er - level Managers to give them a sense of ownership in the work of the organization. Finding ▪ T he Review Team verified that the budget preparation was participatory by all heads of department upon which submissions were i ncorporate d into the Commission’s a nnual budget. ▪ Annual departmental budget is prepared in consolidation with the Commission’s annual budget which is in line with the Budget Call from the Ministry of Finance.

75. 74 Furthermore, a total of Le3,194,693,000 (three billion one hundred and ninety four million six hundred and ninety three thousand Leones) were also amounts owed by NATCOM to various airline agen cies. Fina lly, the cumulati ve total amount is Le 7,013,255,317.84 (Seven Billion and thirteen million two hundred and fifty - five thousand three hundred and seventeen Leones eighty - four cents) . Implication Failure by the Commission to pay suppliers on tim e after deli vering services, goods and works may lead to mistrust and would undermine the image of the Commission. However, it may also create an opportunity of filing litigation against the Commission by suppliers and service providers. Recommendation I t is recomme nded that the Com mission designs a payment plan and offset the liabilities forthwith to restore confidence of suppliers and service providers. Management Responses The Procurement Committee During a procurement Committee meeting had unanimousl y decided th at all debts shou ld be paid and the Finance Department should come up with a payment plan for all debtors. 1 2 .0 STORES MANAGEMENT Section 178(1) of the Public Financial Management Regulations, 2018 states that “ the acquisition, receipt, cus tody, contro l, issue and disp osal of Government stores shall be in accordance with the Act and these Regulations.” Also sub - section (2) Subject to sub - regulation (1) says that “ the Minister may give general directions in writing to the Procurement Board on matters rel ating to Governme nt stores under the Act.” 1 2 .1 Store Environment The Store is not tidily kept and / or spacious as most of the items are obsolete. The Team found it very uncomfortable to work in the store as it was unsightly and the atmosp here was con ducive for the St orekeeper to execute his duties. Due to these factors, the Storekeeper spent most of his time in the HR and Admin office rather than, the store.

50. 49 • Admin : • Fleet and fuel • Stores • C anteen As result, it was observed that there was no clear description of tasks, segregation of duties and time lines associated with the activities amongs t staff in the department as there were overlapping and conflicting responsibilities amongst staff. Implication Combining these two specialized Management functions particularly within a large establishment with diversified functions will affect the smoo th running of the department . It also undermined accountability and created room for conflict of interest. Recommendation As a best practice and for effective checks and balances, the Mo F and NATCOM must ensure that the Human Resources and Administrative department are divided into two independent departments ( i.e., the Human Resources (HR) Department and the Administrative Department). In this regard , the HR department should handle human resource issues and the canteen whilst the Administrative Departmen t will comp rise of the Procu rement Unit, Fleet and Fuel Management Unit, Stores Unit, Security Unit and the general administrative matters. • There should be clear segregation of duties. For example, the person or persons in charge of procurement should be d ifferent fr om those in charg e of stores or fleet and fuel management. Management Response The Admin and HR Department have a clear description of task/separation of duties and function for each unit within the department. Employees within the HR and Admin Department are assigned to perform specific tasks/roles based on their respective unit they represent and areas of expertise as stated in their job description to avoid overlapping and conflicting responsibilities. 9 .2 Job Description F indings Job description is fundamental t o good employment practices. It was observed that some of the staff files inspected do not have job descriptions.

87. 86 • Management should develop dispute resolution mechanism for staff members. Al l disputes amongs t staff members that affect operations of the Commission should be investigated and appropriate actions taken. • Management should ensure all employees possess the requisite skills and qualifications for the positions held. • Contr actual staff contract terms a re addressed as prescribed in the contract. • Staff movement are properly monitored and communicated . Management Response Recommendation is noted and action will be taken accordingly . 15.2 Budgetary Support t o t he Regions It was observe d that even thoug h Regional Offices periodically submitted activity plans and cost to Head Quarter, these plans were not funded. The work of these zonal/ district offices required extensive mobility but there were no means for official mobilit y because th ere were no motor bike or vehicles to undertake activities such as monitoring and public education. Implication Lack of funding for activities militate against the actualization of an organization’s overall objectives. Recommendations • Manageme nt should en sure that regiona l offices are adequately funded. • Regional offices should provide comprehensive reports on activities and funds utilized. Management Response Recommendation is noted and action will be taken accordingly. 15.3 Monitoring, Su rveillance a nd Outreach Activ ities Monitoring, Surveillance and outreach are the key operational activities of the regional offices. The essence of these offices hinges on successfully undertaking these activities. Findings • The Team observed that the zo nal offices had no equipment to be able to surveillance the air waves.

68. 67 11 . 8 Sale of B idding D ocuments Section 58(4) of Procurement Regulation2020 states that “a procuring entity may charge a fee for the bidding documents, which shall be calculated to cover the cost s related to printing, copyi ng and distribution of the documents only and shall not include any element of profit. Subsection (5) states that “Payment from the sale of standard bidding documents shall be made into the Consolidated Funds”. Also, subsection (6) stipula tes that “The Au thority shall receive on a regular basis a percentage of the fees for each standard bidding document paid by bidders.” Findings The Team could not see any evidence of such payments being made as prescribed by the sections of th e law and re gulations quoted above. Implication There a breach of regulation Recommendation Management should ensure that the Procurement Unit abide by the provisions stated above as a best practice Management Responses ▪ The Sale of Bidding Document is being done b y the Commission ’s Finance Department. • Sequel to the Memo from the NPPA providing accounts for sale of bid documents, the commission had been 100% compliant with the regulation and have never flouted any regulations of such nature. 11 . 9 Payab les to suppl ies A liability is typically an amount owed by an institution to a supplier, bank, lender or other provider of goods, services or loans. In this context, procurement liabilities are an amount owed by the Commissi on to variou s suppliers for undertaking the full provision of goods, services and works. Finding The Review Team observed that the Commission owed enormous sums of money to various suppliers for various goods, services and works, supplied to the Commissi on

55. 54 also be conducted in the event of a promotion or change in duties and responsibilities.” • The team observed that performance reviews have not been conducted regularly as prescribed in the policy. Implications • There is a Breach of compan y’s policy. • Employees subject to ineffective systems and performance review practices are likely to feel upset, demoralized , and demotivated. This may lead to employees becoming dissatisfied and burnt out in their roles Rec ommendations Performance appr aisals must be done regularly as prescribed in the Performance Management Policy to improve staff performance and productivity. Management Response • There is evidence to show that employees’ performances were appraised in 2 019 and 2021 respectively. How ever, in the year 2020 due to the national Covid19 restriction policy which recommend employees to work from home in the quest to avoid physical contract, resulted to the cancelation of 2020 performance appraisal process. • Ma nagement is aware of the impli cations of ineffective Performance appraisal system, as such; we have and have maintained a structured appraisal system. • Currently, performance appraisal is done yearly; also, appraisal is conducted after probationary period for new sta ff before confirma tion as well as for promotion or change in duties and responsibilities.” Nonetheless, as recommended, management will ensure we adopt mid - year and end of year appraisal system in the future. 9 . 7 Staff Personal Files /R ecords Fin ding The Team obs erved that most of the staff files examined were without certificates and/or not updated with the necessary information and/or documents Implication Failure to update personal files of employees of relevant documents woul d limit info rmation on that em ployee for staff development

36. 35 deep fall in revenue between 2 019 and 20 20 of about Le21,722,202,221. 0 ( 1 3 %) from 2019 revenue generation. Implications A drop in revenue showed weaknesses in the Commission’s revenue drive. Furthermore, the failure by Management to examine and/or investigate this sharp fall in revenu e made it impossible for Management to determine the cause and take corrective measures to ensure sustainable revenue generation. Recommendation ▪ The Management of NATCOM should conduct a financial assessment and/or evaluation on its revenue generation dri ve during this period to maximize futur e revenue generating potentials. Such evaluation should be regularly conducted when preparing the annual budget. ▪ Any drop in revenue generation should be critically examine and/or investigated in order to determine th e cause an d necessary corrective measur es taken. Management Response • In the first instance , the fall in revenue in 2020 was due to the impact of Covid 19 pandemic, which affected many businesses as they closed down and some customers did not start up the ir busines s. • Additionally, there was an improvement in technology as many VSAT customers decommissioned their VSATs licenses. • Furthermore, the income stream, Local Interconnect was discontinued in order to satisfy users for mobile networks. • Moreover, we ar e not char ging surcharge on data. • NRA w as also responsible for collecting debts instead of NATCOM. • Finally, there was an increase in Over The Top (OTT) calls examples WhatsApp calls, Facebook, face time etc. which affected our local and international calls . 6. 4 . C heque Withdrawals The team o bserved that numerous cheques were drawn in the names of lower cadre workers of the Commission who were not members of the Finance Department. For example, cheques were drawn in the names of Office Assistants and /or a dispatch for withdrawals from the Ban k of Sierra Leone for payment for workshops and honorarium. The table below gives example of cheques drawn in the names of dispatcher(s):

20. 19 • We observed that whilst these reports contained findings, we did not see any corresponde nce requesting officers /depart ment to respond to the fin dings in the report. T he y failed to answer queries, in addition no holistic and/or comprehensive annual internal audit report of NATCOM for the periods under review was provided for examination. Implications • Failing to conduct internal audit and provide i nternal audit reports will render the Commission to be unable to assess controls and risks and take corrective measures. • Also, failure to provide responses to queries will undermine efforts to ensure internal controls measure as a result, weakne sses will remain unresolved. R ecommendations • The Management of NATCOM should ensure that regular and/or holistic (quarterly, annually) audit of the Commission are conducted. Moreover, the Internal Audit department should conduct comprehensive audit inclu sive of al l operational areas fo r a better Internal Control and risk mitigation. • The Management should also, ensure that all audit reports and audit queries therein are acted upon and addressed. Management Response Noted . 4.5 External Audit An Extern al Audit i s an independent exami nation of the financial records prepared by an organization. The main objective of an External Audit is to verify that the accounting records for a company provide a true and accurate picture of the organization’s finances a nd financi al statements are prep ared in accordance to the set laws and accounting standards. External Audits also add value by identifying areas where efficiency in the business can be improved and where controls and processes may be made more effective. Section 17 (2) of the Telecommuni cations Act 2006 states that “ The books of account kept under subsection (1) shall within three months after the end of each financial year, be audited by the Auditor - General or an auditor appointed by him .”

62. 61 as well as on supplier, contractor or co nsultant per formance is repo rted to the procurement committee’. Moreover, Section 12 of the Public Procurement Regulation 2020 states that “A Procurement Committee may in addition to the structure and functions specified in section 18 of the Act” Furtherm ore, Section 15(1) of the Pu blic Procurement Regulation 2020 stipulates that “Procurement Committee meetings shall be attended by all members of the Committee and a quorum for meetings of a Procurement Committee shall be the Chairman and at least 2 members .” Sub Sect ion (2) of the r egulation states that “A decision of a Procurement Committee shall be unanimous and where unanimity cannot be achieved, the decision shall be deferred for further consultation and clarification to ensure that unanimous decision can be made at the next meet ing.” Also Sub (3) states that “Where a member of a Procurement Committee has an interest in a submission, he shall - (a) declare his interest in the submission; (b) leave the meeting while the matter is considered; and (c) not participate in the deliberat ions or decision - making process of the committee in relation to that submission. Finding(s) • The review Team observed that there was an existing Procurement Committee but not functional on regular basis. Furthermore, the Team fu rther observ ed that certain procurement activities were not under the control of the Procurement Unit and those activities did not follow due diligence as well as compliance mechanisms. • Additionally, available document indicated that the Procurement Commit tee used to hold meetings bu t most of the Minutes and attendance list were not signed by the committee members. Implication(s) • Lack of commitment of the Procurement Committee may not provide the needed oversight required ; ensuring best procurement practic es and that has utmost tende ncy for corruption to drive safely in a convenient vehicle because, it created room for conflict of interest and compromise decision making. • Failing to sign an official document by the Procurement Committee members automaticall y nullified the process and questioned the authenticity of the process.

18. 17 4. 2 Audit Committee Section 76 (1) of Public Financial Management (PFM) Act of 2016 states that “ The Director of the Internal Audit Depa rtment of the Ministry may require the vote controller of a Budgetary Agency, Sub - vented Agency, other entity in the central government, Local Council, social security fund, or public enterprise to establish an Audit Committee of the entity, afte r consulta tion with the vote con troller of the entity.” Findings For the periods under review, the team observed that the Commission had no established Audit Committee to which the Internal Auditors should report to. Rather, they were reporting to a Financ e and Audi t Committee establishe d by the Board. Implications The non - existence of an independent Audit Committee impedes the oversight of the financial reporting process , the audit process, the company's system of internal controls and compliance with law s and regu lations. Additionally , it undermines the authority and weights of the internal audit reports as there will be no structure within the management hierarchy to ensure that the findings and recommendations are acted upon by Management. It is also a complete violation of Section 7 6(1) as stipulated above. There was no oversight role. Recommendations Management must immediately constitute an independent Audit Committee as prescribed by the aforementioned sections and also in line with professional s tandards a nd best practices. The Audit Committee should be made up of independent non - executive directors . Management Response An Audit Committee has been established by the Commission. 4.3 Annual Audit Plan According to International Audit Standards ( IAS) 300 – “ In planning an Audit of Financial Statement, the Auditor should plan the audit so that the engagement will be performed in an effective manner. The objective is for the Auditor to develop an Audit Plan in order to reduce audit risk to an accepta bly low le vel .”

51. 50 I mplications Without a good job description, it becomes very difficult for an employee to know what is expected o f him and f or a manager or s upervisor to provide an accurate and effective job performance evaluation or appraisal. R ecommendations • The Human Resources Department should ensure that there are properly drafted job descriptions for every position in the Com mission. • Th e Department shou ld further ensure that all staff members of the Commission are issued with the appropriate job description. Management Response Recommendation is noted and action will be taken accordingly. 9 .3 Records Management Findin gs • It was observe d that records were mostly maintained in soft copies. Hard copies were difficult to come by or access. There was no observed back up mechanism for digitized records. • It was observed that there was no approved records management policy or m echanism in place . Implications • In the absence of hard documentations to support the records management system, there was a greater risk of fraud and system failure or crash. • The Commission should also note that there were statutory requireme nts to main tain certain docu ments over a certain period of time. R ecommendations • Management should develop a records management policy for the Commission. • Whilst it is laudable for the Commission to attempt to digitized its records management, however it must be pro perly done taking in consideration fraud and security concerns, preservation and authenticity of records • Records Management Policy of NATCOM should clearly include the retention of hard copy documentation over a certain period of time and also t o ensure th at the hard copy documentations are consistent with the soft copies.

39. 38 Recommendation(s) • The Mana gement should establish an effective tax management mechanism by having a designated person within the Account Department to conduct monthly analysis and ensure prompt payment of all taxes and statutory contributions. • This per son should also ensure that a ll withholding taxes are properly accounted for and paid. Subsequently all suppliers should be provided with proof of payment to enable them to set off their withheld tax against their annual tax obligations. Managem ent Respon se • All the liabilities NATCOM owed to NRA and NASSIT has been paid in full for 2019 & 2020 and the receipt s are available for inspection. Proper records are kept and analyzed monthly for PAYE, withholding tax and NASSIT are they are available bot h on excel and QuickBooks. • We have an effective tax management system and designated staff members assigned to perform this function. • We have printed withholding tax receipt books and we have been issuing them out to suppliers. In the future, we will en sure promp t payment of the tax liabilit y. 6. 6 Fixed Assets Register Finding • The Fixed Asset Register should contain list of Fixed Assets of the Commission recorded by name, Asset serial number, description, location, purchased date, price, Asset code e tc. • The t eam observed that the Commis sion does not maintain a fixed Assets Register as the document presented was a listing of assets which did not reflect fixed assets registered. • The listing provided was not exhaustive as tangible assets such as land a nd buildin g s were not stated on the l ist. • The Review Team also observed that most of the assets of the Commission were not coded . Implication s ▪ The accountant would be unable to estimate the value of the assets of the Commission. Tracking of the Commissio n’s assets will be difficult as ther e were no records to follow.

57. 56 9 . 9 Canteen Services A canteen is a restaurant provided by an organization for its staff. F indings • The Review Team observ ed that the Canteen started o perations in the early years of the existence of the Commission. The first contractor that managed the Canteen services left and a new one was contracted. • However , the Team was not provided with any information on the sourcing of contract or for the cantee n. More so the Team observed that there was no contract or rather signed MoU between the Canteen Contractor and the Commission. • The Review Team also observed that food and drinks were sold to staff at the Canteen yet; the Cante en Managemen t never paid any overhead cost for usage (rent) and/or energy supply. • There were also reports of delay in making payments (debtors) to the canteen Management for food supplied to staff members. Implications • Not having a legally binding documen t and/or MoU specifying detai led responsibilities and obligations could lead to misunderstanding and /or possible disruption in the operation of the canteen services. • Either party can abruptly resort to taking any action that would not be convenient to the other party at any time with out notice. Recommendations • Management should ensure that the proper procurement procedure in the sourcing out of contractors for the canteen is applicable. • Furthermore, a MoU and/or contract must be prepared and signed by bot h parties (T he Commission and the Canteen Management) to ensure smooth running of business. • Finally, Management should ensure that debtors (staff) pay on time and /or amount owed be deducted at source and paid to the management of canteen. Management Resp onse Recomme ndation is noted and action will be taken accordingly .

40. 39 ▪ Failing to code assets would lead to theft, exchange and loss of the Commission’s property. Recommendation s • A Fixed Asset Register must be maintained so that assets are tracked, recorded fo r proper r eporting and audit purpose s. • The assets can also be coded for ease of identification. Management Response We now have a comprehensive fixed asset register which includes all the fields mentioned above and the asset s have been coded and its ava ilable for inspection. Land and buil ding are also part of fixed asset register. 7.0 DEBT MANAGEMENT Section 4(a)(1) of the Finance Act 2009 states that: a) to take over ‘The collection of the revenues or other monies, not derived from taxation, raised or receive d for the purpose of, or o n behalf of the government, hereafter referred to as non - tax revenue and required by subsection (1) of section 111 of the constitution to be paid into the Consolidated Fund, including but not limited to fees, royalties p ayable und er the enactments...’ The ab ove provision was further amended under section 12(e) and (f) of the Finance Act 2019 as follows: e). “Collect all non - tax revenue debts owing to the government of Sierra Leone including License payments that are due on a yearly b asis, as they become due’ f). ‘seal the premises of a non - tax revenue debtor, and g) ‘order a third - party including banks holding money for a non - tax revenue debtor to pay to the national Revenue Authority all of the debt of non - tax revenue debto r or any a mount that is sufficient t o discharge the non - tax revenue debt’ NATCOM was in full control of collecting all debts from Mobile Network Operators. The above provisions have prevented them from performing such functions and are required to terminat e all Reve nue Collection Agreement t hey have entered into with Mobile Network Operators; and redirect all such actions and activities to the NRA with immediate effect. A cumulative total debt of Le145,226,028,479.32 is still in the books of NATCOM as debt. The colle ctions done by the NRA is slow and/or not robust.

21. 20 Findings • T he review team noted that there was evidence that the Commission had never been audited by an External Audit firm and/or Audit Service Sierra Leone. • However, the review team was informed that Audit Service Sierra Leone (ASL) will undertake an external audit for the financial years (F Ys) 2017, 2018 and 2019. Implications • Delay in External Audit process will affect the credibility of a company's financial statements and compliance with regulations . • The External Auditors will not be able to assess t he objecti vity and/or evaluate t he effectiveness of internal controls within the company. Recommendations As prescribed by the sections above, the Management of NATCOM should ensure that External Audit is adhered to by the provisions of the Acts, so that an assess ment of their financia l statement complies with regulations. Management Response External Audit for the years stated have all been conducted and concluded by the Audit Service Sierra Leone. 4.6 Staffing Staffing is an operation of recruitin g employee s by evaluating their skills, knowledge, and then offering them specific job roles accordingly . Finding • The Audit Unit is understaffed with only four (4) personnel, inclusive of the Director and the Deputy Director with two support staff with no audit exp erience. Given the eno rmity of the mandate of the Commission, it was not practicable for two staff to handle the internal audit processes of the Commission. • The team also identified the vacant position(s) at the Audit D epartment. Implication U nderstaffi ng in the Audit Depart ment will lead to inefficiency, and ineffectiveness in the discharge of audit duties.

80. 79 Implication Failing to maintain a store records voucher may lead to poor accountability and the possibility of corruption. Recommendation The Management of NATCOM should ensure that the storekeeper followed the due process es on store requi sition and issues. Moreover, the Commission should develop a policy on stores management and ensure it strict adherence. Also, the storekeeper should ensure that a store card was maintained and displayed on every item stored. Management Response Recomme ndation noted for appropriate action 13 .0 UNIVERSAL ACCESS DEVELOPMENT FUND (UADF ) Section13; Subject to subsection (2) of section 16 of the Telecommunication Act 2006 states that “ there is hereby established a fund to be kno wn as the Un iversal Access De velopment Fund which shall consist of a percentage of the gross income of service providers as declared for income tax purposes determined by the Minister by statutory instrument.” A secretariat was established to manage the fu nd. The fund was meant for th e construction of telecommunication infrastructures across the country to ensure access. Findings The following were observed: • Examination of relevant documents revealed that NATCOM had given out Le 2,931,612,800 (two billio n nine hundr ed and thirty - one million six hundred and twelve thousand eight hundred Leones) as accumulated loan amount to UADF for the period December 2018 - December 2020 inclusive. Additionally, the Audited Financial Statement of UADF 2019 stated the loan amount from NATCOM as Le2,35 9,475,000 (Two billion, three hundred and fifty - nine million four hundred and seventy - five thousand Leones). The difference of Le572,137,800 (Five hundred and seventy - two million, one hundred and thirty seven thousand eight hun dred Leones) represent the lo aned amount for 2020 by NATCOM to UADF.

88. 87 • There were no qualified Engineers to lead the monitoring or surveillance process in all the zonal office. • Monitoring or outreach activities were conducted using either petty cash or own resources o f staff. Implic ation • Lack of mobility limits full coverage as well as pose serious strain on staff including the associated risk of useful commercial motorbikes • Lack of equipment that leads to sub official output and leaves the office at the mercy of th ose who may not w ant to be with the system. • Diverting petty cash from its intended use to core budgeted activities is an unhealthy financial practice. It is even worse when staff to use their own resources to fund the office activities. Recomm endations • Ma nagement should e nsure that R egional O ffices are adequately funded and staff. • Regional O ffices should provide comprehensive reports on activities and funds utilized. Management Response Recommendation is noted and action will be taken accordin gly. 15.4 Regional Office Fuel and Petty Cash Findings • A flat sum of Le 5,000,000 was given as petty cash to every R egional O ffice and was supposed to be replenished after 85% being utilized. The Team observed that there were delays in the replenishmen t by HQ. The petty cash were mostly managed or controlled by the zonal heads or appointees as there were no account officers deployed in these offices. • The sum of Le 5,000,000 was also provided to the zonal heads for onwards, transfer to fuel dealers of the ir choice wh o would then supp ly the fuel for the official quota of 36/45 liters per person per week and 45 liters for generators. No framework contractual agreement between the fuel dealers and NATCOM. There was also a reported delay in the replenishment p rocess. • Fuel chits of fuel su pplied shown to the Review Team were not signed and all copies including the duplicates were kept by the offices.

19. 18 Findings Aud it plans were provided for the periods under review. However, the material content of the plans was focused on repetitive transactions (transactional auditing) rather than comprehensive and/or holistic audit of the Commissio n. For ins tance, the plans do no t entail auditing of Financial Management, Procurement, Stores, Assets, Fuel and Fleet, Personnel/HR, etc. Implications This implied that activities were not implemented as planned for the periods under review and as such it provide d a fertile ground for other departments of the Commission to execute their activities and mandate without checks and balances. Recommendations The Audit Plan should include the auditing of all departments and operational areas of the Commissio n. Subsequ ently the audit plans should be presented to the Audit Committee for approval. The Director of Internal Audit and Risk Management should carefully ensure that all activities are implemented as planned to improve efficiency and effectiveness in c arrying ou t their duties. Mana gement Response Recommendation noted. 4.4 Internal Audit Queries An Audit Query is an explanation that is required by the Audit team on certain points that they may have identified during an audit . These may be used to g ather info rmation to come to a c onclusion in the audit . All audit clients are required t o provide a written response to audit findings. The response represents Management's plan for correcting or improving the findings. All responses are included in the final audi t report that is distr ibuted to Senior Management, the Board, and the External Auditors. Section 151 (1) of the PFM - regulation 2018 states that “ An auditee shall respond within ten working days after an Internal Auditor has issued a draft audit report in writing.” Findings • Th e review team was provided with the internal audit reports for some provincial offices.

53. 52 STAFF NAMES STAFF LIST PAYROLL Abdul Dumbuya Abdulai Dumbuya Mamadi K Kamara Mamadie F Kamara Yankuba Nyallay Yankubu Nyal lay Sheikh Swaray Deen Sheik h Alieu Swaray - Deen Kalilu Massaquoi Kalilu P. B. Massaquoi Ruth Konah Feika Ruth Feika Amiru K. Dabor Amiru Dabor Salamatu T. Chakanda Salamatu Tutu Fonti - Kanu Foday Kanu Foday Thomas Kanu The Review Team observed that there were no mechanisms in place to ensure regular audit and reconciliation of pay roll and staff list of the Commission. Implications Variances and discrepancies of such nature may be an indication of payroll fraud and also misuse and /or misappropriat ion of compa ny’s resources. Recommendations There should be regular review and reconciliation of pay roll and staff list by the HR Department. The Internal Audit should conduct an audit on Human Resources and payroll. The variances or inconsistencies sho uld be regul arized in order t o save cost. Management Response The inconsistency between the payroll and staff list has been regularized. The internal audit on HR and Payroll exercise/activity has now been incorporated into the Admin and HR departmental ye arly activit y plan as this wi ll ensure proper compliance with SOP. 9 . 5 Staff Attendance Register F indings • The Commission was operating a Biometric system of staff attendance which was a good endeavor as it prevented human interference. Due to the Covid outbreak, th e system was put on hold and manual recording was reintroduced.

82. 81 • The basis on which the loan was written off as bad debt was not provided. The amount was so significant for it to be tre ated as an expense (bad debt). In fact, UADF was a going concern and has never been liquidated or pronounced insolvent for its loan to be treated as a bad debt. The loan period had just run for almost two years for it to be co nsidered as bad. • Furthermo re, there was no evidence that NATCOM had positively engaged UADF on the loan repayment. • With regards to revenue generation by UADF Secretariat, it was observed that a Cabinet Resolution Paper had been past and Section 7(1) of the Univ ersal Access Deve lopment Fund Statutory Regulation Instrument 2019 states that “ there shall be charged on a service provider, in accordance with Section 13 of the Act, a Universal Access and Service levy of 0.75% of his gross income as declared for income tax purposes.” ✓ T he Review Team could not be provided with the total revenue generated from the GSM and ISPs as a result of the 0.75% deductions from their profits. The Team was also informed that some of these GSMs were refusing to pay. ✓ Secti on 7(3a) of the regulation pu rported that “ A licensee who fails to pay a universal access and service levy under subsection1 commits an offence and is liable to a penalty not exceeding 25% of the levy and an interest of 5% thereon.” The Team was not provid ed with any penalty charge on licensees who failed to pay. • Pertaining to the fulfillment of its mandate of building telecommunication infrastructures, it was observed that the UADF Secretariat had failed to undertake any such project. All the funds rece ived so far had been spent on salaries and other administrative matters. • The Team was also informed that UADF was not obliged to report to NATCOM despite the fact that the Secretariat was supposed to be a su b set of NATCOM. It now reports directly to the Ministry of Information and Communication with no supervision or collaboration with the Commission. • The Team realized that public education on the work of UADF was not done enough.

81. 80 • A letter dated 3 rd December 2018 from the Permanent Secretary of the Ministry of Information and Communications referencing UADF request for a loan of Le545,772,535.12 (five hundred and forty - five m illion seven hund red and seventy two thousand five hundred and thirty five Leones twelve cents) from NATCOM. • According to the letter, it was stated that “ the Ministry’s no objection to provide the said soft loan to augment their operations. Furthermore, the Ministry wil l be repaid by UADF with a payment plan as soon as modalities have been put in place for service provider to commence payment to the funds pursuant Sector 13 of the Telecommunications Act 2006.” • On the 18 th December 2018, a loan repayme nt agreement was signed by UADF’s management, undertaking to make a monthly payment of Le20,000,000 (Twenty Million Leones) to NATCOM effective February 2019. ✓ The Review Team observed that the loan repayment agreement was prepared by UADF inste ad of NATCOM . ✓ The Review Team could not identify any member NATCOM being part of the agreement as signatory. ✓ The amount stated as monthly repayment was too small because it would take UAFD over five years before the loan was fully repaid, even if they had honored thei r agreement. • O n the 17 th January 2019, another letter was sent by UADF notifying NATCOM stating that “ due to the delay in the processing of the Cabinet Resolution Paper, to determine the percentage of payment to be levied on the Global Syste ms for Mobil es Operators (GSM ) and ISPs (Internet Service Providers), we will not be able to meet the terms of the payment agreed until there is a Cabinet resolution on the percentage to be paid.” • It was observed that in the books of NATCOM, the amount had been ini tially treated as long - term loan in their Balance sheet but due to the non - payment of the loan by UADF, the loan amount was now treated as an expense. The Review Team did not set eyes on any correspondence from NATCOM reminding UADF of their ob ligations as it was a debt. • No evidence was provided to show approval from the Board for the granting of the loan and the writing off of the loan as bad debt.

16. 15 • To monitor the implementation of the review recommendations . 3.0 SCOPE AND METHODOLOGY The review period was between the periods 2018 - 2020 (inclusive), a three - year period. All areas of operat ions were examined. T he review process commenced with an inception meeting with management of NATCOM. At the inception meeting commitment was made by the management to collaborate with the Review Team and the workplan and activity schedule was a dopted. I n conducting the revie w, desk - based reviews of relevant documents were conducted and research on similar reviews in T elecommunication . Accordingly, the team conducted interviews with key staff of the organization and its related agencies in line with the r eview objectives. The Review Team observed existing practices and procedures in order to determine their weaknesses and strength. Field visits were conducted which involved physically observing service delivery; and Additionally, the team res earched ot her studies done on si milar institutions to inform the conclusions. The input of end - users was also invariably considered, and critical to the outcome of this review. FINDINGS AND RECOMMENDATIONS 4.0 INTERNAL AUDIT AND RISK MANAGEMENT Accordin g to the I nstitute of Internal A uditor (IIA), " Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization’s operations. It helps an organization accomplish its objectives by bringing a systemati c, disciplined approac h to evaluate and improve the effectiveness of risk management, control, and governance processes. " In assessing the internal audit function, the following area of focus was examined. 4.1 Audit Manual An audit manual outl ines the a uthority and scope of the internal audit function, documents standards, and provides cohesive guidelines and procedures. These guidelines promote

60. 59 There was no policy on fuel allocation. Recommendation(s) • The Management of NATCOM should ensure that a policy of fuel management is established. • There should also be a framework Contract agreement between the supplier and the Commission With regards the supply of fuel and that should be in line with the procurement regulations. • The Commission should ensure that there is a regular reconciliation of fuel so as to establish the reorder level of stock, usage and ba lance. • The office r is charge of fuel should be trained. • Management should embark on the modern - day fuel dispensation by initiating the electronic chit system (Tom Card) for staff and the Commission at large. Management Response • Recommendation is noted an d action will be taken accordingly. However, fuel reconciliation report is done monthly and submitted to Internal Audit and Risk Management Team for verification before the approval of monthly fuel replenishment. • Additionally, the use of elect ronic chit s ystem (Tom Card) has currently been implemented/executed for employees that are eligible to fuel allocation and the Commission at large. 1 1 .0 PROCUREMENT MANAGEMENT Procurement Management is the systematic approach used for buying all the g oods and ser vices needed for a company to stay sustainable. When procurement is managed well, it would add value to all business practices, and save both time and money. Furthermore, the goals of the procurement cycle are to: i. Manage spending; ii. Support ope rations; and iii. Protect the orga nization from risk. 11 .1 Procurement Plan Procurement planning is the process of identifying and consolidating requirements and determining the timeframe for procurement with the aim of having them as and when

85. 84 The table above illustrates the payment on various dates to ICC. There has been a d elay in the project implement ation as the schedule above shows that the final disbursement Le10,809,000 (ten million eight hundred and nine thousand leones) of the loan amounts was made on the 22 nd September 2021. Implication Failing to meet monthly obli gation as st ated in the stand ing order could trigger a default rate or penalty interest rate which will increase payment . Recommendation • Management of NATCOM to seat with the Management of SLCB and BSL to review the loan repayment and by extension the sta nding order date. • Also, ICC should give an update as to the finalization of the new office. Management Response Recommendation noted 1 5 .0 REGIONAL OFFICES The R egional O ffices were established to implement NATCOM’s mandates at regional and/or distric t level. The Review Team visi ted the Port L oko, Makeni, Moyamba, Kono, Bo, Kenema and Pujehun offices of NATCOM to get firsthand information about the functioning of these offices. Below are the findings and recommendations. 15.1 Staff Composition and Functionalit ies • It was obser ved that Kenema and Bo were headed by Managers and the others by Supervisors. The overall functioning of these offices were centered on the Managers or Supervisors who performed multiple and conflicting roles. The Managers/Supe rvisors were in charge of the day to day activities of the offices and they embodied the entire Administration, Finance and HR functions. It was further observed that most of the regional heads do not possess the required qualifications for such position. • There were assigned General Services Officers and General Services Assistants to these offices. The General Services Officers (GSOs) and General Service Assistant (GSAs) were not proportionately distributed in the regions as they were more than required i n some offic es whilst few in others. Most of the GSOs were not provided with a job description.

6. 5 LIST OF ACRONYMS ACC Anti - Corruption Commission GoSL Government of Sierra Leone NATCOM Nation al Telecommunication Commission IIA Institute of Internal Auditor PFM Public Financial Management GBBA Gov ernment Budget and Accountability IAS International Audit Standards ASL Audit Service Sierra Leone WHT With holding Tax Payment GBAA Government Budget and Accountability Act MoF Ministry of Finance NPPA National Public Procu rement Authority Act UADF Universal Access Development Fund NRA National Revenue Authority

38. 37 6. 5 Withholdi ng Tax Payment (WHT), NASSIT Contribution & PAYE Section 117 of the Income Tax Act 2018 mandates a 5.5% withholding Tax Payments to contractors/ or suppliers to be deducted at source of income. Findings • It was obse rved that withholding tax deduction of 5.5% was made from payments to various suppliers as prescribed by Law. • However, the Review Team were not presented with any evidence of monthly analysis of withholding tax payments made to NRA and receipt or certific ate of pay ment presented to suppliers. • It was observed that an accrued amount of Le1,849,704,567.06 (One Billion Eight Hundred and forty - Nine million, seven hundred and four thousand, five hundred and sixty - seven Leone and six cents) of Withholding tax d eductions had not been paid to NRA. • It was also observed that there were also accruals for NASSIT contribution of Le2, 648,819,970.18 (two billion six hundred and forty - eight million eight hundred and nineteen thousand nine hundred and seventy Leone eighte en cents), and PAYE Le12,057,460,130 (t welve billion and fifty - seven million four hundred and sixty thousand one hundred and thirty Leones). • However reviewed document showed that on the 16 th of June 2020, the Ministry of Finance (MoF) agreed to pay all d ebts owed by the government of Sierra L eone to NATCOM totaling Twenty - nine Billion and Fifty - Two Million Two Hundred and Forty - Seven Thousand One Hundred and Seven - Five Leones Sixty - Three Cents ( Le29,052,247,175.63 ) for services rendered to the GoSL. In t his agreem ent , the MoF was to pay (set o ff) the liabilities of NATCOM with respect to NASSIT and NRA against government’s debts. Implication s • The huge amount of accrual of tax liabilities and other statutory payment indicated weaknesses in the way the Co mmission m anaged its tax liabilities. Su ch weaknesses may result in additional cost to the Commission as these accruals may attract penalties and fines. • The observed weakness to properly account for withholding taxes deducted from suppliers raises corrupti on concern s.

58. 57 10 .0 FLEET AND FUEL MANAGEMENT 10 .1 Fleet According to NATCOM’s policy on the “Procedures and patterns on the use of Commission vehicles” it states “During normal working days and hou rs within, a ny official wishi ng to use a Commission vehicle must fill out a vehicle form which is in the custody of the Senior Driver and Supervisor Transport and Estates”. The review exercise revealed the following: • Lack of comprehensive Fleet Data and D atabase Mana gement. The docum ent provided to the Team could not speak of the status and locations of fleet. • Accountable tools such as logbooks, Vehicle Movement Register, Vehicles Request Form etc, were not maintained. In fact, the vehicle movement registe r maintained at the security post only records outward movement of vehicles and no record of return. Most of the audio meters on the vehicles were out of order. • Accountability tools such as Maintenance Forms, Reporting Template and routine maintenance sch edule for ea ch automobile wer e not available at the time of the review. Vehicles were repaired at Petco Garage and Abu Marg Garage. No contract document and/or policy were provided to the Team with regards maintenance of the Commissions’ fleets. • The Senior Driver and Supervisor Transp ort and Estates had no control on the movement of drivers and vehicles. Also, he had no formal training in Fleet Management. • The entire fleet of the Commission are as follows: • No information was provided to the Team with regard boarding vehicles. • No fleet inspections check list or Standard Operating Procedures was provided. The Review Team observed that ther e was no veh icle request form . Requests were made verbally to the Transport Officer without any documentation (vehicle request form) of the movement to be made. Fleet Number Status Vehicles 16 Road worthy Mot or bikes 1 R oad worthy Gener ator 9 Working Vehicle 5 Faulty

17. 16 consistency, stability, continuity, acceptable performance standards, and a means of coordinating th e efforts of audit staff effecti vely. Section 143(2) of the PFM - regulation 2018 stipulates that “ The Internal Audit Unit established within a Budgetary Agency, Sub - vented Agency, other entities of government, Local Councils, social security fund, or publ ic enterpr ise shall operate in a ccordance with the operational procedures outlined within the Internal Audit Manual and other guidance provided by the Internal Audit Department of the Ministry ”. Findings The team was provided with an Internal Audit Manual which was not comprehensive and detailed in line with Professional Standards and Best Practices. The following were some of missing contents within the manual: • Objective • Mandate • Audit Planning • Audit Framework • Responsibilities of Audit Staff • Internal Contr ols to Ris k Management • Audit Com mittee, Composition and tenure • Template on Audit report, risk alert form, assignment sheet, annual audit plan etc. Implications • A non - comprehensive Internal Audit Manual will affect the professional guidance, tools and inf ormation f or managin g, planning, conducting and reporting on internal audit work. • Also, the non - comprehensiveness of the Internal Audit Manual affects the quality and usefulness of the Internal Audit Department by preventing them from adopting practices, p rocedures and processes that wou ld help them conform to professional standards and best practices. Recommendations The Management of NATCOM should ensure that a comprehensive and adequate Internal Audit Manual is produced to facilitate the smooth function ing of the department. Manageme nt Response A comprehensive Internal Audit M anual will be instituted a s it s on working progress.

86. 85 • There were Regional /District Outreach Coordinators on contracts. We observed that the contracts agreements for most have expired for over six months without i t being rene wed or extended. However , these individuals continued to work without any proper employment contract. • We observed poor working relationships between some staff members which had affected checks and balances and the smooth running of the offic e. For examp le , at the Makeni office rift between the supervisor and GSO resulted in the supervisor refusing to sign petty vouchers. • We also observed weak supervision of staff by the HR Department. For example, in Kono , the Review Team could not track par ticular pers onnel . • The Revi ew Team was told that this person was supposed to relieve the supervisor at Port Loko between the periods of 21 st October 2021 – 24 th November 2021. • Howeve r , he neither reported for duty in P ort Loko nor in Kono nor receives salary for s uch periods. Im plication • The risk of abuse of office was high in situations where a single individual was in charge of everything especially financial control. • Lack of specific job descriptions would create the avenue for some staff to be ove rused while others idle by pa rticularly those favoured by the boss. • Square peg in round holes breed poor performance for the administration. • Working without a binding contract and getting paid was contrary to law and could also lead to demotivation. • Absen ting from du ty showed lack of disciplinary measures to ensure effective human resource control over staff. Recommendations The Management of NATCOM should ensure that: • Adequate administrative structures are established at provincial offices to ensure adeq uate checks and balances. • Job descriptions are given to all staff inclusive of GSO. • Staff members should be proportionately distributed to the regions depending on work load and area covered.

25. 24 5.4 Board o f Directors Findings • Board members are appointed and removed b y the Government. We ob served that their appointment letters did not specify how involved they would be in the day to day running of the company i.e., whether they are executive or non - executive board members. • The independence and diversity to e nsure and effective board are als o questionable as the board does not include members with diverse and relevant professional background and experience necessary for an effective board. Implications • Failure to specify whether the re is an executive or non - executive is a source of conflict between the Managing Director and Board Members. • Without diverse and relevant professional background and required experience, the board will be unable to effectively steer the management of the Company. Recommendations • I t is recom mended that all Board a ppointments should be done in line with the Commission’s Act with consideration given to qualifications and experience. • The Act should be reviewed in order to clarify the role of the board as supervising body and the Direc tor Genera l as head of administra tion. • The appointment Letter must state whether the Board is a no n - executive or executive board. If it a non - executive a written terms of engagement include job description should be given and if it is executive a service a greement s etting out the terms of the directorship should be given. Management Response Recommendation noted for action 5. 5 Organizational Structure Finding The Review Team observed that the Organogram was incomprehensive and limited to few departmenta l heads. T here were a number of d epartments or offices that were not captured in the Organogram. Some of the reporting lines and line of authority on the

15. 14 1.0 INTRODUCTION The Anti - Corruption Commission (ACC) was established with the primary aim to prevent, investigate and prosecute corrupt offend ers and to also provide accurate information to the general public on the dangers of corruption in our society. The preventive aspect of the ACC is provided for in Section 7 and 8 of the Anti - Corruption Act of 2008 as amended. The ACC secured funding fro m the Open Society Initiative fo r West Africa (OSIWA ) to support the operations of the Commission. Part of the support was used to conduct the systems review of the National Telecommunication Commission (NATCOM) Sierra Leone. The review conducted identifie d areas of weakness es in the man agement and operations of NATCOM. However the review proffered recommendations that is geared towards preventing corruption and improving on service delivery. The National Telecommunications Commission (NATCOM) was establi shed by an Act of Parliament in 2006 to regulate the Sierra Leone telecoms sector, protect consumer interest and ensure fair competition among service providers. S ince its establishment, the Commission crafted a strategic direction/plan that clearly state d its Miss ion and Vision to surm ount the various challenges in the telecoms industry . The major policy direction of the Commission was the establishment of an effective, sound and dynamic licensing regime that was responsive to the industry ’s demands; an d the regu lation of the activiti es of telecoms operators aiming at promoting efficiency and fair competition; ensuring expansion in investment in the sector; and adopting rules and procedures that guarantee and protect the rights of users of telecoms servi ces. The report of the review h ighlights findings, recommendations and management responses. The recommendations contained therein will be monitored for implementation compliance. 2.0 OBJECTIVES The following are the objectives of the review: • To promote efficiency and improve service d elivery; • To improve ethical behavior in the organization; • To improve performance measurement and create good governance in the Organization; • To ensure that management policies, procedures, practices, and processes are follow ed; • T o st rengthen the Internal Controls System of the Commission; and

7. 6 EXECUTIVE SUMMARY NO. FINDINGS RECOMMENDATIONS 1. INTERNAL AUDIT AND RISK MANAGEMENT Audit Manual Internal audit manual presented not exhaustive and detailed in line with professional standards and best practices. The Management of NATCOM should ensure that a comprehensive and adequa te Internal Audit Manual is produced to facilitate the smooth functioning of the department Audit Committee For the periods under review, the team observed that the Commission had no established Audit Committee to which the Internal Auditors should re port to. Rather, they were reporting to a Finance and Audit Committee established by the Board. • Management must immediately constitute an independent Audit Committee as prescribed by the aforementioned sections and also in line with professional standar ds and best practices. • The Audit Committee should be made up of independent non - executive D irectors. Staffing The Audit Unit is understaffed with only four (4) personnel, inclusive of the Director and the Deputy Director. Given the enormity of the manda te of the Commission, it was not practicable for two st aff to handle the Internal A udit processes of the Commission. The team also identified the vacant position(s) at the Audit D epartment. • The Human Resource Department must ensure that adequate staff are recruited for the Audit Department with the prerequisite qualifications and experience. • Additionally, it is recommended that capacity building should be extended to the two - support staff of the Audit Department to enhance their productivity in discha rging their duties 2. CORPORATE GOVERNANCE Handing Over Notes/Status Report No detailed handover notes / status reports from the previous Management were presented to the Review Team. The previous Management failed to properly give an accoun t of its stewardship and the status of the company at the time of leaving office. On the other hand, the current Management was complacent in ensuring that there was a proper handover process. A mechanism should be put in place for a detailed handing o ver note to be provided to the Internal Audit Department by any administration in the event of a transition.

11. 10 6 FLEET AND FUEL MANAGEME NT Flee t Lack of comprehensive Fleet Data and Database Management Accountable tools such as logbooks, Vehicle Movement Register, Vehicles Request Form etc, were not maintained. The Senior Driver and Supervisor Transport and Estates had no control on the movement of drivers and vehicles. Also, he had no formal training in Fleet Management • Accountable tools such as Logbooks, Vehicle Movement Register/Tracking System, Vehicle Request Form, Maintenance Reporting Template etc. should be developed by the Fl eet office r and be operational at all levels of the Commission. • The fleet officer should ensure that files are maintained for vehicles . • A credible data base of all automobiles under the purview of Commission should be developed, and regularly updated. • T he Commiss ion should ensure that a policy and/or contract be established with garage(s) through the Legal Department. Fuel Management it was observed that no technical knowledge was used to determine the quantum of fuel a vehicle or motorbike can consume p er kilometer covered We noted that there was no fuel reconciliation report with fuel suppliers on fuel allocation to the Commission. Also, no fuel reconciliation report was provided to the Team with regards the usage of fuel by the Commission. T here was n o policy on fuel allocation. • The Management of NATCOM should ensure that a policy of fuel management is established. • There should also be a framework Contract agreement between the supplier and the Commission With regards the suppl y of fuel and that s hould be in line with the procurement regulations. • The Commission should ensure that there is a regular reconciliation of fuel so as to establish the reorder level of stock, usage and balance. • The officer is charge of fuel should be t rained. • M anagement should embark on the modern - day fuel dispensation by initiating the electronic chit system (Tom Card) for staff and the Commission at large.

9. 8 presented was a listing of assets which did not reflect fixed assets registered. purposes. The assets can also be coded for ease of identification. 4 . BUDGET AND BUDGETARY MANAGEMENT Budget Participation The Review Team verified that the budget preparation was participatory by all heads of d epartme nt upon which submissions were incorporated into the Commission’s annual budget. The Management of the Commission must ensure that the budgetary participatory process is inclusive of both Management and lower - level staff. Budget Committee Th ere was no evidence to show that an independent Budget Committee to guide and regulate the budget process for the periods under review. A Minute of a Finance and Budget Committee was presented to the Review Team to show that such Committee existed. The C ommissi on should immediately constitute a Budget Committee comprising of all H eads of D epartments and representative of the Board. The Committee should be given freehand to guide the budget process 5. HUMAN RESOURCES MANAGEMENT Human Resour ces and Administration The Review Team observed that the Human Resources and Administrative Department was one and the same. Department. As a best practice and for effective checks and balances, the MoF and NATCOM must ensure that the Human Resources and Adm inistrative department are divided into two independent departments (i.e., the Human Resources (HR) Department and the Administrative Department). Job Description Job description is fundamental to good employment practices. It was observed that s ome of the staff files inspected do not have job descriptions. • The Human Resources Department should ensure that there are properly drafted job descriptions for every position in the Commission. • The Department should further ensure that all staff mem bers of the Commission are issued with the appropriate job description. Records Management It was observed that records were mostly maintained in soft copies. Hard copies were difficult to come by or access. There was no observed back up mechanism for digitiz ed records. • Management should develop a records management policy for the Commission. • Whilst it is laudable for the Commission to attempt to digitized its records management, however it must be properly done taking in consideration fraud and sec urity c oncerns, preservation and authenticity of records

12. 11 7 PROCUREMENT MANAGEMENT Procurement Plan I t was observed that the 2019 and 2020 p lans were exac tly the same. It was highly unlikely that an institution of this nature would have the same procurement plan for two consecutive years. The Procurement Officer should prepare a standardize procurement plan as prescribed by the A ct. P rocurement Com mittee The review Team observed that there was an existing Procurement Committee but not functional on regular basis. Furthermore, the Team further observed that certain procurement activities were not under the control of the Pro curement U nit and those activities did not follow due diligence as well as compliance mechanisms. The Management of NATCOM should ensure that the Procurement Committee restore full commitment in discharging their duties and ensure that all procurement a ctivities follow the due processes as demanded by law to promote transparency and accountability in public procurement of goods, services and works. Procurement Unit The Review Team observed that there was a Procurement Unit established at NATCOM but attached t o the Administ ration and Human Resources Department. However, the Team realized that the Procurement Unit report was supervised directly by the Director of Human Resources and Administration, who happened to be an active member in the Procurement Committee . • The Manag ement of NATCOM should ensure that the Procurement Unit is detached from the Administration and Human Resources department and be a standalone unit. • Also, Management must ensure that the Procurement Unit is directly supervised by a nd/or repo rts to the vot e controller, rather than to the Director of Human Resources and Administration. Records Management The Team also observed that procurement documents were all bungled up in files rather than it being separated and filed as Work s, Service s and Goods. The Procurement Unit must retain and maintain appropriate filing systems and/or records management to ensure effective storage, retrieval and use of records with due regards to security, integrity and confidentiality. 8. STORES MAN AGEMENT Stor e Environment The Store is not tidily kept and / or spacious as most of the items are obsolete. The Team found it very uncomfortable to work in the store as it was unsightly and the atmosphere was conducive for the Storekeeper to e xecute his duties. Ma nagement should ensure that a secured, conducive location is provided as storage to enable free movement and documentation of materials. This would enable materials to be easily traced.

8. 7 Board of D irectors We observed that their appointment letters did not specify how involved they would be in the day to day running of the comp any i.e., whether they are executive or non - executive B oard M embers. • The Act should be reviewed in order to clarify the role of the board as supervising body and the Director General as head of administration. • The appointment Letter must state whethe r the Board is a non - executive or executive board. If it a non - executive a written terms of engagement include job description should be given and if it is executive a service agreement setting out the terms of the directorship should be given. Board Re muneration/Expenses The Board Remuneration was determined by State House. There was no given format or policy on how the remunerations were determined. Further it was unclear as to what constituted legitimate expenses of the Board that should be funded b y the Commission. • A policy on Board remuneration and what constituted legitimate expenses of the Board should be developed and strictly implemented by the Commission. • Management should ensure that Board activities were properly planned and budgeted for and should be related to their function and the Commission. 3. FINANCIAL MANAGEMENT Financial Policy and Procedural Manual The Review Team was not provided with any financial manual of the Commission for the period under review despite the f act that, they work in line with the statutory financial instruments in carrying out their duties. The team was informed of a financial manual which was in a draft stage commencing 2021, but yet to be verified by the team The Management of NATCOM shoul d e nsure that a financial manual policy and Procedural manual is established and if so, the draft financial manual should be finalized and effected. Petty Cash N o policy on petty cash disbursement was presented to the team, though monthly reconciliatio n a nd/or retirement are done before a float was given. There were also delays in reimbursement of floats. The Management of NATCOM should ensure a policy on petty cash is effective and reimbursement should be timely. Cheque Withdrawals The team observe d t hat numerous cheques were drawn in the names of lower cadre workers of the Commission who were not members of the Finance Department . All payments should be done in line with best practices and also laws and regulations Fixed Assets Register The te am observed that the Commission does not maintain a fixed Assets Register as the document A Fixed Asset Register must be maintained so that assets are tracked, recorded fo r p roper reporting and audit

43. 42 Recommendation The Co mmission should immediately constitute a Budget Committee comprising of all heads of departments and representative of the Board. The Committee should be given freehand to guide the budget process. Management Response • A budget co mmittee will be establishe d representing all heads of departments . • There is an assigned staff from MoF who guides the budget process whenever there is a budget call but not stationed at the commission. 8 . 3 Budget Variance Section 30 (1) of the public financial management regu lations, 2018 states that “ A vote controller of a budgetary agency shall not incur or settle any commitment for which public money has not been provided by the State budget or authorized to be charged on the Consolidated Fund .” M oreover, sub (2) states th at “ When a budgetary agency has overspent a head or subhead of expenditures under the State budget or made unbudgeted expenditure, the Minister shall require the head of the budgetary or sub - vented agency to submit an ac tion plan under paragraph (b) of sub section (2) of section 120 of the Act, as soon as practicable after the end of a financial year ”. Findings The table below shows comparative analysis between the Budgeted income and exp enditures as against the Actual f or financi al year 2019. Activity Budget Le Actual Le Variance Le % Variance Income 182,886,631,000 .00 165,191,546,155.53 17,695,084,845 10 % Expenditure 190,7 95,737,176.60 168,071, 795,754.19 22,723,941,423 12% Gross profit/(Loss) (7,909 ,106,176) (2,880,250,599) (10,789 ,356,775) - 36 %

45. 44 increase of Le11,052,519,116.98 (Eleven billion and fifty - two million five hundred and ni neteen tho usand one hundred and sixte en Leones ninety - eight cents). Furthermore, no data was provided to the team with respect to FY 2018. Implication • Weak revenue generation. • Weak cost control. • Possible under reporting of revenue. • A negative gross margin is an ind ication that the Commission was unavailable to cover its operating costs and inability to control expenditures. Forecasters are unable to predict future costs and revenue with complete accuracy. Recommendation In order to maintain a favorable pr ofit, the Management of Netcom should ensure that the Commission’s costs/expenditures are reduced; turnover and efficiency are increased. Management Response Management will ensure that the Commission’s expenditures are reduce; turnover and efficiency are increase i n the future. • The actual fi gures were receipts and payments or cash based, not income and expenditure whilst the budgeted figures are on accruals basis (inclusive of debtors) and as result will not be consistent. In the Future we ensure budgets are prepare d on cash bases. • In additio n, t he reason for unfavorable variance in income for 2019 and 2020, was as a result of businesses closing down , and some service providers decommissioned their equipment • Lastly, t he C ovid 19 pandemic was a gain a major cause of i ncome deduction. 8 . 4 Vari ance in Budgeted line Activities/ Expenditures The Team took samples of Actual expenditures as outlined in the budget analysis and income and expenditure statement and verified them with payment vouchers to ascertain whether the actual amount stated on th e income statement reflects that of the vouchers. The following were the expenditure items upon which the survey was undertaken. • Workshop and seminar • Support to National Development • Public Relations and outreach • Fraud management and cyber security • License and insurance

44. 43 The table above shows summary of budgeted income and expenditure as against actual income and expenditure for the FY 2019. Actual income was lower than planned. There was an un favorable income variance of Le 7,6 95,084,845 i.e.1 0 % shortf all of the budgeted income. The table also shows that the actual expenditure was lower than anticipated. There was a favorable variance of Le22,723,941,423. i.e.12% less of projected expenditure. Column three of the tabl e reveals that the actual expenditu re was higher than the actual income for the year. There was a gross loss of Le2,880,250,599 (two billion eight hundred and eighty million two hundred and fifty thousand five hundred and ninety - nine Leones Additionally, a compar ative analysis between the Budgeted income and expenditures as against the Actuals for financial year 2020 is shown thus: Activity Budget Le Actual Le Variance Le % Variance Income 250,413,929,165.41 148,583,288,059.53 101,830,641,105.88 41 % Expendit ure 224,174,032,252.33 156,755,556,574.51 67,418,475,677.82 30% Gross profit/(Loss) 26,239,896,913.08 (8,172,268,514.98) 34,412,165,427 31% The above shows a comparative analysis of budgeted income and expenditure as to actual incom e and expe nditure. Like 2019, Actual income generated in 2020 was lower than planned. There was an unfavorable income varianc e of Le 101, 830,641,105 i.e. 41 % shortfall of the budgeted income. The variance was greater than the variance in 2019. The table al so shows t hat the actual expenditure was lower than anticipated. There was a favorable variance of Le67,418,475,677. i.e. 30% less of projected Expenditure. Column three of the table reveals that the actual expenditure was higher than the actual income for the year for the second consecutive year. There was a gross loss of Le8,172,268,514 (eight billion one hundred and seventy - two million, two hundred and sixty - eight thousand five hundred and fourteen Leones. This was a greater loss than that of 2019. Fro m all indi cations, the above tables illustrate the progressive loss in the Commission’s income statements from 2019 ( Le2,880,250,599) to 2020 (Le8,172,268,514.98 ); an

10. 9 Performance Appraisal The team observed that performance reviews have not been conducted regularly as prescribed in the policy. Performance appraisals must be done regularly as prescribed in the Pe rformance Management Policy to improve staff performance and productivity. Strategic Plan The Review Team observed that was an existing five year strategic plan (2017 - 2021) and that the Commission had already commenced the development of the ( 2022 to 2027) Strategic Plan which was currently in the draft stage. • The Management of the Commission should ensure that activities in the strategic plan (2017 - 2021) are exhaustive and attained within the time frame. • Also, the draft Strategic Plan sh ould on ly be operational in the prescribed year. Staff Personal Files /Records The Team observed that most of the staff files examined were without certificates and/or not updated with the necessary information and/or documents The Human Resources M anager must ensure all staff files were regularly updated and all gaps identified by the team are regularized. Organizational Structure The Review Team observed that the Organogram was incomprehensive and limited to few departmental heads. There were a numbe r of departments or offices that were not captured in the Organogram The Commission should immediately review its Organizational structure by separating clustered departments distinctly showing reporting lines. Staff Qualification T he Team obse rved th at most staff did not have the required qualification(s) that best suited their positions. The Team also observed that some staff qualifications did not match with the work designated. • The Management and the Board should ensure a comprehensive Hu man Res ource Audit is conducted by the Internal Audit Department. • Moreover, the HR should ensure that all staff should submit their original qualifications for verification. Canteen Services T he Team was not provided with any information on the sourc ing of contractor for the canteen. More so the Team observed that there was no contract or rather signed MoU between the Canteen Contractor and the Commission. • Management should ensure that the proper procurement procedure in the sourcing out of contractors for the canteen is applicable. • Furthermore, a MoU and/or contract must be prepared and signed by both parties (The Commission and the Canteen Management) to ensure smooth running of business.

49. 48 The above table reveals variances with respect to budget and actual alongside percentages and payment vouchers of respective sample transactions. With reference to Support to National Development, it showed t hat only 50 % of the budget w as utilized and a variance 3 0 % of the supporting documents could not be found. Moreover, Public Relations and Outreach showed that 31% of the budget was actualized leaving variance of 69% . Also, the table shows that 81% of th e budget wa s over spent on S ecurity Service, while 2 0 % was the variance between the actual and payment vouchers. Additionally, 48% excess was utilized from the budget giving a variance of Le383,050,000 and equilibrium payment vouchers verification. Mana gement Resp onse • The budget a gainst actual report will now be prepared , variances investigated and corrective actions implemented quarterly. • The actual report will also be compared to both hard and soft copies of payment vouchers to ascertain any variance i n documenta tion • For Public R elations, the payments vouchers exceeded the actual payments because there was re - classification of the expenses. 9 .0 HUMAN RESOURCES MANAGEMENT According to Eric Flamholtz, “ Human Resource Audit is a systematic assessment of the stre ngths, limitation s, and developmental needs of its existing human resources in the context of organizational performance .” Also Gary Dessler stated that, “ Human Resource Management is the process of acquiring, training, appraising, and compensat ing employe es, and attending to their labour relations, health, safety and fairness concerns .” 9 .1 Human Resources and Administration Findings The Review Team observed that the Human Resources and Administrative Department was one and the same Departmen t. This me rged department c overed the following Units: • Procurement • HR

84. 83 Section 2(1) Public Debt Management Act 2011 states that” Subject to section 118 of the Constitution, the Minister shall have sole authority to borrow money on behalf of Government by concluding loan agreements, issuing G overnment se curities, or ente ring into supplier’s credit agreements and to issue Government guarantees, both in Sierra Leone and elsewhere and in local and foreign currencies ” . O n 25 th March, 2020 NATCOM applied for the loan of L e 50bn (fifty billion Leone s) from S ier ra L eone C ommerci al B ank (SLCB) through the Ministry of Information and Communications and the Ministry of Finance for the primary purpose for the completion of the NATCOM building. On 27 th March, 2020, the board of Commissioners unanimously re solved to se cure funds in ord er to complete the project as a matter of priority. NATCOM Capital Development Account was opened at SLCB and a loan of Le50bn was approved and subsequently credited into the account on five installment payments from September 2020 to Sep tember 2021 with an interest of 18% for a period of 36 months. NATCOM issued a standing order to the BSL to debit its di s bursement account and credit the NATCOM Capital Dev. Account on a monthly basis with L e 1,500,000,000 (One Billion, Five Hundred Mill ion Leones) to me et the required debt service payment until the loan is amortized. Standing Order is to be credited to NATCOM Capital Development Account on or before 24 th of every month. There has been delay and as a result interest is levied on the loan amount. Due to th e delay, interest on Loan has accrued into billions. Moreover, BSL could not honour such due to insufficient funds to meet the standing order. Below is the breakdown of the schedule of payment to international construction com pany (ICC): Type Date Memo AM OUNT Deposit 10/09/2020 Loan IRO Building Project from SLCB 9,868,610,000 Deposit 30/10/2020 Loan iro of new building 2nd installment 9,868,610,000 Deposit 24/12/2020 Loan iro of Building project 9,868,610,000 Deposit 30/ 04/2021 paym ent in respect of building project 9,585,170,000 Deposit 22/09/2021 Long term loan iro building project final credit 10,809,000,000 TOTAL 50,000,000,000

4. 3 8.0 BUDGET AND BUDGETARY MANAGEMENT ..................................................... 40 8.1 Budget Participation ...................................................................................... 40 8.2 Budget Committee ........................................................................................ 41 8.3 Budget Variance ..................... ...................................................................... 42 8.4 Variance in Budgeted line Activities/ Expenditures ............................................... 44 9.0 HUMAN RESOURCES MANAGE MENT .............................................................. 48 9.1 Human Resources and Administration ............................................................... 48 9.2 Job Description ............................................. ................................................ 49 9.3 Records Management ..................................................................................... 50 9.3 Staff List ....................................................................................................... 51 9.4 Staff Attendance Register ................................................................................. 52 9.5 Performance Appraisal .................................................................................... 53 9.7 Staff Personal Files /Records ............................................................................ 54 9.9 Staff Qualification ............................................................................................ 55 9.10 Canteen Services .......................................................................................... 56 10.0 FLEET AND FUEL MANAGEMENT .................................................................... 57 10.1 Fleet ........................................................................................................... 57 10.2 Fuel Management .......................................................................................... 58 11.0 PROCUREMENT MANAGEMENT ...................................................................... 59 11.1 Procurement Plan .......................................................................................... 59 11.2 Procurement Committee .................................................................................. 60 11.3 Procurement Unit ........................................................................................... 62 11.4 Staff Capacit y ................................................................................................ 63 11.5 Records Management (Filing System) ................................................................. 64 11.6 Debriefing to | Unsu ccessful Bidder ..................................................................... 65 11.8 List of Supplier/ Vendors ................................................................................... 66 11.9 Sale of Bidding Documents ............................................................................... 67 11.10 Payables to supplies ...................................................................................... 67 11.10.1 Goods .......................................... .......................................................... 68 11.10.2 Works .................................................................................................... 70 11.10.3 Services ................................................................................................. 70 11.10.4 Air Ticket/Travel Agencies .......................................................................... 71 12.0 STORES MANAGEMENT .................................................................................. 74 12.1 Store Environment .......................................................................................... 74 12.2 Staffing ......................................................................................................... 75 12.3 Qualification of Storekeeper .............................................................................. 76 12.4 Monitoring and Supervision ............................................................................... 76 12.5 Store Bin Card ................................................................................................ 78 13.0 UNIVERSAL ACCESS DEVELOPMENT FUND (UADF) ........................................... 79 14.0 PROJECT MANAGEMNT ................................................................................... 82

37. 36 The R e vie w Team further observed that cheques for the payment of suppliers were drawn in the names of staff also. Some payment vouchers inspected , showed c heques were drawn in the name of the dispatcher rather than in the name of the contractor, supplier or Individual. Implication T he risk involves in writing chegues in the name of a person who have no bearing with that transaction is very high a nd there c ould be a tendency of cheque fraud. This will involve breach of financial laws and regulations and hence the tendency of implied fictitious transactions or shady deals. Recommendation ▪ All payments should be done in line with best practices and also finan cial laws and regulations. ▪ F or activities which would require cash disbursement such as retreat or honorarium, cheques should be writing in the name of the Contractor and deposited in his /her account. If payment should be made cash, then an offi cer from t he Finance D epartm ent should be bearer of the che que. • Furthermore, the Finance Department should desist from writing cheque in huge sums payable to an office assistant and/or dispatch. Management Response The finance unit will desist from such practice g oing forward. Date Payment Voucher Number Description Cheque drawn in the Name Cheque Num ber Amount Le 31/1/19 14595 Payment IRO retreat/honorarium in BO at J & E Hotel Dispatcher 00098778 37,400,000 31/1/19 14594 Payment iro Retreat/honorarium Dispatcher 00098777 50,000,000 12/12/19 13329 Payment for the use of Miatta Conferenc e Centre f or the launching of regional free roaming service. Dispatcher 00118692 6,000,0000

3. 2 TABLE OF CONTENTS List of Acronyms .................................................................................................. 5 Executive Summary .................. ........................................................................... 6 INTERNAL AUDIT AND RISK MANAGEMENT .......................................................... 6 BUDGET AND BUDGETARY MANAGEMENT .................................... ...................... 8 1.0 INTRODUCTION ........................................................................................... 14 2.0 OBJECTIVES ............................................................................................... 14 3.0 SCOPE AND METHODOLOGY ........................................................................ 15 FINDINGS AND RECOMMENDATIONS ................................................................. 15 4.0 INTERNAL AUDIT AND RISK MANAGEMENT ................................................... 15 4.1 Audit Manual ............................................................................................. 15 4.2 Audit Committee ....................................................................................... . . 17 4.3 Annual Audit Plan ..................................................................................... . . 17 4.4 In ternal Audit Queries . ............................................................................... . . 18 4.5 External Audit .......................................................................................... . . 19 4.6 Staffing ..................... .............................................................................. . . 20 4.7 Reporting Line of the Internal Auditor ............................................................ . . 21 5.0 CORPORATE GOVERNANCE ............ ......................................................... . .. 22 5.1 Handing Over Notes/Status Report ............................................................... .. 22 5.2 Due Deligence on Natcom by the Curre nt Management .................................... .. 22 5.3 Strategic Plan .......................................................................................... .. . 23 5.4 Board of Directors ......................................................... ........................... .. . 24 5.5 Organizational Structure ........................................................................... ... . 24 5.6 Board Structure ....................................................................................... .. . 25 5.7 Board Remuneration/Expenses .................................................................. ... 26 5.8 Development of Regulatory tool ..................................................................... 26 5.9 Legal Department ....................................................................................... 27 5.10 Policy and Governance .............................................................................. 29 5.10.1 Annual Work Plan ................................................................................. 30 5.10.2 Annual Activities Report ......................................................................... 30 5.10.3 Policy /Regulation Development. .............................................................. 31 6.0 FINANCIAL MANAGEMENT ........................................................................... 31 6.1 Financial Policy and Procedural Manual ........................................................... 31 6.2 Area of Focus: Petty Cash ............................................................................. 32 6.3 Area of Focus: Revenue Generation ................................................................ 33 6.4 Cheque Withdrawals .................................................................................... 35 6.5 Withholding Tax Payment (WHT), NASSIT Contribution &PAYE ........................ 37 6.6 Fixed Assets Register ................................................................................... 38 7.0 DEBT MANAGEMENT .................................................................................... 39

83. 82 Implications • Converting the loan into an expense (bad debt), witho ut justifica tion was a bad ec onomic/financial practice which had the tendency to impact negatively on the company’s financial status. • Additionally, the manner in which the transaction took place looked very shady. It would be considered as an insider de aling and/or related party’s transaction. Recommendation • The Management of UADF should embark on a nationwide public education. • Moreover, since a percentage has been determined as stipulated in the Regulation, the legal department of NATCOM should pre pare a payme nt plan in addend um to the previous payment plan prepared by UADF. The contract should be inclusive of both parties. • Also, the Management of UADF should effect a penalty clause on defaulters as stated by Section 7(3a) of the regulation. • The Management of NATCOM should stop treating the item as expense but rather a long - term loan as there was an agreement of repayment. • T here should be a comprehensive loan policy • The Internal Audit department should conduct a full - blown investigation on t he entire lo an process. Mana gement Response • NATCOM will encourage UADF to engage the public more effectively. • A payment plan will be prepared by NATCOM with ( inclusive parties ) to address this issue. • NATCOM will ensure a penalty clause be included i n the contra ct to enforce pay ment. • NATCOM will review the loan agreement and revise treatment of this as an expense and considered treating it as a long - term loan. • NATCOM will develop a loan policy • The Internal Audit department will conduct a compreh ensive inves tigation on the l oan process and will revert to Management for appropriate action. 1 4 .0 PROJECT MANAGEMNT NATCOM commenced a building project situated at South Ridge – IMATT in February 2016 and consulted TS & Co. Consortium and contracted I nternational Construction Com pany.

48. 47 2 020 Activity Budget Le A Actual Le B Variance Le C = (A - B) % Variance D = (C/A)*100 % Budget E = 100 - D Payment vouchers verification F Variance between Actual and payment vouchers G = B - F % difference actual and paymen t vouchers H= (G/B)*100 S upport to National Development 5,828,428,782.84 2,907,575,900.00 2,920,852,882.84 50% 50% 2,046,242,070.00 861,315,830 30% Public Relations and Outreach 1,195,726,833.15 375,110,000.00 820,616,833.1 5 69% 31 % 375,110,000.00 0 0% Security services 131,117,739.84 717,870,000.00 (586,752,260.16) - 81% 181% 577,220,875.00 140,649,125 20% Fraud management and cyber security 801,750,000.00 1,184,800,000.00 ( 383,050,000.00 ) - 48% 148% 1,184,800,000 0 0

47. 46 The above table shows the irregularities and/or inconsistencies in reporting actual amounts of expenditures as compared to total amounts on vouchers with respect to each activity stated. The differences in column (G) sho w the unacc ounted amounts (v ariances) between the actuals and the payment vouchers. Also, column H shows the percentage differences of the unaccounted amount. In essence, the total am ounts in the vouchers could not match up with the actual amounts recorded in the Inc ome statement . Activity Bud get Le A Actual Le B Variance Le C = (A - B) % Variance D=(C/B)*100 % Budget E = 100 - D Payment vouchers verification F Variance between Actual and payment vouchers G = B - F % difference actual and payment vouchers H= (G/B)*100 Support to Nat ional Devel opment 6,500,000,000.04 7 ,005,057,604.38 - 505,057,604.34 - 8% 108% 6,071,845,971.53 933,211,632.77 13 % Workshop and seminar 1,809,699,999.96 1,683,494,591.30 126,205,408.66 7% 93% 1,683,494,591.30 0 0 % Publ ic Relation s and outreach 2,082,999,99 9.96 1,856,697,592.00 226,302,407.96 11% 89% 615,920,000 1,240,777,592 69% Fraud management and cyber security 1,536,000,000.00 1,385,606,500.00 150,393,500 10% 90% 1,389,206,50 0.00 - 996,400,000 26%

70. 69 2 1 Procuremen t of Football Kits 40,813,500 RFQ 3rd December, 2019 22 Drilling of borehole at Kenema Government Hospital 176,500,000 RFQ 12 December, 2019 23 Procurement of computers, printers and accessories 981,557,732 NCB 20 November, 2019 24 Insurance 261,231,282 .84 6 Decemb er, 2019 25 Procurement of Goods (Assorted Office Equipment for NATCOM HQ 81,730,500 RFQ 26November 2019 26 Procurement of Good (Assorted Items Needed for Precautionary Health Measures for NATCOM HQ and Zonal Offices) 7,475,000 R FQ 20 Februa ry, 2019 27 Procurement of Goods (Replacement of AC Unit at Drives Offices 14,728,500 RFQ 25 March, 2020 28 Procurement of Goods (Door Tags for the Commission) 36,500,000 RFQ 21 February, 2020 29 Procurement of Goods (Laptop for PA to DG & A ssistant Man ager PRA NATC OM) 64,400,000 RFQ 12 February, 2020 30 Procurement of Goods (Toners Ink Cartridge for DDG, Finance & Engineering 29,440,000 RFQ 10 January, 2020 31 Procurement of Goods (Laptops for Strategic Communications Unit at State House, office of t he President) 128,800,000 RFQ 12 February, 2020 32 Procurement of Goods (Toners for Finance Department for the Printing of Budget & Invoices 48,300,000 RFQ 18 November, 2019 33 Procurement of Toners for DG's Printer, Secretary to DG, Procurem ent Unit Reg ulatory Affai rs and Board Room & Legal Dept. 48,300,000 RFQ 15 November, 2019 34 Procurement of Goods 15 Tire and 1 Battery for the Commission Vehicles 35,535,000 RFQ 29 November, 2019 35 Procurement of Goods Additional Tyres and Batteries 72,162,000 R FQ 12 Novembe r, 2019 Grand Total 3,266,283,814.84

69. 68 and the g reatest chunk o f the debts were on the procurement of Air Tickets. The Team further categorized the liabilities of the Commission into four categories (goods, services, works and air tickets) for clarity. Please see list below: 11.10 Goods NO CONTRACT DI SCRIPTION CO NTRACT AMOUNT (Le) PROCUREMENT METHOD RFQ Issue Date 1 Procurement of Goods Outer Tires for NATCOM Vehicles 58,707,500 RFQ June, 2019 2 Procurement Goods of Electricals Fittings for NATCOM HQ 42,320,000 RFQ 11 October, 2019 3 Procuremen t of Goods Ve netian Blind for Moyamba Zonal Office 30,360,000 RFQ 19November,2019 4 Procurement of Air Conditions (Conference Room) 109,710,000 RFQ 5th April, 2019 5 Procurement of Goods (NATCOM Caps, T - shirts, Teacup & Water Bottle ) 96,000, 000 RFQ 15th November, 20 19 6 Procurement of Goods Assorted Furniture for the Office of the Director General 28,175,000 RFQ 18th November, 2019 7 Procurement of Goods Christmas Hamper (Super Premium) 197,830,000 RFQ 12November, 2019 8 Procurement of Ba ttery, Outer Tyres, Seat Cover, Floor Mat and Steering gloves 72,162,000 RFQ 12 November, 2019 9 Procurement of Heavy Duty Extension Cable, LG DVD Player and Wireless Microphone 9,430,000 RFQ 13 November, 2019 10 Procurement of Goods (Replacement of Ai r Conditione rs) 20,500,00 0 RFQ 8 November, 2019 11 Procurement of Goods Venetian Blind Moyamba Zonal Office 30,360,000 RFQ 1 November, 2019 12 Procurement of Goods (Calendars’ for 2020) 193,000,000 RFQ 1 November, 2019 13 Procurement of Goods (Office S tationery fo r NATCOM HQ 2 5,405,800 RFQ 28 October, 2019 14 Procurement of Goods (Assorted Goods for CTO Conference 76,705,000 RFQ 15 November, 2019 15 Procurement of Goods (Assorted Goods for Recruitment Purpose at NATCOM HQ 73,600,000 RFQ 16 October, 2019 16 Pro curement of G oods (Assorted Goods for NATCOM HQ) 45,770,000 RFQ 15 November, 2019 17 Procurement of Goods (10KVA UPS for Saver 51,700,000 RFQ 30 September, 2019 18 Procurement of Goods (3) 6KVA Generators for Newly Opened Zonal Offices Moya mba, Pujehun and Matru Jo ng 55,200,000 RFQ 7 October, 2019 19 Procurement of Goods for PA System Accessories 9,430,000 RFQ 19 September, 2019 20 Procurement of Drinking water for January to December 2020 for NATCOM HQ 17,620,000 RFQ 16 January, 2020

71. 70 11 .10. 1 Works 11 .10. 2 Services NO CONTRACT DISCRIPTION CONTRACT AMOUNT (Le) PROCUREMENT METHOD RFQ Issue Date 1 Procurement of Services (Clearing of Septic Tanks) 5,700,000 RFQ 1 - 10 - 2019 2 Procurement of Services (Corporat e Ringtone f or Media Outrea ch Events & Staff Caller Ring Back) 6,000,000 RFQ 1 - 11 - 2019 3 Procurement of Services Quick Books Accountancy Service for 3 Months 31,800,000 RFQ 15 - 10 - 2019 4 Procurement of Services (Printing of Assorted Office Items) 38,100 ,000 RFQ 4 - 1 1 - 2019 5 Procu rement of Services T Shirt and Caps for the Reopening of Moyamba Zonal Office 10,500,000 RFQ 26 - 09 - 2019 6 Procurement of Services (Printing of T - Shirt, Brochure and Invitation for Regional Free Roaming Workshop 56,500,000 RFQ 20 - 11 - 201 9 7 Procuremen t of Services (Transportation and Assembling of Goods at the Commission's Zonal Offices 81,007,003 RFQ 4 - 11 - 2019 8 Procurement of Services Staff Party 97,531,500 RFQ 29 - 11 - 2019 9 Procurement of Services Washing of the Comm ission Vehic les for January - March 2020 104,640,000 RFQ 10 Procurement of Services (Décor Services for Cyber Security Workshop 4,600,000 RFQ 6 - 12 - 2019 11 Procurement of Services (Building of 2 Zinc Structure and Brushing of 21 acres of land at big wata 110,200 ,000 RFQ 16 - 12 - 2019 Grand Total 546,578,503 NO CONTRACT DISCRIPTION CONTRACT AMOUNT (Le) PROCUREMENT METHOD RFQ Issue Date 1 Procurement of Services (Clearing of Septic Tanks) 5,7 00,000 RFQ 1 October, 201 9

35. 34 Revenue Streams 2018 Le 2019 Le 2020 Le GSM Licenses 12,049,298,414.11 35,750,907,847.09 31,808,671,342.83 ISP WIMAX 340,467,408.42 599,261,389.33 1,564,885,667.66 2 Way Radio Amateur/VHF 68,250,000.00 105,299,663.00 95,160,28 8.00 FM Licenses 124,807,863.15 632,7 61,729.99 555,063,903.10 VSAT 956,262,168.19 1,158,303,269.86 553,175,141.04 TV Licenses 952,110,351.58 989,649,569.47 675,638,390.00 CDMA International Gateway 32,784,556,998.21 50,139,558,024.85 52,837,868,22 8.12 Othe rs 379,137,566.26 124,118,750 .00 Type Approval 168,027,800.95 365,102,307.08 293,455,202.45 Microwave Link 129,259,899.43 0 207,349,354.40 Fines 0 16,500,000.00 1,362,300,000.00 Local Interconnect 15,248,247,460.29 26,067,622,87 3.75 1,4 90,698,218.72 Ship station and Amateur Radio 3,415,603.50 19,229,410.00 2G, 3G and 4G Licenses 66,830,604,154.41 48,697,303,083.61 48,521,843,541.73 Uncategorized Income 1,291,197,571.47 37,556,665.00 42,646,868.00 VHF 1 35,518,440 .60 236,778,634.50 588,102,32 3.10 Special Numbering Resource 59,200,000.00 2,697,258,380.20 Dealer licensees 9,750,000.00 Call sign 29,260,488.14 Spectrum Resources 3,444,943,734.16 Satellite Phone 4,041,068.00 Royalty Licenses and Resource fees – Others 7,091,607,394.44 251,592,938.00 141,925,529.50 Totals 142,066,662,829.17 165,191,546,155.53 143,469,343,934.99 From the data above, we observe d that revenue generated in 2019 was highe r than revenue generated in 2018 a nd 2020. It was further obser ved that there was a sharp increase in revenue from 2018 to 2019 by Le 23,124,883,326, which is about 16% increase in revenue generated between the two years. The Commission experi enced a

13. 12 Qualification of Storekeeper T he Team obser ved that t he Storekeeper had no knowledge or the pre - requisite qualification for discharging his duties. Management should ensure that the storekeeper be provided with the required training in the discharge of his functions for effective and efficient s ervice del ivery. Moni toring and Supervision The Review Team observed that there was less and/or no supervision on the activities of the storekeeper • The Management of NATCOM should ensure that the storekeeper follows the due processes on store requisit ion and is sues. • Moreove r, the Commission should develop a policy on stores management and ensure it strict adherence. 9. LEGAL DEPARTMENT The Review Team observed that the Commission had both a Legal retainer and a Legal Department which comprised lawyers. Furthermo re, a budget was provided for the Legal retainers and the legal services; both of which performed the same role No contract agreement was provided to the Team with respect to the legal retainers and they were paid on an annual basis. Th e legal department was under staff with only three personnel of whom two are lawyers and a secretary. • The Management of NATCOM should ensure that best practice was implemented by ensuring that the legal team was mandated to represent the Compan y in litig ation processes (i f any). • Also, the legal department should be fortified with additional legal practitioners thereby eliminating the functions of the retainers. 10 UNIVERSAL ACCESS DEVELOPMENT FUND (UADF) NATCOM had given out Le 2,931,612, 800 (two billion nine hundred and thirty - one million six hundred and twelve thousand eight hundred Leones) as accumulated loan amount to UADF for the period December 2018 - December 2020 inclusive. Also, the Management of UADF should effect a p enalty cla use on defaulters as s tated by Section 7(3a) of the regulation

72. 71 11 .10. 3 Air Ticket/Travel Agencies No Company Amount Date Route 1 Angelco Company (Sl)Limited 20,850,000 26/7/2019 LhrCdgLhr 2 Angelco Company (Sl)Limited 54,700,000 8/6/2019 Fna Ad d Fna 4 Ang elco Company (Sl) Limited 20,550,000 13/7/2019 FnaKglFna 5 Angelco Company (Sl)Limited 57,590,000 24/9/2019 Fna Ebb Fna 6 Angelco Company (Sl)Limited 16,170,000 11/6/2019 FnaOuaFna 7 Angelco Company (Sl)Limited 20,550,000 14/07/2019 FnaKglFna 8 Angelco Company (Sl)Limit ed 29,890,000 24/09/2019 Fna Ebb Fna 9 Angelco Company (Sl)Limited 33,000,000 13/6/2019 FnaLfwFna 11 Angelco Company (Sl)Limited 52,700,000 17/7/2019 LhrFnaLhr 12 Angelco Company (Sl)Limited 57,590,000 2/10/2019 Fna Ebb Fna 13 Angelco Company (Sl)Limit ed 12,200,000 14/6/2019 FnaDssFna 14 Angelco Company (Sl)Limited 28,700,000 18/7/2019 FnaIadFna 15 Angelco Company (Sl)Limited 26,980,000 6/10/2019 Date Change 16 Angelco Company (Sl)Limited 41,500,000 13/7/2019 FnaKglFna 1 7 Angelco Co mpany (Sl)Limited 20,850,000 26/7/2019 LhrCdgLhr 18 Angelco Company (Sl)Limited 9,500,000 7/10/2019 Date Change 19 Angelco Company (Sl)Limited 20,550,000 13/7/2019 FnaKglFna Total 23,870,000 11.10. 4 Company Amount Date Route 1 Blue Whale Trave l Agency 79,890,0 00.00 31/10/2019 FnaTllFna Total 79,890,000.00 Cinderella Travel & Tours No Comp a ny Amount Date Route 1 Cinderella Travel & Tours 34,300,000.00 16/11/2019 FnaDssFna 2 Cinderella Travel & Tours 24,500,000.00 22/11/2019 F naMpmFna 3 Cinderella Travel & Tours 3,700,000.00 27/11/2019 Date Change 4 Cinderella Travel & Tours 18,750,000.00 16/11/2019 FnaCaiFna 5 Cinderella Travel & Tours 46,500,000.00 22/11/2019 FnaMpmFna 6 Cinderella Travel & Tours 24,500,000.00 27/11/2 019 Date Cha nge 7 Cinderella Travel & Tours 18,750,000.00 16/11/2019 FnaCaiFna 8 Cinderella Travel & Tours 67,000,000.00 22/11/2019 FnaSshFna 9 Cinderella Travel & Tours 37,500,000.00 8/12/2019 FnaTunFna 10 Cinderella Travel & Tours 2,000,000.00 21 /11/2019 Dat e Change 11 Cind erella Travel & Tours 12,700,000.00 23/11/2019 FnaAccFna

29. 28 for the Legal retainers and the legal services; both of which performed the same role. • Addi tionally, litigation on behalf of the Com mission was seldom and/or none in a year as a result payments were being made for no service. • No contract agreement was provided to the Team with respect to the legal retainers and they were paid on an annual basis . • The lega l department was under staff wi th only three personnel of whom two are lawyers and a secretary. • The legal department could not provide annual work plan for periods under review to the Team. Implication Having a legal department and hiring a priv ate retain er is an extra cost on the Comm ission. Recommendation • The Management of NATCOM should ensure that best practice was implemented by ensuring that the legal team was mandated to represent the Company in litigation processes (if any). • Also, the leg al departm ent should be fortified with ad ditional legal practitioners thereby eliminating the functions of the retainers. Management Response • Any established Institution should have Retained Lawyers (Retainership) acting for and on behalf of the Commissi on on comp lex issues and give independent advice and address all legal issues on behalf of the Institution. NATCOM is no exception in that regard. The Director and his team are often busy and inundated with other matters such as; drafting of legal instrum ents, cont racts, agreements and respondin g to letters, enquiries/queries addressed to the Commission. • In addition to attending external meetings and conferences nationally and internationally on behalf of the Commission. • The Commission as such, cannot gi ve indepen dent advice unlike Retainers , w ho can devoid of political interference and are bound by such advice. NATCON cannot take its in - house lawyers to court in the event of giving misguided opinion, but can do so in the case of Retainers. Only Le75,0 00,000.00 (Seventy - Five Million Leones) w as paid to Retained lawyers last year. It is a known fact that lawyers can charge

74. 73 11.10. 5 Leone Wing Travel & Tours No Comp a ny Amount Le Date Route 1 Leone Wing Travel & Tours 14,900,000 28/8/20 19 FnaLfwFna 2 Leone Wing Tr avel & Tours 34,500,000 18/10/2019 FnaDxbFna 3 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna - Abj - Fna 4 Leone Wing Travel & Tours 14,900,000 28/8/2019 FnaLfwFna 5 Leone Wing Travel & Tours 34,500,000 18/10/2019 FnaD xbFna 6 Leo ne Wing Travel & Tours 15,500,000 16/8/2019 Fna - Abj - Fna 7 Leone Wing Travel & Tours 14,900,000 28/8/2019 FnaLfwFna 8 Leone Wing Travel & Tours 18,300,000 26/11/2019 CkyAbjFna 9 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna - Abj - Fna 10 Leone W ing Travel & Tour s 93,730,000 29/8/2019 FnaLhrFna 11 Leone Wing Travel & Tours 107,680,000 28/11/2019 FnaAtlFna 12 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna - Abj - Fna 13 Leone Wing Travel & Tours 6,000,000 1/9/2019 Date Change 1 4 Leone Wing Travel & Tours 10,000,000 30/11/2019 Date Change 15 Leone Wing Travel & Tours 15,500,000 16/8/2019 Fna - Abj - Fna 16 Leone Wing Travel & Tours 93,970,000 8/9/2019 FnaLhrFna 17 Leone Wing Travel & Tours 14,770,000 22/3/2019 Fna - Abv - Fna 18 Leone Win g Travel & Tours 15,500,000 16/8/2019 Fna - Abj - Fna 19 Leone Wing Travel & Tours 34,500,000 18/10/2019 Fna Add Fna 20 Leone Wing Travel & Tours 27,000,000 22/3/2019 Fna - Abv - Fna 21 Leone Wing Travel & Tours 28,250,000 20/08/2019 Fna - Abj - Fna 22 Leo ne Wing Travel & Tours 6,000,000 26/8/2019 Date Change 24 Leone Wing Travel & Tours 6,000,000 26/8/2019 Date Change 25 Leone Wing Travel & Tours 6,000,000 26/8/2019 Date Change 26 Leone Wing Travel & Tours 28,250,000 20/8/2019 Fna - Abj - F na 27 Leone Wing Travel & To urs 28,250,000 20/8/2019 Fna - Abj - Fna 28 Leone Wing Travel & Tours 28,250,000 20/8/2019 Fna - Abj - Fna Total 743,650,000 The tables above show the various suppliers to whom NATCOM is indebted to , for various services do ne varying f rom goods, works and services inclusive of Airlines tickets. A total of Le3,818,562,317.84 (three billion eight hundred and eighteen million five hundred and sixty two thousand three hundred and seventeen Leones eighty four cents) was indebted by NATCOM to various supplier s for Works, Goods and Services.

73. 72 12 Cinderella Travel & Tours 14,500,000.00 9/12/2019 FnaAccFna 13 Cinderella Travel & Tours 2,000,000.00 21/11/2019 Date Change 14 Cinderella Travel & Tours 12,700 ,000.00 23/1 1/2019 FnaAccFna 15 Cinderella Travel & Tours 14,500,000.00 9/12/2019 FnaAccFna 16 Cinderella Travel & Tours 24,500,000.00 22/11/2019 FnaMpmFna 17 Cinderella Travel & Tours 3,700,000.00 27/11/2019 Date Change 18 Cinderella Travel & Tours 89,500,000 .00 19/12/2019 Fn aLhrFna 19 Cinderella Travel & Tours 33,500,000.00 15/11/2019 Fna Add Fna 20 Cinderella Travel & Tours 21,300,000.00 24/1/2020 FnaNboFna 21 Cinderella Travel & Tours 109,550,000.00 27/9/2019 FnaDacFna 22 Cinderella Trave l & Tours 2 1,300,000.00 24/1 /2020 FnaNboFna 23 Cinderella Travel & Tours 89,350,000.00 29/10/2019 FnaSshFna 24 Cinderella Travel & Tours 62,390,000.00 11/6/2018 FnaXnbFna 25 Cinderella Travel & Tours 27,500,000.00 6/10/2019 FnaRaiFna 26 Cinderella Travel & Tou rs 18,923,000.00 1/5/2019 LhrFnaLhr 27 Cinderella Travel & Tours 59,300,000.00 10/11/2019 FnaCptFna 28 Cinderella Travel & Tours 47,350,000.00 18/9/2019 FnaIadFna 29 Cinderella Travel & Tours 33,530,000.00 10/11/2019 FnaJnbFna Total 975 ,593,000.00 Omed Travel and Tours No Company Amount Date Route 1 Omed Travel And Tours 2,000,000.00 2/12/2019 Date Change 2 Omed Travel And Tours 78,720,000.00 3/8/2019 FnaLhrFna 3 Omed Travel And Tours 97,500,000.00 4/9/2019 Fna Bud Fna 4 Omed Trav el And Tours 2,000,000.00 2/1 2/2019 Date Change 5 Omed Travel And Tours 78,720,000.00 3/8/2019 FnaLhrFna 6 Omed Travel And Tours 91,550,000.00 5/9/2019 Fna Bud Fna 7 Omed Travel And Tours 37,000,000.00 30/11/2019 FnaEwrFna 8 Omed Travel And Tours 47,50 0,000.00 28/ 8/2019 Fna Bud Fn a 9 Omed Travel And Tours 27,800,000.00 20/11/2019 FnaAccFna 10 Omed Travel And Tours 135,000,000.00 30/11/2019 FnaAtlFna 11 Omed Travel And Tours 41,500,000.00 4/9/2019 Fna Bud Fna 12 Omed Travel And Tours 12,900,000.00 21 /11/2019 Fna AccFna 13 Omed T ravel And Tours 12,900,000.00 21/11/2019 FnaAccFna 14 Omed Travel And Tours 3,900,000.00 26/11/2019 Date Change 15 Omed Travel And Tours 59,850,000 2/8/2019 FnaKglFna 16 Omed Travel And Tours 59,850,000 2/8/2019 FnaKglFna 1 7 Omed Trave l And Tours 41,50 0,000 4/9/2019 Fna Bud Fna 18 Omed Travel And Tours 41,500,000.00 4/9/2019 Fna Bud Fna Total 871,690,000.00

28. 27 Recommendations • Management should ensure that all regulations are developed and published in order to effectively regulate the industry. • NATCOM should ensure strict adherence to these regulations by all sta keholders. Management Response • The Board has ensured that effective regulations are promulgated for the effective and efficient running of the Commission. • Furthermore, the Board has ensured that numbers of reg ulations a re now in place as currently a draft has been table in Parliament to become an Act that will address the challenges stated. 5.9 Legal Department NATCOM has a legal department. The American Bar Association states that “the broad general functi on of the law department is to delineate legal boundaries within which the management of the corporation is free to exercise its ingenuity in successfully managing the corporate enterprise. Its function is not to cover up or conceal illegal activities. It is the re sponsibility of the corporate l awyer, however, to attempt to find ways legally to achieve proper corporate objectives.” A company law department has to administer consistent with the company’s legal activities in such a way as to ensure: • Maximum protectio n of the legal rights of the co mpany consistent with the performance of the company’s other responsibilities ; • Proper discharge of the company’s legal obligations and • Oversees a firm’s litigation and compliance with internal and external regulati ons and la ws. Retainer fees can often le ad to unexpected bills for work NATCOM did not know was needed, but when a company pays a fixed monthly fee for legal services, there would be little or no room for misunderstanding what the company owes each much. Findings • The Review Team observed that the Commission had both a Legal retainer and a Legal Department which comprised lawyers. Furthermore, a budget was provided

78. 77 Date Description Requisition Requested by Requisition Approved by Received by Issue requested by Issue Approved by Delivered to Requisition and issue voucher No. 28/7/21 Laser jet pro MFP M477 Jose phus Mustaph a Not Approved Jo sephus Mustapha Adeyemi L. Coker Not Approved Engineering 01349 Laser pro MFP M281 IsataGandie Not Approved Isata Gandie Adeyemi L. Coker Not Approved Internal Audit 01349 Laser Pro MFP M281 Musa Y. Sesay Not Approved Mus a Y. Sesay A deyemi L. Coker N ot Approved Finance Department 01349 Toiletries Foday Thoronka Not Approved Foday Thoronka SamuraMa nsaray Not Approved General Services A 01349 Laser pro MFP M277 Clementine Y. Sesay Not Approved Clementine Y. Sesay Ade yemi L. Coke r Not Approved Di rector of IT 01349 Laser pro 200 MFP M276m Clementine Y. Sesay Not Approved Clementine Y. Sesay Adeyemi L. Coker Not Approved Marian Yarjah 01349 Laser pro MFP M277 Isha Abdallah Not Approved Isha Abdallah Adeyemi L. Coke r Not Approv ed PA to DG 0134 9 Laser pro MFP M281 Neimatu Koker Not Approved Neimatu Koker Adeyemi L. Coker Not Approved Director of Admin 01349 ✓ Items supplied that were never approved by the issuing department as shown below . ✓ Items supplied that were never approved by the reque sting department as shown below : Date Descrip tion Requisi tion Requested by Requisition approved by Received by Issued requested by Issue approved by Delivered to Requisition and issue voucher No. 05/07/21 Tyres RS 17 Alpha Mansaray Not Approved Alpha Mansaray Samura Mansaray Ahmid Kannah Alpha Mansa ray 01349 1 2/07/21 100 AMP B attery Mohamed Bayoh Not Approved Mohamed Bayoh Adeyemi Coker Ahmid Kannah Mohamed Bayoh 01349 12/07/21 Toiletries Mohamed Kamara Not Approved Mohamed Kamara Adeyemi Coker Ahmid Kannah Weekly G8 01349 05/07/21 Stationery Jo sephus A. Mu sa Not Approved J osephus A. Musa Emmanuel V. Foday Ahmid Kannah Engineering Dept 01349 Date Description Req uisition Req uested by Requisi tion approved by Received by Issue requested by Issue approved by Delivered to Requisition and issue voucher No. 23/6/21 Tyres R7 For Toyato Prado Lamin F. Kanneh Brima Kargbo Lamin F. Kanneh Samura Mansaray Not Approved DG ’s Office 0 1349 27/5/21 Ve hicle Tyre 195 R15 Mustapha Jah Ahmid Kannah Mustapha Jah Adeyemi L. Coker Not Approved Mustapha Jah (Senior Driver) 01349

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