1.

4. ii

6. 2 The specific objectives of the monitoring exercise were to: 3. Methodology of the Monitoring Exercise The monitoring exercise was conducted using a structured verification process that combined documentary review, institutional engagement, and evidence - based compliance scoring. The Compliance Progress Assessment Matrix served as the principal monitoring tool used to assess the implementation status of each agreed corruption risk response.

10. 6 This level of compliance indicates that the majority of agreed corruption risk responses have been implemented and supported by verifiable evidence. The result demonstrates strong institutional commitment to strengthening procurement governance and reducing corruption risks. However, a small number of operational gaps remain and require further management attention to ensure full institutionalization of reforms across all procurement - related processes. 6. Compliance Performance by Area of Focus Compliance performance improved across all areas of focus assessed during the monitoring exercise.

9. 5 Compliance ratings are assigned strictly on the basis of verified documentary evidence rather than verbal assurances or institutional intentions. 5. Overall Compliance Performance of Rokel Commercial Bank The monitoring established that Rokel Commercial Bank achieved an overal l compliance score of 90 %, placing the institution within the Full Compliance category. Out of 41 agreed procurement corruption risk responses, 37 were rated as Full Compliance, 2 as Significant Compliance, and 2 as Moderate Compliance. No recommendation was rated as No Complianc e. Figure 1: Gauge Chart - RCB Overall Compliance Performance Rate

15. 11 VII. Compliance Maturity Has Improved Significantly The achievement of 90% Full Compliance reflects a major improvement in the implementation of agreed corruption risk responses. This progress demonstrates that collaborative monitoring and evidence - based engagement can drive practical institutional reform. 9 . Limitation of the Monitoring Exercise Consequently, procurement practices at branch level were not directly assessed during this monitoring exercise. While Management indicated that low - value decentralized procurements are monitored by Headquarters, Internal Audit, and external audit mechanism s, variations in implementation across branches cannot be fully ruled out. Future monitoring may therefore consider selected branch verification, especially as the Bank rolls out electronic procurement and related controls across its operational network.

7. 3 Table 1: Monitoring Methodology Component Description Monitoring Tool Compliance Progress Assessment Matrix Evidence Reviewed Procurement records, policy documents, meeting minutes, compliance documents Engagement Method Verification discussions with responsible officers Scope Implementation of procurement corruption risk responses Verification Approach Evidence - based assessment using Means of Verification The monitoring exercise focused on procurement governance systems at the Headquarters of Rokel Commercial Bank.

17. 13 11 . Conclusion The Monitoring for Compliance exercise confirms that Rokel Commercial Bank has made substantial progress in implementing the agreed procurement corruption risk responses following the Procurement Thematic Corruption Risk Assessment conducted in 2025. With an overall compliance score of 90 %, the Bank has achieved Full Compliance under the ACC Compliance Barometer. This indicates that most agreed corruption risk responses have been implemented and supported by verifiable evidence. The progress achieved demonstrates strong institutional commitment to procurement governance, transparency, accountability, and corruption risk mitigation. It also reflects the value of collaborative monitoring, evidence - based engagement, and institutional ownership of reform actions. However, to sustain full compliance, the Bank should address the remaining operational gaps, particularly the full rollout of electronic procurement systems, operationalization of framework contracts, formalization of supplier performance evaluation, and d ocumentation of end - user feedback. Overall, Rokel Commercial Bank has demonstrated commendable progress in strengthening procurement governance, transparency, accountability, and institutional integrity. The achievement of Full Compliance reflects Management's commitment to implementing agr eed corruption risk responses and sustaining a culture of compliance and continuous improvement. The Anti - Corruption Commission commends the Management, Board, Procurement Unit, and relevant staff of Rokel Commercial Bank for the significant progress achieved in implementing the agreed procurement corruption risk responses.

5. 1 1. Introduction In 2025, the Anti - Corruption Commission conducted a Procurement Thematic Corruption Risk Assessment at Rokel Commercial Bank to identify systemic weaknesses within the Bank’s procurement processes that could expose the institution to corruption risks. The assessment identified governance, operational, and procedural vulnerabilities within the procurement system. Following the assessment, the Commission and the Bank jointly agreed on a set of corruption risk responses aimed at strengthening procurement g overnance, improving transparency, and enhancing institutional accountability. Monitoring the implementation of agreed corruption risk responses is a critical component of the Commission’s corruption prevention mandate. It ensures that recommendations arising from corruption risk assessments are translated into practical reforms and that institutions demonstrate compliance through verifiable evidence. This Monitoring for Compliance exercise was therefore conducted to assess the extent to which Rokel Commercial Bank has implemented the agreed procurement corruption risk responses and to determine whether procurement governance systems have improved since the corruption risk assessment. 2. Objectives of the Monitoring for Compliance The Monitoring for Compliance exercise was conducted pursuant to the mandate of the Anti - Corruption Commission as provided under Section 8(1) of the Anti - Corruption Act, 2008 as amended in 2019 , which empowers the Commission to examine the practices, systems, and procedures of institutions in order to facilitate the discovery of corrupt practices and secure the revision of methods of work that may facilitate corruption.

14. 10 II. Procurement Governance Reforms Are Being Institutionalized Many of the agreed risk responses have moved beyond policy intent into operational practice. This indicates that procurement governance reforms are becoming embedded within the Bank’s systems and procedures. III. Evidence - Based Compliance Has Improved The monitoring showed that most compliance claims were supported by verifiable documents, including procurement records, approval documents, supplier records, meeting minutes, and internal oversight documentation. This strengthens the credibility of the compliance rating. IV. Oversight Structures Are Functioning Better Internal Audit, Enterprise Risk Management, Compliance, NPPA, and external audit functions provide multiple oversight layers. This creates stronger checks and balances across procurement operations. V. Automation Remains an Important Reform Priority The electronic procurement component is operational at Headquarters, with Management indicating plans to roll it out to branches following successful implementation at HQ. Full deployment will further improve transparency, approval tracking, documentation control, and institutional accountability. VI. Contract Monitoring Requires Further Documentation Although contract monitoring practices are being applied and supplier performance is considered in decision - making, formal documentation of supplier performance evaluation and end - user feedback remains limited. These areas require further strengthening to achieve more mature contract governance.

13. 9 V. Improved Procurement Reporting and Transparency The Bank prepares standard NPPA procurement reports and discloses procurement information through submissions to NPPA and its published annual reports. This strengthens accountability and promotes transparency in procurement governance. VI. Strengthened Segregation of Duties The procurement workflow now reflects functional separation between user departments, procurement staff, stores personnel, finance officers, and final approving authorities. This separation of duties reduces the risk of manipulation and strengthens interna l control. VII. Opportunities for Continuous Improvement Although overall compliance is strong, some gaps remain. These include full operationalization of framework contracts, full rollout of electronic procurement and electronic archiving systems across branches, formal documentation of supplier performance eva luation, and formal end - user feedback on contract performance . 8 . Key Insights from the Monitoring Exercise The monitoring exercise generated several important insights regarding procurement gover nance at Rokel Commercial Bank. I. Strong Institutional Commitment to Procurement Reform The Bank has demonstrated strong commitment to implementing the agreed corruption risk responses. This is reflected in improved procurement staffing, documentation, planning, reporting, supplier due diligence, and oversight arrangements. .

3. i Executive Summary The Anti - Corruption Commission conducted a Monitoring for Compliance exercise at Rokel Commercial Bank following the Procurement Thematic Corruption Risk Assessment carried out in 2025. The objective of the exercise was to assess the level of implementatio n of the agreed procurement corruption risk responses developed collaboratively between the Commission and the Bank. Using the Compliance Progress Assessment Matrix as the primary monitoring tool, the Monitoring and Compliance Team reviewed documentary evidence, examined procurement records, and held verification discussions with responsible officers at the Bank’s Headqu arters. The monitoring established that Rokel Commercial Bank achieved an overall compliance score of 90 %, placing the Bank within the Full Compliance category under the ACC Compliance Barometer. This indicates that the majority of agreed corruption risk responses have been implemented, institutionalized, and supported by verifiable evidence. Strong compliance performance was recorded across all areas of focus. Reporting on Procurement Activities achieved 100%, Manag ement System achieved 100 %, Procureme nt Processes achieved 83 %, Monitoring and Internal Co ntrol Systems achieved 89% , and Contrac t Monitoring achieved 83% . The findings show that RCB has made substantial progress in strengthening procurement governance, improving documentation, enhancing supplier due diligence, strengthening internal controls, and improving reporting and oversight mechanisms. Remaining areas requiring management attention include full operationalization of framework contracts, full deployment of electronic procurement systems across branches, formal end - user feedback mechanisms, and final resolution of the Head of Procurement’s role in Procure ment Committee meetings. Overall, the monitoring findings demonstrate strong institutional commitment by Rokel Commercial Bank to procurement integrity, accountability, and corruption risk mitigation.

12. 8 7 . Key Observations I. Strengthening of Procurement Institutional Capacity The Procurement Unit has been strengthened through the reassignment of additional staff, increasing the number of personnel from two to four. This development has improved operational capacity within the procurement function and enhanced the Bank’s ability to manage procurement activities more effectively. II. Improved Procurement Documentation and Record Management Procurement governance has improved, although the Head of Procurement is still not directly serving as Secretary to the Procurement Committee due to the Bank’s requirement that only Managers sit on such Committees. The Head of Procurement has therefore bee n recommended for promotion to Procurement Manager to enable direct participation in Committee meetings and facilitate full implementation of the recommendation . III. Improved Supplier Due Diligence Supplier due diligence is now applied to major procurement transactions. Supplier performance assessments are also conducted on a need basis for major service providers and contractors. Although a formal supplier evaluation framework is not yet fully docum ented, supplier performance considerations now form part of contract management and decision - making processes. IV. Strengthened Internal Oversight Mechanisms Procurement activities are subject to review by Internal Audit, Enterprise Risk Management, Compliance, NPPA, and external auditors. These oversight layers provide important control points and reduce the risk of procurement irregularities going undetected .

8. 4 4. Compliance Barometer Framework The monitoring results were interpreted using the ACC Compliance Barometer framework, which categorizes institutional complia nce performance based on the level of implementation achieved. Table 2: Compliance Classification Framework Description of Progress Description of Progress Dictionary Score Range Color Code ACC Required Action No Compliance No meaningful action has been taken, and there is little or no verifiable evidence of implementation. 0% - 49%  Indictment Moderate Compliance Implementation has commenced and some evidence exists, but actions remain incomplete. 50% - 79%  Warning Letter Significant Compliance Most actions have been implemented with strong evidence, though minor gaps still exist. 80% - 89%  Further Engagement Full Compliance All actions have been fully implemented, institutionalized, and supported by complete and verifiable evidence. 90% - 100%  Commendation Note: Scores are assigned based on verified evidence, no t intention or verbal assuranc

16. 12 10 . Recommendations Issue Identified Recommended Action Responsible Entity Head of Procurement does not directly serve as Secretary to the Procurement Committee due to internal managerial requirements Finalize the recommended promotion of the Head of Procurement to Procurement Manager to enable direct participation in Procurement Committee meetings and implementation of the Secretary role Management Framework contracts not yet fully operationalized Fast - track implementation of framework contracts for frequently procured goods and services and maintain documentary evidence of approved framework arrangements Procurement Unit / Management Electronic procurement and electronic archiving not fully deployed across the institution Complete phased rollout of electronic procurement and electronic archiving systems across branches after successful implementation at Headquarters IT Department / Procurement Unit Supplier performance evaluation not yet fully formalized Develop a structured supplier performance evaluation framework and retain evaluation records for major contracts Procurement Unit End - user feedback on contract performance remains informal Introduce documented end - user feedback forms to support contract performance review and procurement decision - making Procurement Unit / User Departments Disposal policy for office furniture awaiting formal approval Ensure formal approval and implementation of the draft disposal policy for office furniture Management Procurement performance reporting can be further strengthened Complement NPPA technical reports with descriptive internal procurement performance reports for Management review Procurement Unit

35. 31 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 40 No peer review with other banks or agencies. Introduce annual peer review or benchmarking forum. Peer review report available. Annual benchmarking held. Peer review minutes; reports. 100% RCB participates in the Sierra Leone Commercial Banks Association platform where sector issues are discussed. In addition, procurement activities are subject to review by NPPA and external auditors including KPMG and Moore Sierra Leone. 41 Limited Board oversight on procurement compliance. Present quarterly procurement performance report to the Board. Number of Board presentations made. Four per year. Board minutes; presentation slides. 100% The annual budget presented to the Board incorporates the procurement plan. Periodic procurement updates are also presented to senior management and form part of Board - level discussions.

26. 22 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description documents were properly maintained and filed. 17 No defined approval authority for thresholds. Approve authority matrix for procurement thresholds aligned to NPPA. Published approval matrix. Matrix approved and applied. Management circular; notice board copy. 100% Procurement threshold approvals are currently guided by NPPA’s prescribed rules table. Evidence reviewed confirms that the Bank is adhering to these thresholds in processing procurement transactions. 18 Irregular Procurement Committee meetings. Institutionalize monthly committee meetings with attendance register. Number of meetings held. 12 meetings per year. Meeting minutes; attendance records. 100% Procurement Committee meetings are convened based on procurement needs and operational demands. Minutes reviewed indicate that meetings are held when procurement decisions are required and are supported by proper documentation. III. MONITORING AND INTERNAL CONTROL SYSTEMS

30. 26 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description handled by the Procurement Unit, verified through Stores, and payments are processed by Finance with final approval from the Managing Director. IV. CONTRACT MONITORING # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 28 Contract monitoring inconsistent due to limited staff. Strengthen collaboration among Procurement, Compliance, Stores, and Estates for active monitoring. Frequency of monitoring reports. Quarterly monitoring reports produced. Reports; minutes. 100% Additional personnel have been reassigned to strengthen the Procurement Unit. Contract monitoring activities are further supported by Enterprise Risk Management, Internal Audit, and Compliance units that independently identify and assess procurement - relate d risks.

21. 17 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description interactions. This technical support mechanism is reinforced by the active participation of procurement professionals in committee deliberations. II. PROCUREMENT PROCESSES # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 7 Needs assessment limited to CAPEX items only. Develop a comprehensive needs assessment covering both capital and non - capital items. Updated needs assessment report. All needs captured annually. Needs assessment document; procurement plan. 100% Needs assessments are conducted annually and incorporated into the Bank’s budgeting process. Additional procurement needs may also arise from operational demands, market conditions, or Board directives. All procurement requests originate from user departme nts and pass through established approval processes before inclusion in the procurement plan.

22. 18 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 8 Delayed approval of annual procurement plan. Approve procurement plan at start of fiscal year before activities begin. Timeliness of plan approval. Plan approved within first quarter. Approved plan; committee minutes. 100 % The 2026 Procurement Plan was reviewed by the ACC Monitoring and Compliance Team. Evidence confirmed that the Plan was developed by Management, scrutinized by the Board, and subsequently submitted to NPPA for review and approval. During the Full - Blown Moni toring Exercise, evidence further confirmed that NPPA concurrence/no objection had been obtained and procurement activities were being implemented accordingly. Once NPPA approval is granted, no further Board approval is required, indicating full compliance with the recommendation. 9 Frequent emergency procurements without guidelines. Develop and enforce clear emergency procurement policy and approval limits. Existence of approved policy. Policy implemented and monitored. Approved policy; usage records. 90% The NPPA is currently updating its Standard Operating Procedures, and RCB has indicated it is awaiting the final version to guide further internal alignment. Nevertheless, procurement activities currently reviewed are being conducted in

24. 20 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 12 Procurement splitting used to bypass thresholds. Develop formal guidelines and require justification and approval for all split purchases. Existence of split - procurement guideline. 100 % documented and approved. Policy document; approval memos. 80% The current Procurement Plan includes provisions aimed at minimizing procurement splitting through the use of framework agreements. During the Full - Blown Monitoring Exercise, evidence confirmed that Management had approved the commencement of framework con tracting arrangements. However, implementation was still at an early stage and will be reassessed during subsequent monitoring engagements, indicating significant progress toward compliance. 13 Inconsistent procurement documentation and filing. Standardize filing templates for procurement records. Standard templates in use. All files auditable and complete. File index; audit verification. 100% Procurement documentation reviewed indicates that supporting documents are now consistently attached and filed. Files examined during verification contained the necessary procurement records to support decision - making and audit review.

31. 27 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 29 No formal contract monitoring framework. Develop standard framework and templates for monitoring. Approved framework in place. Framework operational. Documented templates; reports. 100% Monitoring arrangements are applied based on the nature of procurement. Technical procurements are supervised by consultants, while deliveries of consumables are verified against delivery documentation and specifications. Monitoring practices are therefore applied on a case - specific basis. 30 No supplier performance evaluation. Conduct post - contract supplier performance reviews. % of contracts evaluated. 100 % completed reviews. Evaluation forms; scorecards. 90 % Supplier performance assessments are conducted on a need basis, particularly for major service providers and contractors such as Breat Construction and Design Technologies. Evidence reviewed during the Full - Blown Monitoring Exercise confirmed that supplier performance considerations form part of contract management and decision - making processes. While a formalized evaluation framework is yet to be fully documented, significant progress has been achieved in monitoring supplier performance.

23. 19 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description accordance with existing NPPA provisions and guidelines. 10 No framework agreements for recurring purchases. Establish framework contracts for frequently procured goods and services. Number of framework contracts approved. All routine supplies under framework agreements. Signed framework contracts; supplier list. 80% The current Procurement Plan provides for the introduction of framework contracts for frequently procured goods and services. During the Full - Blown Monitoring Exercise, Management reaffirmed its commitment to implementing framework contracts, and provision for their introduction was reflected in the approved Procurement Plan. However, implementation had not yet commenced at the time of monitoring, indicating moderate progress toward full compliance. 11 Advance payments made before delivery confirmation. Enforce “payment after delivery” supported by GRN/SIV. % of payments supported by GRN/SIV. 100 % verification before payment. Delivery notes; GRNs; payment vouchers. 100% Verification indicates that advance payments are limited to large procurement contracts in accordance with NPPA provisions. For other procurements, payments are effected only after delivery and verification supported by Goods Received Notes (GRN) or Stores Issue Vouchers (SIV).

20. 16 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description Procurement Manager to enable direct participation in Committee meetings and implementation of the outstanding recommendation for the position to serve as Committee Secretary. While substantial progress has been achieved, full implementation remains pendin g. 5 Contracts awarded to bidders with incomplete compliance documents. Enforce strict pre - award verification of tax, legal, and compliance documents. Number of compliant contracts awarded. 100 % contracts fully compliant. Evaluation reports; compliance certificates. 100% Procurement transactions reviewed for 2026, including the procurement of the Bank’s wall calendars, diaries, and notebooks, were supported by complete compliance documentation. Verified records confirm that all required documents, including valid tax clear ance certificates, were obtained prior to contract award. 6 Limited training for Procurement Committee members. Conduct annual capacity - building on NPPA guidelines and ethics. Number of trainings held per year. At least one per year. Training attendance list; programme report. 100% Technical guidance is regularly provided to the Procurement Committee by the Procurement Unit. Committee members are professionals in their respective fields and demonstrated knowledge of basic procurement rules during

18. 14 12. Compliance Progress Tracking Matrix I. MANAGEMENT SYSTEM # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 1 Procurement Unit operates with only two staff instead of four. Recruit additional qualified procurement personnel to strengthen capacity and efficiency. Number of staff in Procurement Unit. Four qualified officers fully deployed. HR records; appointment letters; organogram. 100% Two additional personnel have been reassigned to the Procurement Unit. Correspondence and a circular confirming the reassignment of Isha Kamara (Diploma in Procurement and Supply Chain, IPAM 2017) and Patrick Kallon were verified. Patrick Kallon is current ly undergoing on - the - job training under the supervision of three procurement professionals, bringing the total staffing of the Procurement Unit to four. 2 Internal Procurement Policy not fully aligned with NPPA Act 2016. Review and update policy to achieve full alignment with the NPPA Act and clarify roles and reporting lines. Approved revised policy. 100 % compliance with NPPA requirements. Approved policy; management minutes. 90% The National Public Procurement Authority (NPPA) is currently updating its Standard Operating Procedures (SOPs). RCB has indicated that it is awaiting the outcome of this national update to ensure full alignment. Notwithstanding this, current procurement a ctivities are being conducted in accordance with

28. 24 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description introduces independent review points across operational activities. 22 Compliance Department excluded from procurement stages. Include Compliance in all phases for due diligence review. % of tenders vetted by Compliance. 100 % reviewed. Attendance; vetting forms. 100% Compliance functions within the Bank focus primarily on regulatory banking compliance and risk monitoring. Procurement oversight is therefore handled through Internal Audit and Enterprise Risk Management structures in line with the Bank’s operational risk management framework. 23 Supplier due diligence inconsistently done. Conduct full due diligence on all suppliers. % of suppliers screened. 100 % compliance. Due diligence records. 100% Supplier due diligence procedures are now applied to major procurement transactions. Evidence reviewed included due diligence records relating to the procurement of five vehicles from Ugyema Enterprise. 24 Poor documentation and record archiving. Create electronic procurement filing system. Functional e - archive system. Fully operational. IT system log; samples. 60% An electronic procurement archiving component is being introduced within the Bank’s core banking system. At the time of monitoring, the system was operational only at Headquarters and had not yet been fully rolled out across the institution.

33. 29 V. REPORTING ON PROCUREMENT ACTIVITIES # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 34 No comprehensive procurement report for management. Prepare annual procurement performance report. Annual report produced. Report submitted to MD. Annual report; submission record. 100% Standard NPPA procurement reports (SPF6) were prepared for 2023, 2024, and 2025. Management was advised to complement these technical reports with descriptive procurement performance reports for internal management review. 35 No quarterly management review meetings. Hold quarterly reviews on procurement performance. Number of meetings held. Four reviews annually. Meeting minutes; attendance. 100% Procurement review meetings are currently convened based on operational requirements. Documentation reviewed confirms that procurement issues are discussed periodically at management level. 36 Lack of public disclosure of procurement information. Publish annual summary of procurement activities. Publication available. Annual disclosure made. Website copy; notice board photo. 100% Annual procurement information is disclosed through submissions to NPPA as the public oversight body. Procurement information also forms part of the Bank’s published annual report available on its website.

19. 15 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description existing NPPA provisions and guidelines. 3 Decentralized low - value procurements by branches and departments. Centralize all procurements under the Procurement Department to ensure control and transparency. Evidence of centralized procurement structure. 100 % of procurements processed through the central unit. Procurement manual; internal memos; purchase records. 100% Low - value procurements remain decentralized to support operational efficiency across branches. However, such procurements are subject to monitoring by Headquarters, Internal Audit, and External Audit. Verification indicates that decentralized procurements are conducted in line with NPPA requirements and internal audit observations are addressed accordingly. 4 Procurement Committee minutes unsigned or missing Procurement Officer. Ensure all minutes are signed and include a Procurement Officer as secretary for technical guidance. % of meetings with signed minutes. 100 % of minutes signed and filed. Signed minutes; attendance lists. 90 % The Admin Manager currently represents the Head of Procurement at Procurement Committee meetings, in line with the Bank's requirement that only Managers serve on such Committees. This limits the direct technical contribution of the Head of Procurement. The Head of Procurement has therefore been recommended for promotion to

34. 30 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 37 Weak follow - up on audit recommendations. Develop and maintain implementation tracker. Tracker available and updated. 100 % recommendations tracked. Tracker sheet; updates. 100% A tracking mechanism is currently maintained for audit queries. Although not presented in a tabular format, audit queries are documented and responded to in descriptive follow - up records. 38 Limited staff capacity on reporting. Provide refresher training on reporting tools and templates. Number of staff trained. At least five staff trained annually. Training attendance; report. 100% Two additional staff members have been reassigned to strengthen procurement reporting capacity. Correspondence confirming the reassignment of Isha Kamara and Patrick Kallon was verified. Patrick Kallon is receiving on - the - job training under the supervision of procurement professionals. 39 Procurement performance not linked to staff appraisal. Integrate procurement KPIs into performance appraisal system. Appraisal forms updated. Linkage fully implemented. HR performance reports. 100% Staff performance appraisal within the Bank is linked to job descriptions, annual work plans, and assigned responsibilities. These performance indicators form part of the staff KPI framework.

11. 7 Table 3: Compliance Progress by Area of Focus Calculate to the nearest % # Area of Focus Total Recommendations No Compliance Moderate Compliance Significant Compliance Full Compliance Compliance Rate (%) 1 Management System 6 0 0 0 6 100% 2 Procurement Processes 12 0 0 2 10 83% 3 Monitoring and Internal Control Systems 9 0 1 0 8 89% 4 Contract Monitoring 6 0 1 0 5 83% 5 Reporting on Procurement Activities 8 0 0 0 8 100% Total 41 0 2 2 37 9 0%

25. 21 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 14 Lack of automation in procurement process. Integrate procurement software with approval and payment workflow. Functional e - procurement system. Automated process operational. IT reports; user logs. 9 0% Initial steps were taken to introduce an electronic procurement component within the Bank's core banking system. During the Full - Blown Monitoring Exercise, evidence confirmed that the system was operational at Headquarters, with Management indicating plans to roll it out to branches following successful implementation at HQ. Significant progress was observed; however, full deployment across the Bank remained outstanding 15 Supplier database outdated. Update supplier register annually with NPPA registration details. Updated supplier register. Database reviewed annually. Supplier list; NPPA certificates. 100% An updated supplier database has been established and is currently maintained by the Procurement Unit. Supplier records reviewed during verification were updated and supported by relevant documentation. 16 Weak documentation of evaluation , delivery note Adopt uniform evaluation template and checklist. Use of evaluation checklist. 100 % of procurements use checklist. Evaluation reports; minutes. 100% Evaluation and procurement documentation reviewed during monitoring were supported by the required documentation. Evaluation records and related procurement

29. 25 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 25 Central store not fully utilized. Enforce routing of all goods through store with GRN/SIV. % of deliveries documented. 100 % compliance. Store ledger; GRN/SIV. 100% Procurement operations are structured to support lean inventory management. Goods are largely procured on a demand - driven basis and routed through appropriate documentation procedures, including GRN and SIV, to maintain accountability and efficient workflo w. 26 Weak disposal control. Develop and implement disposal policy aligned to NPPA guidelines. Disposal policy approved. 100 % disposals documented. Policy; disposal committee minutes. 100% Verification confirmed that disposal of vehicles in 2025 was conducted with the involvement of the Assets Commission and the Sierra Leone Road Safety Authority. Disposal of unserviceable furniture is carried out through defacing, listing, removal from the asset register, and disposal in accordance with NPPA - approved methods. A draft disposal policy for office furniture is currently awaiting formal approval. 27 Lack of segregation of duties in procurement process. Separate roles for requisition, approval, and payment. Segregation matrix available. 100 % functional segregation. Workflow chart; internal memos. 100% The procurement process now reflects functional separation of duties. Requests originate from user departments, pass through administrative processing, are

27. 23 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 19 Procurement audits conducted only as part of administrative audits. Conduct stand - alone procurement audits annually. Number of dedicated procurement audits. One audit per year. Audit plans; reports. 100% Dedicated procurement audit activities are currently undertaken by NPPA, Internal Audit, and the Enterprise Risk Management Unit. Verification confirms that procurement transactions are now subject to specific audit review. 20 Limited verification of goods supplied by Audit Department. Involve Audit in verification before payment. % of verified procurements jointly signed. 100 % verified jointly. GRNs; verification forms. 90% Due to the physical location of the Internal Audit Department at Juba, routine verification of all deliveries by auditors alone is operationally difficult. As an alternative control measure, the Bank has introduced additional verification by Compliance and Enterprise Risk Management functions located closer to Headquarters to support third - party verification prior to payment. 21 Weak coordination between Audit and Compliance. Establish collaboration framework and quarterly joint meetings. Number of meetings held. Four per year. MoU; joint reports. 100% The Bank maintains independent operational structures for Audit, Compliance, and Enterprise Risk Management to preserve objectivity and maintain multiple oversight layers. This arrangement functions as an internal control mechanism that

32. 28 # Baseline / Issue Recommendations / Agreed - Upon Risk Responses Indicator ACC Target Means of Verification (MoV) Progress Score % Compliance Progress Description 31 Variations or extensions not properly documented. Require written approval for all variations/extensions. % of variations approved. 100 % documented approvals. Variation register; letters. 100% Contract extensions and variations are now documented and supported by appropriate written approvals. 32 Limited feedback between Procurement and End - Users. Create formal feedback system on contract performance. Existence of feedback forms. All contracts with user feedback. Feedback forms; memos. 50% Procurement staff indicated that feedback from end - users is informally obtained; however, no documentary evidence was available during monitoring to confirm a formalized system. The Monitoring and Compliance team advised the introduction of an End - User Eva luation Form to ensure proper documentation. 33 No KPI monitoring in contracts. Integrate KPIs in all new contracts. % of contracts with KPIs. All new contracts KPI - based. Contract documents; KPI tracker. 100% Procurement documentation reviewed indicates that deliveries are assessed against specifications and completion requirements. Supporting documentation including evaluation reports, delivery notes, and verification records were available prior to payment au thorization.

2. Table of Contents Executive Summary ................................ ................................ ................................ ......................... i 1. Introduction ................................ ................................ ................................ ............................. 1 2. Objectives of the Monitoring for Compliance ................................ ................................ ............ 1 3. Methodology of the Monitoring Exercise ................................ ................................ ............... 2 4. Compliance Barometer Framework ................................ ................................ ............................ 4 5. Overall Compliance Performance of Rokel Commercial Bank ................................ .................. 5 6. Compliance Performance by Area of Focus ................................ ................................ ............... 6 7. Key Observations ................................ ................................ ................................ ........................ 8 I. Strengthening of Procurement Institutional Capacity ................................ .......................... 8 II. Improved Procurement Documentation and Record Management ................................ .. 8 III. Improved Supplier Due Diligence ................................ ................................ .................... 8 IV. Strengthened Internal Oversight Mechanisms ................................ ................................ . 8 V. Improved Procurement Reporting and Transparency ................................ .......................... 9 VI. Strengthened Segregation of Duties ................................ ................................ ................. 9 VII. Opportunities for Continuous Improvement ................................ ................................ .... 9 8. Key Insights from the Monitoring Exercise ................................ ................................ ................ 9 I. Strong Institutional Commitment to Procurement Reform ................................ ...................... 9 9. Limitation of the Monitoring Exercise ................................ ................................ ..................... 11 10. Recommendations ................................ ................................ ................................ ................... 12 11. Conclusion ................................ ................................ ................................ .............................. 13 12. Compliance Progress Tracking Matrix ................................ ................................ ................... 14