Internal Audit Control Policy
Internal Audit Control Policy
Internal Audit Control Policy
This policy document defines Internal Controls measures to assist in mitigating risk and standardizing
operations
Internal Controls and Audit Manual
TABLE OF CONTENTS
1 INTRODUCTION 4
1.3 Distribution 4
3. MANAGEMENT CONTROLS 8
3.4 Membership 8
4.1 Purpose 9
5. SAVINGS CONTROLS 11
6. OPERATIONS CONTROLS 12
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7.1 Cash management 17
9 INVESTMENT CONTROLS 20
13.3 Remuneration 28
14.1 Documentation 30
14.2 Reports 31
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15.4 Planning for ICT 32
16.0 INVESTIGATIONS 34
16.2 Fraud 34
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1 INTRODUCTION
1.1 Objectives of the Manual
The Manual is an explanation of the manner in which BRAEMEG‟ Sacco Ltd requires its Auditing function to
be conducted. It is not intended to be a book of reference of last resort, but to be read section wise so that the
knowledge of the underlying principles and reasons for rules are understood.
Further, this manual seeks not only to protect BRAEMEG‟ Sacco assets but also to establish policies and
procedures that will facilitate the management of quality growth and development of the company into a highly
sustainable and respected organization.
The manual is intended to be a handbook for easy reference and interpretation of Auditing policies and
procedures. As a rule, the CEOs and the Auditing staff must be fully conversant with the entire manual.
1.3 Distribution
This Auditing manual is the property of BRAEMEG‟ Sacco, and shall not be made available to any person who
is not a member of staff of BRAEMEG‟ Sacco, whether in part or in whole and in whatever form without
express authority from the board.
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2 PROCEDURE IN CARRYING OUT AN AUDIT
Where the audit wok is to be carried out particularly if the clients have several locations
The Auditor must work out a probable program of work on how the objectives of the assignment are to be
achieved.
Reasonable Assurance
An audit in accordance with ISA‟s is designed to provide reasonable assurance that the financial statements
taken as a whole are free from material misstatements.
Reasonable Assurance is a concept relating to the accumulation of audit evidence, necessary for the Auditor to
conclude that there are no material misstatements in the financial statements taken as a whole. Reasonable
assurance relates to the whole audit process.
However, there are inherent limitations in an audit that affects the auditor‟s ability to detect material
misstatements. These limitations result from factors such as:
Use of testing
Inherent limitations of any accounting and internal control system e.g. possibility of collusion
The fact that most audit evidence is persuasive rather than conclusive
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The work undertaken by the Auditor to form an opinion permeated by judgment, in particular regarding:
The gathering of Audit evidence for example in deciding the nature timing and extend of Audit
procedures
The drawing of conclusions used on the Audit evidence gathered e.g. assessing the reasonableness of
the estimates made by management in preparing the financial statements.
Date of preparation
From the above functions, it will be seen that working papers, perform the following functions:
i. Enable the Auditor to obtain an understanding of the audit and the evidence obtained. Such an
understanding may be required by:
A court in the event of a need to justify the appropriateness of the opinion expressed in accordance with
approved auditing standards
ii. Introducing a discipline into the audit process ensuring that appropriate evidence is gathered and
evaluated
iii. Provide a basis for planning and performing subsequent period‟s audit.
The wording to be used in the audit report depends on the area of business being audited and the requirements
of the Society.
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Basic elements of the Auditors report
Title
The Auditors report should have an appropriate title such as – The report of the Internal Auditors. This Title
distinguishes the Auditors report from the other reports that might be issued by others, such as offices of the
Society.
Addressee
The Auditors report should be appropriately addressed to the Central Board of Directors of BRAEMEG‟ Sacco.
Introductory/opening paragraph
The report should include a statement that Society accounts are the responsibility of the entity‟s management.
Opinion paragraph
The Auditor should give an opinion on the affairs and records of the Society.
To bring to the attention of the management areas of weakness that could lead to material errors
To enable the management to put right matters that may otherwise lead to a qualified report
Auditor to point out areas where the management could be more efficient, more effective or where
economies could be made or resources could be used more effectively
The report should be clear, constructive and concise. It should contain an opening paragraph explain the
purposes of report, a note that it contains matters which came to the Auditors attention and is not a
comprehensive list of all weaknesses, a request that BOD should reply to each point made.
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3. MANAGEMENT CONTROLS
The Board of Directors shall ensure that the delegated responsibility matches the authority to enable the
management staff execute their duties efficiently.
3.4 Membership
Common Bond
The membership shall consist of persons who work for Braeburn schools ltd and others as will be stipulated in
the Society By-Laws.
Eligibility
A person of either sex shall be eligible for membership if he or she possess the qualifications specified in the
By-Laws.
Every applicant for membership shall complete an „application for membership” form. A membership fee, set
by BOD from time to time, shall be submitted together with this form.
Application for Membership
Membership in the Society shall be terminated upon occurrence of one or more of the events as specified in the
By-Laws.
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4 LOAN POLICY CONTROLS
4.1 Purpose
The Loan Policies are intended to provide direction, guidelines, and make provisions for proper and efficient
utilization and administration of the SACCO Loan Portfolio in order to ensure that the SACCO‟s interests are
adequately protected, to ensure equitable distribution of funds, encourage liquidity planning and enhance
effective communication and information flow between the SACCO and its members.
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c) If the loan outstanding is greater than the member‟s savings, the Society shall recover the loan from the
employee‟s benefits through the employer or other property/assets pledged by the member.
d) Where a member defaults and the Society is unable to recover the loan from his employer, the loan shall
be recovered from the guarantors.
e) A member whose loan is in default shall be blacklisted and will not be eligible for another loan for a
period of not less than six months.
f) No member shall be allowed to withdraw from the society if in default but can after clearing the loan
balance.
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5. SAVINGS CONTROLS
To mobilize savings, the Society shall apply aggressive marketing efforts. Appropriate incentives shall be
applied to promote savings growth based on set goals.
Savings withdrawal shall only be allowed at the time a member is withdrawing membership unless he/she is
withdrawing part of withdrawable savings product.
At a members‟ discretion, voluntary savings may be offered as a product with flexible withdrawal. The Society
shall offer these depending on member‟s needs.
a) From time to time the Board of Directors shall determine the interest rate applicable to savings and the
method of calculating interest earned. In determining these the Board of Directors shall consider the
following elements: -
1. Financial market behavior
2. Current inflation rate
3. Transaction costs on savings
4. Savings mobilization volume
5. Terms offered to the market
6. Average rate on deposits weighted on portfolio
7. Business methodology to estimate rate on deposit.
b) The interest rate offered shall be competitive in the market. The interest rate shall be reviewed periodically,
according to the competitive patterns and should be adjusted in a timely manner to market conditions.
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6. OPERATIONS CONTROLS
a) Loan applications shall be received and checked for completeness and attachments as required. If in order,
the officer in charge will stamp them “received” and allocate a serial number and then register them into
the Loans Register.
b) The loan application forms shall then be forwarded to the loans section. The loans officer shall check the
following: -
Whether the amount applied and other loans outstanding are within the set multiplier.
Whether the guarantors have ability to guarantee (savings)
Repayment capacity determined by the ratio of installment to regular pay
History on loan repayment in the last 2 years – if there are any missed installments.
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The loans officer recommends the maximum amount that can be disbursed and forwards the form to the CEO.
The CEO, if in agreement with the officer, recommends the amount to be approved to the Credit Committee.
Loan Approval
a) The Credit Committee shall approve the loan. The committee can delegate the powers of approving to one
of the members pending ratification by the full committee and the Board of Directors. In approval, the
committee shall check conformity to the set criteria for each loan type applied for;
Ratio of installment to gross (regular) pay
Loan applied to savings ratio
Letter of commitment from employer (agreement form)
Any special requests (in form of a letter) from the applicant.
b) Approved loan application forms are then passed to CEO to authorize for cheque or Electronic fund
payment.
c) The CEO passes the approved loan applications to the accounts section for cheque writing or electronic
payment.
d) It then follows the normal payment process.
Loan Disbursement
a) All loan payment shall be made into the members FOSA account unless the BOD approves
otherwise.
b) The loan officer updates the loans register.
c) An allotment letter is prepared and signed by the loanee. It is then taken to the CEO for approval.
d) Allotment book is updated and the allotment letter is send to the employer (payroll office).
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Procedure
a) At the end of each quarter or any such other times as the Board of Directors may require, the CEO shall
prepare a detailed report of all loans on which the SACCO anticipates loss of interest and/or principal
(Allowance for Doubtful Loans report).
b) The SACCO shall be required to maintain an allowance for loan losses based on the Allowance for
Doubtful loans report. When all effort to collect and or the loan has been turned over to collector or
SACCO lawyer and the period has exceeded 18 months, such loans will be charged off against the
allowance for loans loss.
c) In event that the principle sum and interest is not fully recovered from the security offered by the
defaulting member and the guarantors, the balance shall be provided for at the rate of 100%. (written off)
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7 ACCOUNTING SYSTEM CONTROLS
Basis of Accounting
The Society accounts should be prepared under the historical cost convention. Incomes and expenses shall be
recognized using the accrual basis of accounting.
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7.4 Bank Reconciliation
a) Bank reconciliation shall be done monthly. The Accountant, will do the reconciliation, the Internal
Auditor will review before approval by the CEO.
b) All paid vouchers together with original third party supporting documents shall be filed in chronological
order.
c) Un-established items shall be cleared within one month after reconciliation date.
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8 FIXED ASSETS CONTROL
Depreciation
a) Bank reconciliation shall be done monthly. The Accountant, will do the reconciliation which shall be
reviewed by the CEO.
b) All paid vouchers together with original third party supporting documents shall be filed in a chronological
order.
Un-established items shall be cleared within one month after reconciliation date.
c) Disposal of Assets
The society shall apply reasonable and convenient assets disposal methods but in all cases
transparency and accountability must be upheld.
The MC shall approve all assets disposal transactions.
Assets shall be disposed when they become uneconomical to maintain.
Security on Assets
a) The SACCO shall have an elaborate security system to safeguard all its assets. This shall be arranged
with reputable security organizations as well as put in place the relevant physical security structures as
determined and approved by the Board of Directors.
b) All SACCO fixed assets shall be insured.
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9 INVESTMENT CONTROLS
At all times, the investment decisions shall be based on: return (yield), risk and liquidity of the investment.
a) Short-term savings funds shall be invested in short term assets. Long-term assets shall be matched with
long-term liabilities and capital. The mismatch shall not exceed 5%.
b) The Society shall adhere to the matching principle to avoid interest-risk exposure that could impair the
SACCO‟s liquidity and solvency.
Cash Reserve
The cash reserve to be maintained shall be determined by the BOD from time to time depending on the
prevailing operational circumstances.
Valuation
Investments shall be valued for purposes of annual reporting of carrying consistent with existing relevant
accounting standards.
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10.0 INCOME AND EXPENDITURE CONROLS
Public relations shall be paid on Society official functions subject to Board of Directors‟ prior approval.
Taxation
Taxation shall be based on co-operative taxation legislation and the society shall choose to apply current
taxation and/or deferred tax method where necessary.
General Journals
a) All journal entries must be approved by the CEO before they are passed to the general ledger accounts and
reviewed quarterly by Board of Directors
b) Pre-numbered general journal book shall be used.
Correction of errors
a) Any error discovered after final monthly reports have been made or the monthly transaction files have
been closed, should be corrected in the following accounting period (month) but not going to the past
records and correct it. Such errors could affect members‟ statements or financial reports.
b) This error correction shall be properly documented and approved by the CEO.
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11.0 FINANCIAL PROCEDURE CONTROLS
The following procedures shall be followed when payments are received in form of a cheque or direct banking
(banking in slip):
a) The receipt number shall be entered in the reverse side of the cheque for follow-up in the event the
cheque is dishonoured.
b) Cheques shall be banked within one day of receipt.
c) When a cheque is dishonoured, the accountant shall communicate with the drawer immediately. The
dishonoured cheque shall not be released until the drawer makes acceptable alternative payment with
penalty accrued. The entry of the dishonoured cheque shall be reversed in the cashbook.
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c) The approved payment voucher shall be returned to the accountant to write a cheque. The accountant,
upon issuance of a cheque shall stamp all documents PAID
d) The cheque, with all supporting documents shall be sent to the CEO, Treasurer and Chairman (or other
signatories) in that order for signature.
e) The signed cheque shall be sent or dropped to, or collected by the payee, who must sign the payment
voucher as acknowledgement.
f) Details of paid vouchers shall be entered into the cashbook.
g) All paid vouchers together with original third party supporting documents shall be filed in
chronological order.
h) The cashbook shall be updated daily and control reports printed showing receipts and payments by
assistant accountant and filed.
i) The office shall maintain a current and up-to-date cheque register with columns for cheque number,
payee name, purpose
j) When a new cheque book is received from the bank, details of all the cheque leaves shall be entered in
the cheque register, in sequential order. The rest of information will be left until the cheque is drawn for
payment or cancelled. As payment is made, details will be filled in the columns as necessary.
k) Cheque cancellation must only be done by CEO/accountant and reasons given for such cancellations.
Bank reconciliation
a) Bank reconciliation shall be done monthly. The Accountant, will do the reconciliation before approval
by the CEO.
b) All bank reconciliation must be filed in chronological order plus all the supporting schedules
c) Un-established items shall be cleared within one month after reconciliation date
Fixed Assets
Acquisition and disposal
a) Recording and payment for the acquisition of fixed assets should be as per procurement and payment
procedures.
b) On delivery, assets shall be inspected before acceptance.
c) On acceptance, the asset shall be classified, tagged and recorded in the fixed assets register and invoice
stamped to authenticate the same.
d) If the disposal is a cash sale, the Accountant shall issue a general receipt.
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e) The relevant entries shall be passed into the general ledger accounts.
Depreciation
At the end of every accounting period (quarter or year), the Accountant shall prepare a depreciation schedule
for each class of items using the depreciation rates described above under depreciation policies.
Investments
a) The Board of Directors shall ensure that the SACCO maintains sufficient levels of liquidity to satisfy both
the demands for credit and deposit withdrawals.
b) Where an investment is to be made, the CEO shall collect the required data and pass it to the Board of
Directors
c) The Committee shall then analyse the data and advise the Board of Directors.
d) The Board of Directors shall make the final decision on the investment and authorize the Executive to
implement the decision.
Stationery Capitalization
a) Using the stock take report of the end of last quarter of the year, the office shall value the stationery.
b) If material, the Accountant shall prepare a journal voucher to be approved by the CEO and adjust the
accounts accordingly.
Trial Balance
a) The trial balance shall be extracted from the general ledger by latest the 15th of every month by the
accountant.
b) Management accounts shall be made for every quarter and ready by the 20th day of the following month.
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c) The trial balance shall be used in preparing the draft financial accounts and supporting schedules.
Accounting Documents
Accounting documents such as cheque books and receipts shall be kept under lock and key and daily reports
pertaining to usage shall be availed for verification and authentication. The report shall contain serial numbers
of the same for monitoring purposes.
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12.0 PROCUREMENT CONTROLS
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13.0 PERSONNEL POLICY CONTROLS
Employment terms
a) New employees shall serve a probationary period of six (6) months and shall be confirmed upon
successful performance during this period.
b) The CEO on behalf of the Treasurer shall maintain a personal file for every employee
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c) Employees shall neither solicit nor accept gifts, favours or anything of monetary value from third parties
involved in any transactions with the society. Disciplinary actions including summary dismissal may be
taken against violators of this regulation.
d) Employees shall refrain from engaging in actions that may appear to create potential or real conflict of
interest with the organization. Specifically, no employee shall participate in the selection, award,
administration of contract where, to his/her knowledge his/her immediate family, partner or an
organization which he/she or his/her family has a financial interest or with whom he/she is negotiating or
has an arrangement concerning prospective employment.
e) It is the duty of every employee to keep his/her work- station neat and tidy all the time and help maintain
a professional and business like atmosphere in the SACCO.
f) Employees are to use Society properties responsibly and avoid abuse.
g) Except for cases of illness, absence from work must be reported to an employee‟s immediate supervisor
by start of the normal working day except under unavoidable circumstances.
h) Absenteeism due to sickness must be reported before end of the day and documental proof presented to
the supervisor on the first day of reporting to work. If the employee is to be away for more than one day,
another request must be made, unless satisfactory arrangements were made in advance with the immediate
supervisor.
i) Staff members must not involve themselves in campaigns for Board of Directors positions either on their
behalf or on behalf of other members. Such actions may warrant disciplinary actions, including
termination.
Staff attendance
The SACCO may maintain time of arrival and attendance records for all staff. Supervisors must ensure that,
their staff are aware of their responsibilities and when they are to be on duty. Flexible reporting and departure
times may be recommended by the CEO and approved by the Treasurer.
Grooming
Employees are expected to be neat, presentable and to maintain a standard of dress, grooming and general
decorum that will help present the SACCO as a top quality financial service organization in Nairobi.
Uniforms shall be provided for positions that require staff to be in them for better performance of their duties.
13.3 Remuneration
a) All salaries and wages shall be paid in arrears monthly.
b) All employees shall be required to open bank accounts for clearing salary cheque payments.
c) Salaries may be reviewed at the end of every year and implemented in January of the following year.
Within grade salary review (at the anniversary of the contract), shall involve individual consideration
relating to each member of staff. To review salaries, the following factors will be considered:
1. Work performance based on annual performance appraisal report
2. Professional skills enhancement
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3. General conduct
4. Length of service in the SACCO
5. Changes in the cost of living
6. Comparable salaries in relative sectors
Reviews of salaries and allowances may be carried out at the discretion of the Board of Directors and approval
by the AGM through the annual budget. The Human Resource Policy shall have all the details on staff issues.
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14.0 MANAGEMENT INFORMATION SYSTEM CONTROLS
14.1 Documentation
The Society‟s records shall be generated, classified, retrieved and utilized in a professional manner.
Society data and records may be originated from internal activities or from outside activities. Whatever the
source of records/data, the Society shall receive and file them properly.
Filling
The following filing guidelines shall be used for various types of records: -
(i) All personnel files shall be kept by the CEO
(ii) All members‟ files will be kept at the registry
(iii) There shall be a register book for the movement of files and other records in the registry. This will be in-
built into the computer system
(iv) A delivery book shall be used for all correspondence going out of the office.
(v) There shall be a register for all records delivered to the society.
(vi) All correspondence should be coded as they come into the office.
Document Security
a) The manual on document handling and security shall lay down the criteria to determine the sensitivity of
the documents of the society.
b) There shall be a cheque register maintained in the office.
c) All accounting documents like bank statements, voucher books, receipt books, share certificates, etc. shall
be kept in a safe.
d) The manual on records access shall lay down the different security levels attached to the records and the
level of staff that should have access to such records.
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Records Archiving
The Society shall archive records/data that are dormant either in the office or outside the office (rented place) in
order to created space for the active records.
Documents
The following documents will be maintained:-
(i) Loan application and loan agreement (Normal loans)
(ii) Installing application and loan agreement
(iii) Membership application form
(iv) Deduction advice
(v) Allotment form
14.2 Reports
Member reports
The following are some of the Member based reports:-
a) Member statements
b) Withdrawn members
c) Loan Defaulters (listing)
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15.0 ICT POLICY CONTROLS
Hardware
Computers and other hardware shall be accessible to authorized staff to assist them in their duties as assigned.
They shall be used responsibly. The society shall install and upgrade its network so as to maintain internal
communication and centralized printing.
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c) Data for transfer shall be prepared by the management staff with assistance from the software vendor to
ensure that correct data is transferred into the new system.
d) The new system shall run parallel with the existing system for at least 3 months for comparison before
discontinuing the old system.
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16.0 INVESTIGATIONS
An investigation is an enquiry commissioned by a client for some purpose. The scope of enquiry, the range of
possible clients and the number of purposes can be very large.
Stage 3: Organization
This involves the Auditor assessing the aims of the investigation, estimating the time to be taken and the likely
costs and ensuring that the appropriate staff will be available.
16.2 Fraud
The nature and scope of fraud investigation are dependent on the instructions given. The main considerations in
fraud investigations include the following:
a) The past time period that needs to be investigated which could be a few day or many years
b) The scope of the investigations. We have to determine whether we are investigating an
individual, a whole company or a whole department
c) Questioning of the individuals concerned
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