that BC WEI prepare a segregation of duties matrix to mitigate the inherent risk that limited personnel present to segregation of duties controls. In circumstances where duties cannot be appropriately segregated due to the small size and geographic layout of the organization, additional review steps should be added to standard procedures.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

BC region DG

August 2008

the BC WEI implement policy requiring staff to annually declare understanding of policies and procedures.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

BC region DG

August 2008

that criminal background checks be required as a condition of employment for staff involved in financial transactions or approving loans.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

BC region DG

August 2008

that the CEO continue to document corporate policy as it is understood amongst staff members. KPMG recommends that WEI develop policy to ensure that employees understand the consequences of ethical and policy violations. Additionally, policy requiring staff to annually declare understanding of policies and procedures should be implemented.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

AB region DG

August 2008

that job descriptions should be updated or created to reflect current roles and responsibilities, skills required, and reporting relationships. Training needs identified should be addressed.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

AB region DG

August 2008

that Alberta WEI prepare a segregation of duties matrix to mitigate the inherent risk that limited personnel present to segregation of duties controls. In circumstances where duties cannot be appropriately segregated due to the small size and geographic layout of the organization, additional review steps should be added to standard procedures.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

AB region DG

August 2008

that the person responsible for financial recordkeeping be adequately trained in accounting and bookkeeping.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

AB region DG

August 2008

that criminal background checks be conducted as a condition of employment for staff involved in financial transactions or approving of loans.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

AB region DG

August 2008

that the Board set and communicate with the CEO new evaluation metrics for her performance to satisfy the WEI is being adequately managed, as it will be no longer participating in operational decisions.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

AB region DG

August 2008

that information protection processes need to be further considered to ensure access to data and personal information is only available to those who require it and is otherwise secured from view.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

AB region DG

August 2008

that Saskatchewan WEI prepare a segregation of duties matrix to mitigate the inherent risk that limited personnel present to segregation of duties controls. In circumstances where duties cannot be appropriately segregated due to the small size and geographic layout of the organization, additional review steps should be added to standard procedures.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

SK region DG

August 2008

Saskatchewan WEI implement policy requiring staff to annually declare understanding of policies and procedures.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

SK region DG

August 2008

that criminal background checks be required as a condition of employment for staff involved in financial transactions or approving loans.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

SK region DG

August 2008

that disciplinary policy and processes be defined by the CEO and communicated to staff.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

SK region DG

August 2008

that the Code of Conduct and Conflict of Interest policies be updated to reflect an alternative reporting line option outside of the norm.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

MB region DG

August 2008

that Manitoba WEI prepare a segregation of duties matrix to mitigate the inherent risk that limited personnel present to segregation of duties controls. In circumstances where duties cannot be appropriately segregated due to the small size and geographic layout of the organization, additional review steps should be added to standard procedures.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

MB region DG

August 2008

that WD continue to work with WEIs to ensure consistency in interpreting performance metric definitions.

WD agrees with this recommendation and continues to chair conference calls with the WEIs and WD regional offices to work on issues of consistency. Additional training on the TEA system will also be offered.

WD - Headquarters and regional offices

Ongoing

that WD consider increasing the maximum loan amount if it is deemed integral to the type of economic impact the program is hoping to have.

WD intends to recommend increasing the maximum loans amount with renewal of the Terms and Conditions.

WD - Headquarters

On hold pending finalization of the WEI Impact Study which should be completed by June 2008.

WD does not consider this to be a control gap, but a limitation under the current Terms and Conditions.

December, 2008

that WD should consider evaluating the specific loan policy and procedural requirements under the contribution agreements to determine if these are robust enough to meet their needs as the funding partner of the WEI centres. The BC WEI has exhibited the strongest documented policies and procedures surrounding loans and financial controls. Two specific leading practice documents are the “Integrated Loan Control Framework” and the “Financial Controls Framework”.

The current five-year agreements with the WEIs expire March 31, 2010. With renewal of operating funding, WD reviews the Contribution Agreements, and this recommendation will be considered at that time, to determine whether the Contribution Agreement should be revised.

WD - Headquarters

December 2009

as the WEI’s are separate entities from WD they are governed only by their contribution agreement, and are not required to be in compliance with Treasury Board policies.

No action required

WD - Headquarters

No action required

WEI Boards should ensure that the CEO performance evaluation metrics are clear and allow them to obtain sufficient comfort that the CEO is managing operations effectively and appropriately.

WD agrees with this recommendation and will discuss implementation in the operating plan and/or policies, with the WEI

Regional DGs

August 2008