Corruption Risk Assessment RISK DOCUMENT KEMENTERIAN JANUARY 2019

Corruption Risk Assessment RISK DOCUMENT KEMENTERIAN ______ JANUARY 2019 TCC@2019. ALL RIGHTS RESERVED 1

Table of contents Contents 1 Organisation context Strategic Objectives and Key Processes Potential corruption risks 2 Risk Map 3 Summary of Risks 4 Summary of Action Plans 5 Risk Registers TCC@2019. . ALL RIGHTS RESERVED Pages 2

Organisation Context: Strategic Objectives and Key Processes Risk. Doc-01 Strategic Objectives Key Activities/ Processes linked to strategic objectives Potential Corruption Risks (linked to key processes) TCC@2019. , ALL RIGHTS RESERVED 3

Risk. Doc-02 Corruption risks – Risk Map MOD RISK MAP – 31 March 2019 Almost certain No. 1 2 1 3 12 Likely 8 Moderate Unlikely 2 11 3 6 7 5 10 4 5 6 9 4 Rare Corruption risks 7 8 9 Insignificant Minor Moderate Major Catastrophic 10 Key: Low Moderate Significant High 11 12 TCC@2019. . ALL RIGHTS RESERVED 4

Risk summary – “Project Management” Corruption risks Impact Likelihood Inherent risk rating Complex contractual structure Major Moderate High TCC@2019. . ALL RIGHTS RESERVED Control Effectiveness Impact Likelihood Some weakness Risk. Doc-03 Impact Likelihood Residual risk rating Risk Treatment? Moderate Signifcant Reduce 5

Risk. Doc-04 Summary of risk action plan Risk action plans 1 To consider legal actions to enforce terms in the integrity pact (recovering costs and termination of contract). 2 To conduct detailed background checks on joint ventures and agents 3 To develop policies over the prohibition of using agent or middleman 4 To consider an Anti-corruption Policy in the company 5 To implement Integrity Pledge by all staff TCC@2019. . ALL RIGHTS RESERVED Responsibilities Legal Dept Procurement Finance Target Date for detailed risk action plans 30 September 2017 6

RISK REGISTER TCC@2019. . ALL RIGHTS RESERVED 7

RISK REGISTER Risk ID Risks MOD-001 Use of middle man to bribe public officials MOD-002 Abuse of power in tendering CRM 2. 0@2017. ALL RIGHTS RESERVED Pages 8

Risk. Doc-04 Risk register Risk ID Risk title: 001 Abuse of power in tendering State: Corrupt practices Department Risk Category Causes 1. Internal control weaknesses: Consequences Financial loss Reputation loss a) Delegation of authority not clear b) Lack of monitoring by IA c) Conflict of interest – no policy Litigation d) Weak HR management – job rotation Quality and safety compromised e) Low salary Low staff morale 2. Collusion with suppliers, employees a) Internal control weakness – taking advantage b) Culture of accepting corruption – personal gain 3. Financial pressure of the staff Impact Major CRM 2. 0@2017. ALL RIGHTS RESERVED Likelihood Likely Inherent risk rating HIGH 9

Risk. Doc-04 Risk register (cont’d) Risk ID: 001 : Abuse of power in tendering Existing Controls Delegation of Authority – policy Procurement committee and policy SOP – delegation of authority; procurement; conflict of interest Policy – job rotation; recruitment Training and communication to staff Segregation of duties in key controls areas Integrity pact – contractors and suppliers Declaration of assets – all staff Additional Controls/ Action Plans To consider an Anti-corruption Policy in the company Integrity pledge by all staff Control Effectiveness Impact Major CRM 2. 0@2017. ALL RIGHTS RESERVED Some weakness Likelihood Unlikely Residual rating Significant 10

Risk register (cont’d) Risk. Doc-04 Risk Treatment Option : o o o Terminate Reduce Risk Accept CRM 2. 0@2017. ALL RIGHTS RESERVED 11

Risk. Doc-06 Example – Risk action plan template RISK Abuse of power in tendering Risk analysis RISK ID: q Controllable q On-going q Uncontrollable q Discrete 001 Interconnect to other risks? q Combination Risk Treatment Strategy: Risk Category: Risk Owner: o o o Terminate Assessment date: Next assessment date: Reduce Risk Accept Impact: Major Likelihood: Unlikely Risk Rating: SIGNIFICANT Target Impact: MODERATE Target Likelihood: UNLIKELY Target Risk Rating: MODERATE High level action plan to be considered Responsibility Target date for detailed plan 1. To consider an Anti-corruption Policy in the company 2. Integrity pledge by all staff 3. 4. 5. CRM 2. 0@2017. ALL RIGHTS RESERVED 12

Risk. Doc-04 Risk register Risk ID Risk title: 001 State: India Corrupt practices Department Risk Category Causes Consequences Impact CRM 2. 0@2017. ALL RIGHTS RESERVED Likelihood Inherent risk rating 13

Risk. Doc-04 Risk register (cont’d) Risk ID: 001 Existing Controls Additional Controls/ Action Plans Control Effectiveness Impact Likelihood Residual rating Risk Treatment Option : o o o Terminate Reduce Risk Accept CRM 2. 0@2017. ALL RIGHTS RESERVED 14

Risk. Doc-05 Example – Risk action plan template RISK Risk analysis RISK ID: q Controllable q On-going q Uncontrollable q Discrete 001 Interconnect to other risks? q Combination Risk Treatment Strategy: Risk Category: Risk Owner: o o o Terminate Assessment date: Next assessment date: Reduce Risk Accept Impact: Likelihood: Risk Rating: Target Impact: Target Likelihood: Target Risk Rating: High level action plan to be considered Responsibility Target date for detailed plan 1. 2. 3. 4. 5. CRM 2. 0@2017. ALL RIGHTS RESERVED 15

End of Document CRM 2. 0@2017. ALL RIGHTS RESERVED 16