Corrective Action Plan Year Ended December 31, 2022 Finding 2022-001: Suspension/Disbarment Searches Management response: IWPR was able to provide vetting which confirmed that monies were not provided to any suspended or debarred parties as required per 2 CFR 200.214. Vetting was undertaken aft...
Corrective Action Plan Year Ended December 31, 2022 Finding 2022-001: Suspension/Disbarment Searches Management response: IWPR was able to provide vetting which confirmed that monies were not provided to any suspended or debarred parties as required per 2 CFR 200.214. Vetting was undertaken after the fact but prior to the audit in a small sample of transactions within our Central Asia region of operations only, and represented only a very small percentage of overall operations. Nevertheless vetting is a matter which IWPR takes very seriously, alongside wider compliance obligations. IWPR hired a Compliance Manager in November 2021 to work with staff across all programs to ensure IWPR's compliance with all aspects of USG regulations, including all vetting requirements. This included all staff training on IWPR's Vetting Policy and Procedures, which include new vetting software and staff access. Reflecting the critical importance of ensuring IWPRs procurement is compliant, IWPR has undertaken a full review of its Procurement Policy and Procurement Guidelines involving a lengthy, rigorous and collaborative process to update the Policy, which has now been approved by the Board and which will be rolled out in 2023 alongside Guidelines and through mandatory interactive training for all staff. For 2023, all vetting for procurements has been carried out in a timely manner, prior to contracting. A routine internal audit visit has already been scheduled to take place in Central Asia in 2023 to further validate the correct application of all compliance requirements, through training around finance and compliance which will include a refresher on USG rules and regulations, the new Procurement Policy and the Vetting Policy. Furthermore, a mandatory refresher training on the IWPR Vetting Policy and Procedures will be carried out for the entire organization in 2023 and then yearly thereafter. Name of Responsible Official: Stephen Ramsey, Chief Operating Officer Anticipated Completion Date: September 2023