Program Manager/ Compliance Roving at CAMRIS International

Overview

• Working under the authority of the Chief of Party (COP), the Nigeria Program Manager (NPM)/Compliance Roving will independently develop and lead internal reviews of the NLCB program’s compliance with CAMRIS, USAID, and government of Nigeria (GON) policies, procedures, and regulations. 
• The NPM serves as a senior member of CAMRIS’ team in Nigeria, playing a central and critical role in CAMRIS’ internal control system, designed to prevent fraud, waste, abuse, and corruption. 
• The NPM performs professional compliance work, which involves conducting performance, financial, and compliance review of NLCB program activities and CAMRIS operations; supporting procurement staff on bid evaluations; supporting the HR staff on candidate selection; supporting the organization’s management and staff with internal and/or external audits. 
• The NPM upholds and disseminates through trainings and email information about CAMRIS’ policies and procedures, code of conduct, ethical standards, and independent fraud, waste and abuse reporting lines.  Works under the supervision of the COP and collaborates closely with, sometimes under legal instruction by, CAMRIS home office (CAMRIS/HO).

Responsibilities
Essential Job Functions:

• Identify and evaluates the risk areas of the NLCB program and operations and provides input to the development of the approach to compliance and prepares weekly and monthly reports on the findings.
• Carry out compliance reviews.
• Monitor procedures compliance, identifying bottle necks, issues and training needs as well as develops compliance criteria.
• Monitor and respond to calls and emails made and sent to the local, in-country 24-hour anti-corruption hotline and email address in Nigeria and review and analyze hot line reports and evidence presented, investigate and issue a report, and document corrective actions taken.
• Conduct desk compliance interviews, review documents, compose summary memos, and prepare working papers.
• Identify, develop, and document compliance issues and draft recommendations using independent judgment concerning areas being reviewed.
• Communicate the results of compliance reviews on a weekly basis to COP via written reports and oral presentations to CAMRIS field and home office senior management, as requested.
• Develops and maintain productive relationships through individual and group meetings.
• Monitor compliance during operations and program management meetings.
• Perform related work as assigned or directed by the COP, CAMRIS/HO, or the Senior Operations Manager/Deputy Chief of Party (SOM/DCOP).

Financial Reviews:

• Sample and review transactions, including a thorough compliance review of payment requests, to verify correct coding of transactions, adequacy of supporting documents per CAMRIS policies and procedures, and approvals follow both internal controls and delegation of authority thresholds established by CAMRIS/HO.
• Verify that authorized personnel have approved expenditure.
• Verify that invoices received and paid are traced to record of incoming bills, invoices, statements of accounts, etc.
• Ensure that invoices and payment vouchers are properly cancelled.
• Verify that adequate documentation i.e. original invoices/receipts. (As opposed to copies, statements or past due notices).
• Determine that the expenses are allowable, allocable, and reasonable/necessary.
• Verify that documentation is third party invoice, receipt or other acceptable form.
• Check that invoices/receipts are arithmetically accurate, invoice extensions; additions & freight charges are checked and evidenced before approval of payment.

Procurement & Purchasing:

• Sample and review procurement files in CAMRIS cloud-based procurement management system and,
• Verify that completed procurement files for goods and services rendered have been wholly transferred to the finance department as payments are released. All original documentation should be transferred to finance department upon release of first payment.
• Determine that authorized personnel approve procurement in advance via CAMRIS cloud-based procurement management system without violating segregation of duties and check and balances.
• Verify that the procurement and purchase is donor-approved per cleared grant, short term technical assistance, or direct delivery of goods and services activity, and the procurement and purchase will not result in exceeding the total approved budget.
• Review that invoices received and paid are traced to record incoming bills, invoices, statements of accounts, etc.
• Verify that invoices and payment vouchers are marked or stamped to prevent double payment.
• Determine that there is adequate documentation i.e. original invoice/receipt.
• Determine that documentation is third party invoice, receipt or other acceptable form per Nigerian law.
• Check that invoices, receipts are arithmetically accurate, invoices, extensions, additions and freight charges are checked and evidenced before approval of payment.
• Verify that correct quantities of goods or services received are documented and signed for by Grants Specialist, Program Development Officer, or other member of program staff and outside of the procurement department.
• Determine that purchase is approved, as required by the thresholds established in the CAMRIS/HO delegation of authority, by duly signed purchase order (PO) or subcontract and is correct as to date, number and description of goods and services to be provided.
• Verify that the good or service was not provided before the PO or subcontract was signed.
• Verify that invoices are charged to the proper activity number or operations CLIN and account codes charged for the good or service are correct.
• Verify that invoices match with purchase orders and subcontracts and receiving documents, including delivery notes and or goods received and/or services provided documentation exists and is signed following the segregation of duties established in the Operations Manual.
• Verify that the invoice was not issued before the good or service was received
• Review that purchase orders and subcontracts are properly approved as to price and terms.
• Make sure that comparative prices/bids/proposals considered, following thresholds established in the Operations Manual, and results of analysis of quotations, bids, proposals are duly documented and approved and attached to purchase order or subcontract and payment vouchers. Review that the quotation, bid or proposal evaluation and vendor selection is properly documented.
• Verify that the supporting documentation is in CAMRIS cloud-based procurement management system.
• Verify that link to the finance’s payment documents has been recorded in CAMRIS cloud-based procurement management system.

Payroll: 

• Randomly select five to six employee files and two payroll summaries and perform the following compliance review steps,
• Verify the mathematical accuracy of the “payroll summary”.
• Trace the below listed totals to the “account ledger” printout noting that the correct amounts and account classifications: 1) total payroll before deduction, 2) deduction, 3) net payroll.
• Verify that the COP and SOM/DCOPapproved “payroll summary”.
• Verify that the payroll taxes withheld and accrued were accurate based upon local laws and regulations.
• Verify that the payroll taxes were remitted to authorities as required.
• Trace total payroll voucher to the general ledger.
• Trace each host country national (HCN) employee to personnel records noting that the appropriate personnel records are maintained in CAMRIS’ cloud-based human resources management system. Education, experience, promotions and salary increase documents are to be filed in each personnel file.
• Verify that the current pay rates are authorized in writing in each employee’s personnel file.
• Recalculate amounts withheld and verify accuracy of amounts withheld and pay.

Petty Cash and Bank Accounts:

• Review petty cash payments and/or reimbursements, performing the following compliance review steps,
• Perform unannounced spot counts of all petty cash funds in the presence of the petty cash custodian.
• Trace each item to the proper documentation (i.e. invoices, receipts, etc.)
• Verify that each payment or reimbursement was properly approved.
• Verify that monthly bank reconciliation is prepared within a reasonable time after receipt of bank statement.
• Verify that bank reconciliation was signed and dated by the person who prepared it.
• Verify that there was evidence of a supervisory review on bank reconciliation performed by the SOM/DCOP or COP.
• Determine if reconciling items were cleared in a timely manner.
• Check that the book balance agrees with bank statement.

Accounts Receivable: 

• Out of current significant receivables at each year-end covering the compliance review period, five to ten receivables are selected for compliance testing as follows,
• Determine the nature and type of receivables, advances represents normal office activity and complies with office policy.
• Verify that adequate documentation and explanation exists and that receivables, advances, and any other loans are properly approved.
• Review that subsidiary ledgers are maintained and monitored to control advance accounts on a regular basis.
• Verify that outstanding advance balances are checked prior to new advances being issued.
• Verify that advances are settled within established deadlines and that advance settlements are supported by expense report and are properly approved.
• Verify that outstanding balances of advances appear reasonable and are collectible.
• Test that reconciliation of fuel advance account is being performed for each fuel card at least monthly and accurate recording of fuel consumed charged to the correct activity and operations CLINs and account codes are being correctly recorded.
• Test that reconciliation of any Mobile Money advance accounts is being performed at least monthly and accurate recording of Mobile Money transactions are being charged to the correct activity and operations CLINs and account codes are being correctly recorded.

Accounts Payable:

• Review all current significant accounts payable at each quarter- and year-end (i.e. settlement advice, payroll taxes, payments on office and residential leases, etc.). From there a sample of 5-10 payables to verify if subsequent payment was made and perform the following compliance review steps,
• Verify that subsidiary ledgers are maintained.
• Determine that subsequent payments were made
• If applicable, verify that accruals were properly approved.

Fixed Non-expendable Property:

• Obtain the current non-expendable inventory and perform the following compliance review steps,
• Verify that the following information is provided for each non-expendable property item: 1) date of acquisition, 2) description, 3) cost in USD.
• A sample of 5 largest non-expendable property items is selected and their physical existence is verified. Agree the cost of the five largest non-expendable property items shown on the listing as of the end of FY month to purchase invoices.
• Depreciation for the period is recalculated for the period and the recomputed amount is agreed to the general ledger.
• Determine if the assets are properly insured with regards to CAMRIS coverage, and local office fire and theft coverage.

Ethical Issues:

• Determine that all staff have signed a disclosure clause on conflict of interest.
• By obtaining the personnel files of all HCN employees and verify that all personnel files contain the “conflict of interest” confirmation signed by the individual employee.
• Verify that each employee has signed a confirmation acknowledging receipt of CAMRIS Manuals including the Activity Manual Addendum, Field Procurement Guide, Physical Security, Operational Communications, Emergency, and Information Security Plans, CAMRIS Ethical Business Practices, Code of Conduct, and Sexual Abuse and Exploitation policies and signed confirmation is filed in each employee’s file.
• Any other duties and tasks as needed and assigned.

Qualifications
Required Skills & Experience:

• Four-year university degree in Finance, Accounting, Business Administration, Management, or a related field.
• Minimum of eight (8) years general work history is required.
• Six to eight years’ experience in Compliance, accounting, finance, and/or program management.
• A graduate degree in business administration, public administration, or a related field, or certification as CIA, CPA, or CISA may substitute for one year of required experience. The combination of a graduate degree and a certification may substitute for two years of required experience.
• Knowledge of and skill in applying internal Compliance and accounting principles and practices, and management principles and preferred business practices.
• Knowledge of the standards of professional practices of internal Compliance and the code of ethics developed by the institute of Compliance Officers.
• Knowledge of management information systems technology, concepts, and practices.
• Knowledge of government of Nigeria policies, procedures, regulations, and laws.
• Skill in conducting quality control reviews of Compliance work products.
• Skill in collecting and analyzing complex data, evaluating information and systems and drawing logical conclusions.
• Ability to plan and manage work, and in maintain composure under pressure while meeting multiples deadlines.
• Ability to communicate effectively both verbally and through written communications and active listening skills and skill in presenting findings and recommendations.
• Excellent interpersonal skills with the ability to work cooperatively, tactfully and diplomatically with a culturally diverse group of people.
• Ability to foster and maintain a spirit of unity, teamwork, cooperation, and learning.
• Ability to establish and maintain harmonious working relationship with CAMRIS colleagues, USAID staff, and partners, and to work effectively in a professional team environment.
• Excellent analytical and writing skills, including strong attention to detail.
• In-depth understanding of USAID’s ADS, AIDAR, and the FAR, and the regulations which apply to NLCB activities and awards.
• Ability to develop in-depth understanding of and willingness to comply with all CAMRIS and USAID/OTI procedures and manuals (e.g., Activity Management Guide. Activity Cycle Flowchart. Field Procurement Guide. and Operational Communications, Emergency, Information, and Physical Security Plans).
• Experience with budgeting and cost analysis.
• Willingness and ability to travel throughout northeastern Nigeria and to other countries in the LCB.
• Ability to work under pressure, efficiently handle multiple tasks, quickly find creative solutions to problems and challenges that arise, and manage stress and time in a fast-paced work and fluid operating environment.
• Sensitivity in working with multiple cultures and beliefs and commitment to gender equity.
• Proficient with Microsoft Office software: MS Word, Excel, PowerPoint, Outlook, etc.
• Excellent record keeping and documentation skills.
• Prior experience working in northeastern Nigeria and/or a conflict environment.
• Written and spoken fluency in English.
• Ability to work both independently and as a part of a team.

Preferred Skills & Experience:

• Prior experience with USAID- or US Government-funded projects.
• Prior experience using cloud-based accounting, procurement, and human resource management applications.
• Master’s degree in a related field preferred.
• Experience with a USAID program with a large and high volume small grants component preferred.
• Fluency/proficiency in local languages used in northeastern Nigeria (Hausa, Kanuri, and Fulfulde, etc.) and/or French.