Archived - Audit of the Debt Management Process
Revised Final Report
June 27, 2011

Archived information

Archived information is provided for reference, research or recordkeeping purposes. It is not subject to the Government of Canada Web Standards and has not been altered or updated since it was archived. Please contact us to request a format other than those available.

Prepared by Internal Audit and Evaluation for the:
Audit and Evaluation Committee meeting of June 7, 2011
Finance Canada

Table of Contents

Executive Summary
Background
Audit Objective and Scope
Approach, Assurance Statement and Auditing Standards Employed
Conclusion
Findings by Audit Criteria
Recommendations and Management Action Plan

Appendices

Executive Summary 

A key responsibility of the Department of Finance (the Department) is to manage Canada’s federal debt.  Debt management is the process of establishing and implementing a strategy for prudently managing the government’s debt in order to meet its financing needs, cost and risk objectives, and other related goals, such as developing and maintaining an efficient market for government securities.

The Department manages the federal debt in partnership with the Bank of Canada (BoC).  The Financial Sector Policy Branch within the Department is responsible for the Treasury and Financial Affairs Program Activity.  This includes Federal Debt Management, Major Federal-Backed Entities Borrowing, Reserves Management and Management of Retail Debt for the Federal Government. 

The objective of the audit was to assess the management and control processes in place, relating to the Department’s role in the administration of the federal debt.

The audit concluded that overall, the Department’s management and control processes related to the administration of the federal debt contribute to the effective management of this function.  In particular, the following key positive aspects are worth noting:

  • An oversight body of the debt process in the Department is established with a clearly communicated mandate
  • Assessments of the Department’s management activities, related to the federal debt, are regularly conducted and publicly disclosed
  • Debt management activities in the Department are supported by an appropriate management information system with effective controls to ensure transactions are coded and recorded accurately, and in a timely manner
  •  The public is provided with relevant information regarding the federal debt such as currency, maturity, and interest rate structure
  • Management compares results achieved in its debt management practices against expectations on a periodic basis

An opportunity for improvement was identified with regards to providing the public with additional information which:

  • Further describes the market risks being managed, including a historical context for the debt portfolio, as well as a description of the analysis undertaken to support the recommended debt management strategy, clarifying the assumptions used and limitations of the analysis
  • Further compares results achieved regarding debt management against expectations

Background 

The Audit of the Debt Management Process was approved as part of the Department’s three-year risk-based audit plan, which was tabled at the Departmental Audit and Evaluation Committee meeting on December 8, 2009.

Debt management is the process of establishing and implementing a strategy for prudently managing the government’s debt in order to meet its financing needs, cost and risk objectives, and any other related goals, such as developing and maintaining an efficient market for government securities.  The International Monetary Fund (IMF) and the World Bank have provided governments with the following debt management tools:

  • Guidelines for Public Debt Management  2003 (refer to Appendix C for details); and
  • Debt Management Performance Assessment Tool – Revised 2009 (refer to Appendix E for details)

An important responsibility of the Department is the sound management of public debt and the management of federal borrowing on financial markets.  This is a joint responsibility between the Department and the BoC.  The Department’s Financial Sector Policy Branch is responsible for the:

  • Federal Debt Management – Setting a strategy for the Government of Canada (the Government) market debt; ensuring government cash requirements are met
  • Major Federal-Backed Entities Borrowing – Direct lending to large borrowers, advising on borrowing plans, promoting sound risk management and governance practices
  • Reserves Management – Overseeing framework for prudent and efficient financing and investment of foreign reserves portfolio
  • Management of Retail Debt for the Federal Government

Audit Objective and Scope 

Objective

The objective of the audit was to assess the management and control processes in place, relating to the Department’s role in the administration of the federal debt.

Scope

The audit scope included the portion of federal debt raised directly by the government through the financial markets (e.g. Canadian dollar borrowings in the domestic market) from January 2007 to October 2010. The audit covered the extent to which the Department had appropriate management and controls in the following areas:

  •  An oversight body of the debt process in the Department is present
  •  Assessments of the Department’s management activities related to the federal debt are conducted
  • Debt management activities in the Department are supported by an appropriate management information system
  •  The public is provided with relevant information regarding the federal debt such as currency, maturity, and interest rate structure
  •  Management compares results achieved in its debt management practices against expectations

The scope did not include:

  • Liabilities to public service pension plans, liabilities of Crown corporations incurred through their own name and other contingent liabilities such as loan and loan guarantees
  • Process, inputs and interrelationships with other government departments and agencies, such as the BoC and Public Works and Government Services Canada

Approach, Assurance Statement
and Auditing Standards Employed

The audit was conducted in accordance with the Internal Audit Standards of the Government of Canada.  These standards require that the audit be planned and performed in such a way as to obtain reasonable assurance that the audit objective is achieved.  During the audit, appropriate procedures were followed and sufficient evidence was obtained to support the accuracy of findings and the overall audit opinion presented in this report.  The opinion is based on a comparison of the conditions, as they existed at the time of the audit, against the audit criteria identified within this report, which was accepted by management.  The opinion is applicable only to the entity examined.

Audit procedures included, but were not limited to, interviews, observations, review of supporting documentation, and analytical reviews.  The audit criteria used to develop the required audit tests were based on (1) the Financial Administration Act, (2) the Treasury Board Policy on Internal Control, (3) relevant elements of the Office of the Comptroller General’s Core Management Controls, and (4) good management practices such as relevant elements from the International Monetary Fund (IMF) and World Bank’s Guidelines for Public Debt Management and the World Bank’s Debt Management Performance Assessment Tool.

In total, eleven individuals were interviewed including personnel from the Department’s Financial Sector Policy Branch (FSPB) and Corporate Services Branch (list of interviewees is provided in Appendix A).  The audit team also conducted a review and analysis of applicable authorities and policies, as well as financial and non-financial documents from various relevant sources (list of key documents consulted is provided in Appendix B).

The audit approach allowed for the audit results to be communicated in such a manner as to enable management to review and provide feedback on the findings and conclusions before they were finalized.

Conclusion 

The audit concluded that overall, the Department’s management and control processes related to the administration of the federal debt contribute to the effective management of this function.  In particular, the following key positive aspects are worth noting:

  •  An oversight body of the debt process in the Department is established with a clearly communicated mandate
  •  Assessments of the Department’s management activities, related to the federal debt, are regularly conducted and publicly disclosed
  •  Debt management activities in the Department are supported by an appropriate management information system with effective controls to ensure transactions are coded and recorded accurately, and in a timely manner
  •  The public is provided with relevant information regarding the federal debt such as currency, maturity, and interest rate structure
  •  Management compares results achieved in its debt management practices against expectations on a periodic basis

An opportunity for improvement was identified with regards to providing the public with additional information which:

  •  Further describes the market risks being managed, including a historical context for the debt portfolio, as well as a description of the analysis undertaken to support the recommended debt management strategy, clarifying the assumptions used and limitations of the analysis
  •  Further compares results achieved regarding debt management against expectations 

Findings by Audit Criteria 

The following table presents the assessment of the level of risk exposure identified in the audit. Levels of risk exposure are categorized by audit criteria. 

High exposure
Medium exposure
Low exposure

The risk ranking is based on the level of risk exposure. A high, medium or low ranking corresponds to the potential risk exposure auditors believe may have an impact on the achievement of Department objectives, and is indicative of the priority management should give to address, if applicable, the related recommendations.

The assessment summarizes the audit observations based on the factual evidence gathered and analyzed during the audit. Based on these assessments, issues/themes along with potential causes, impacts, management initiatives and recommendations are summarized in the “Recommendations and Management Action Plan” section.

Findings by Audit Criteria
Criteria Risk Exposure Findings
An oversight body of the debt process in the Department is established with a clearly communicated mandate. Low

An oversight body of the debt process in the Department is established with a clearly communicated mandate.

The Department and the BoC work jointly, through various committees, to develop financial and liability management strategies.  The most senior of these committees is the Funds Management Committee (FMC).  The FMC is an advisory committee to the Minister of Finance, consisting of Senior Executives from both organizations, which oversees all activities covering the Government’s financial asset and liabilities, including those related to federal debt management. 

In line with this oversight function, the Department’s Treasury Evaluation Program (TEP) provides assessments of the key frameworks and programs related to federal treasury management.   As such, the TEP’s role is an essential part of the decision-making process related to federal debt management.

The audit compared the TEP’s role with expectations of similar oversight/review structures and found that the TEP’s:

  • Charter adheres to relevant Treasury Board Secretariat (TBS) guidelines
  • Activities have an important role related to the responsible and sound management of the federal debt
Assessments of the Department’s management  activities, related to the federal debt, are regularly conducted and publicly disclosed. Low

Assessments of the Department’s management  activities, related to the federal debt, are regularly conducted and publicly disclosed.

Debt management activities have been the subject of at least eleven evaluations, one external audit and two internal audits over the past 11 years.

The audit compared the areas of coverage examined by these assessments to the six areas identified in the 2003 IMF and World Bank’s Guidelines for Public Debt Management  (the Guidelines).

The audit found that:

  • There were no gaps identified in the coverage of these assessments, as they encompassed all of the components of the Guidelines (refer to appendix D for details)
  • All relevant recommendations resulting from these engagements have been addressed or are currently in the process of being addressed.   An example can be found under the next criteria where authorization letters are discussed
For example, an evaluation of the Government of Canada Debt Auction Process was completed in December 2010.  The evaluation’s purpose was to assess the design, approach, controls, relevance and performance related to the management of the auction process.  The evaluation found that:
  •  The current structure works well, and supports the transparency, effectiveness and efficiency of debt auctions
  •  The auction process has been successful in raising necessary funding at a low cost and sustaining a liquid and efficient secondary market for the Government of Canada’s debt
Furthermore, one evaluation is currently underway to assess the Asset Allocation Framework for the liquid reserves component of the Exchange Fund Account and another is being planned to focus on the Government’s Crown Borrowing Program.
Debt management activities in the Department are supported by an appropriate management information system. Low

Debt management activities in the Department are supported by an appropriate management information system with effective controls to ensure transactions are coded and recorded accurately, and in a timely manner.

The audit examined the reliability of financial reporting, compliance with applicable laws and regulations, as well as the effectiveness and efficiency of operations, related to the Department’s debt management activities.  This included conducting an environmental scan of the control environment, analyzing documentation related to financial controls and conducting audit tests on a sample of 30 transactions.

The audit concluded that:

  •  Key controls relating to debt issuance, debt charges, debt redemption and financial statement presentation/disclosure have been designed based on leading control guidance and were found to be working as intended.  For example, the audit determined that the following key controls were functioning effectively:
    • Each borrowing operation performed by the BoC is authorized by the Department (Debt issuance). The current control process to send authorization letters to the BoC for each debt issuance operation, as performed and tested during the period covered by this audit, will be updated to improve efficiency.  In quarter one of 2011-12 this control is to be replaced with a pre-authorized debt issuance schedule/operation, email confirmations and quarterly summary reports. This improvement origins from a recommendation of the Debt Auction Process Evaluation
    • Interest accruals are recorded on a monthly basis to ensure accuracy (Debt charges)
    • Monthly reasonability test of total interest expense by bond type are conducted (Debt charges)
    • Adherence to Sections 33 and 34 of the Financial Administration Act (FAA) for bonds buybacks is monitored (Debt redemption)
    • Reconciliation of the amount of debt outstanding at Department of Finance with BoC reports (Financial statement presentation/ disclosure)
  • Financial Management Directorate has a risk assessment approach in place to mitigate risks associated with the financial reporting of debt-related operations
  • Effective controls were in place to ensure that transactions are coded and recorded accurately, and in a timely manner
The public is provided with relevant information regarding the federal debt. Low

The public is provided with relevant information regarding the federal debt such as currency, maturity, and interest rate structure.

The audit examined the completeness and timeliness of financial and non-financial debt related reporting, with a focus on transparency.  The audit also examined the extent to which enhancements were made based on emerging issues, such as the 2007 amendments to the Financial Administration Act.  The audit compared the reporting practices of the Government of Canada’s Debt Management Strategy with:

  •  World Bank’s Debt Management Performance Assessment Tool  (Debt Strategy Portion)
  •  Other leading and similar jurisdictions (based on World Bank performance indicators)
The audit found that the Department has adapted its debt reporting practices, as required, to provide greater transparency over the past few years.  Debt reporting includes the annual publication of the Debt Management Strategy and the Debt Management Report, which provide a detailed account of the Government of Canada's borrowing and debt management activities.  The audit, however, identified the following opportunity to provide additional information in these documents which:
  •  Further describes the market risks being managed, including a historical context for the debt portfolio, as well as a description of the analysis undertaken to support the recommended debt management strategy, clarifying the assumptions used and limitations of the analysis
Management compares results achieved in its debt management practices against expectations on a periodic basis. Low

Management compares results achieved in its debt management practices against expectations on a periodic basis.

The audit examined the Department’s performance management framework and reporting related to debt management.

In our audit we:

  •  Compared the sections of the annual Departmental Performance Report relevant to debt management with the TBS’ Performance Reporting: Good Practices Handbook (2010) (the TBS Handbook), including consideration of feedback the Department received regarding its performance reporting practices and recent changes
  •  Examined key aspects of the Department’s debt management related to performance monitoring and reporting

During the period examined by the audit, the Department received favourable comments from TBS on its performance reporting practices, including a rating of “strong” the last time this Management Accountability Framework (MAF) criteria was assessed.

However, in lieu of recent changes to the Government’s reporting expectations (e.g.: the TBS Handbook), the audit identified the following opportunities to provide additional information:

  • Improved linkages between identified performance measures and planned results
  • Improved monitoring of actual performance against planned results
It should be noted that the Department is currently working towards strengthening this area through the development of high-level performance indicators for the federal debt.

Recommendations and Management Action Plan

The following section presents the key opportunities for improvement identified during the audit. The impact and recommendation are also presented. Where applicable, the relevant management initiatives already underway are included.For eachrecommendation, management has provided:

  • An action plan, which addresses the recommendation;
  • The position responsible for implementing the action plan; and,
  • The target date for completion.

Provide the public, including the financial markets, with additional information on debt management

Observations and Impact

As part of the Government’s commitment to strengthen accountability and increase transparency in government operations, it is important that the public, including financial markets, receive relevant information on the federal debt.

Although the public is provided with the annual Debt Management Strategy (DMS) and Debt Management Report (DMR), the audit found that an opportunity exists to provide additional information that further describes the market risks being managed, including a historical context for the debt portfolio, as well as a description of the analysis undertaken to support the recommended debt management strategy, clarifying the assumptions used and limitations of the analysis.

Furthermore, the audit found that the opportunity exists to provide more information in the Departmental Performance Report on the performance of debt activities, including improved linkages between performance measures and planned results, and the monitoring of actual performance against planned results.

Providing additional information is important for the following reasons:

  •  Debt management  effectiveness is strengthened when details of market risks, analysis and performance are publicly known, as this enhances the credibility of the debt management strategy
  •  Further transparency enhances good governance through greater accountability of all public institutions involved in debt management

In the aftermath of the global economic crisis, Department officials indicated that efforts in recent years were focused on the economic recovery.  Now that the crisis appears to have stabilized, the Department has begun working towards strengthening the provision of performance information through the development of high-level performance indicators for the federal debt.

Recommendation

It is recommended that the Debt Management Strategy and relevant portions of the Departmental Performance Report, which are compiled under the direction of the ADM, Financial Sector Policy Branch provide:

1. Detailed public information on the debt (e.g.: market risks, historical context for the debt portfolio, description of the analysis undertaken to support the recommended debt management strategy)

2. Improved performance and monitoring information on debt activities in the Departmental Performance Report (DPR)






















Management Response

This observation relates to how the government presents and justifies its debt strategy, including the basis for decisions that impact the structure of the debt portfolio over the medium and long-term horizon. The Debt Management Strategy (DMS) for 2011-12 will build upon an already strong foundation for communication of the debt management strategy with the inclusion of projected paths for a selection of new indicators. These will include the average term to maturity of debt; the re-fixing share of debt, which measures the proportion of all interest-bearing debt net of financial assets that matures or needs to be re-priced within one year; and measures of rollover risk, such as single-day rollover of maturing debt. These metrics will help illustrate the analysis behind the elaboration of the planned debt issuance strategy and the projected future outcomes. A rationale for the increased focus on the issuance in certain bond sectors will also be provided.

Target Completion Date:  March 2011 (Completed). The debt program does not lend itself easily to simple and clear quantitative performance targets, so work in this area will be ongoing, and progress made monitored and recorded. Opportunities for improving the information content and clarity of the debt management process in the Department’s Report on Plans and Priorities/ DPR will also be explored, with possible links to the DMS/ DMR publications. In addition, the new internal quarterly debt management report, to be launched in April 2011, will improve the monitoring and reporting to senior management.

Target Completion Date:  November 2011 (The expected release date of the DPR 2010-11).

Appendix A – List of Personnel Interviewed

Department of Finance Personnel

General Director, Financial Sector Policy Branch (FSPB)

Director, Financial Markets Division, FSPB

Chief, Domestic Debt Management Policy, Financial Markets Division, FSPB

Economist, Domestic Debt Management Policy, Financial Markets Division, FSPB

Financial Economist, Government Financing, Financial Markets Division, FSPB

Director, Corporate Accounting & Public Debt, Corporate Services Branch 

Manager, Corporate Accounting & Public Debt, Corporate Services Branch

Office of the Auditor General Personnel

Principal, Audit Operations

Director, Audit Operations

Audit Project Leader, Audit Operations

Audit Professional, Audit Operations

Appendix B – List of Key Documents Consulted

Legislation

  • Financial Administration Act

Policies

  • Treasury Board Policy on Internal Control 2009
  • Finance Canada Accounting Policy on Financial Statements

Directives and Guidelines

  • Treasury Board Directive on Recording Financial Transactions in the Accounts of Canada
  • Treasury Board Secretariat – Performance Reporting: Good Practices Handbook 2010
  • Public Works and Government Services Canada – Receiver General’s Manual: Public Accounts Instructions for 2009-10 (Chapter 15)
  • International Monetary Fund and the World Bank – Guidelines for Public Debt Management 2003
  • The World Bank – Debt Management Performance Assessment (DeMPA) Tool 2009

Documents Specific to Finance Canada

  • Corporate Risk Profile 2010
  • Reports on Plans and Priorities from 2008-09 to 2010-11
  • Departmental Performance Reports from 2008-09 to 2010-11
  • Entity-level controls self-assessment (2007)
  • Business process narratives for domestic and foreign debt (2009-10)
  • Control matrix for domestic debt (2009-10)
  • Various internal financial reports related to the Federal Debt – 2010 (e.g.: Bond amortization, Exchange Fund Account tracking, swap tracking, summarized trial balance, public debt charge reconciliations, financial risk assessment, list of journal vouchers processed at year-end)
  • Funds Management Committee meeting minutes and related documentation (e.g.: Debt management metrics review (May 2010))

Other Documents

  • Public Accounts of Canada and related Plates for the 2008-09 and 2009-10 fiscal years
  • Canada’s Debt Management Strategy and Debt Management Reports from 2007 to 2010
  • Debt Strategy Consultations Summaries from 2007 to 2010
  • Auditor General of Canada – Audit of Managing Canada’s Debt: Facing New Challenges April 2000
  • Auditor General of Canada – Management Letter to the Department for fiscal year 2008-09
  • Auditor General of Canada – Financial Capability Model 1997
  • Audited Statement of Government of Canada Debt Outstanding as at March 31, 2010

Appendix C – International Monetary Fund and the World Bank’s Guidelines for Public Debt Management (2003)

A. Debt Management Objectives and Coordination: Objective is prudent and risk-based management of debt. Main financial obligations are scoped-in. Monetary and fiscal policies are coordinated.
B. Transparency and accountability: Debt management operations occur in an environment of transparency and accountability.
C. Institutional Framework: Organizational framework for debt management is based on sound governance structure and business practices.
D. Debt Management Strategy: Debt management strategy considers inherent risks to debt structure and costs.
E. Risk Management Framework: A risk management framework is developed for identifying and managing the trade-offs between expected cost and risk in the government debt portfolio.
F. Development and Maintenance of an Efficient Market for Government Securities: A government securities market is developed and maintained to help create a liquid and efficient domestic debt market.

Appendix D – Previous Assessments Coverage

Debt management activities have been the subject of at least fourteen evaluations and audits over the past 11 years, including both external and internal engagements.  The fourteen assessments are listed as follows:

  •  2000 April Report: Chapter 8 – Department of Finance – Managing Canada’s Debt: Facing New Challenges
  •  Evaluation of the Government’s Decision to Target a Higher Fixed Rate Debt Structure (February 2002)
  •  Developing Well Functioning Canada Bond and Bill Markets (March 2002)
  •  External Review of the Reserves Management Framework (December 2002)
  •  Evaluation of the Bond Buyback Program (April 2003)
  •  Review of Canada Savings Bonds (January 2004)
  •  Governance Evaluation: Debt and Reserves Management (March 2004)
  •  Audit of Administrative Controls over the Domestic Debt (July 2004)
  •  Review of Borrowing Framework of Major Federal Government-Backed Entities (June 2005)
  •  Audit of Administrative Controls over the Foreign Debt Portfolio and Foreign Currency Asset Reserves (May   2006)
  •  Report on the Evaluation of the Receiver General Cash Management Program (June 2006)
  •  Evaluation of the Exchange Fund Account (July 2006)
  •  Risk Management Report (November 2007)
  •  Debt Auction Process (December 2010)
Previous Assessments Coverage
√ indicates the assessment covered one of the six guideline areas of the 2003 IMF and World Bank Guidelines for Public Debt Management.
IMF/World Bank Guidelines for Public Debt Mgmt (2003) A. Debt Mgmt. Obj and Coord. B. Transp and Acc. C. Inst. Fram. D. Debt Mgmt Strat E. Risk Mgmt Fram F. Dev. and Main. of an Efficient Market for Gov. Securities
April 2000
External Audit

Managing Canada’s Debt: Facing New Challenges
Feb. 2002
Evaluation

Govt’s Decision to Target a Higher Fixed
Rate Debt Structure
     
March 2002
Evaluation

Canada Bond and Bill Markets
       
Dec. 2002
Evaluation 
Reserves Management Framework
 
April 2003
Evaluation

Bond Buyback Program
 
Jan. 2004
Evaluation

Canada Savings Bonds
       
March 2004
Evaluation 
Debt and Reserves Management
       
July 2004
Internal Audit
Domestic Debt
     
June  2005
Evaluation

Borrowing of Major Fed.
Govt-Backed Entities
May 2006
Internal Audit 
Foreign Debt and Foreign Currency Asset Reserves
June 2006
Evaluation
Receiver General  Cash Mgmt Program
July 2006
Evaluation

Exchange Fund Account
 
Nov. 2007
Evaluation

Risk  Management
         
Dec. 2010
Evaluation

Debt Auction Process

Appendix E – World Bank Debt Management Performance Assessment Tool - Revised 2009

Set of 15 performance indicators grouped under 6 themes, as follows:

1. Governance and Strategy Development

  • Legal framework clearly sets out the authority to borrow and undertake debt-related transactions
  • Managerial structure for debt management is clearly divided between the political level and the entities tasked with implementation
  • Debt management strategy is based on the longer-term debt management objectives and is set within the context of the government’s fiscal policy and budget framework
  • Evaluation of debt management operations is in place to ensure accountability for debt management activities 
  • Audit is performed to ensure scrutiny of debt management operations

2. Coordination with Macroeconomic Policies

  • Coordination with fiscal policy
  • Coordination with monetary policy

3. Borrowing and Related Financing Activities

  • Domestic market borrowing activities are transparent and predictable, to provide the government with a mechanism to finance its expenditures in a cost-effective manner, while minimizing the risks
  • External borrowing activities are well documented, have sound legal documentation, and are contracted on the most beneficial or cost-effective terms
  • Loan guarantees, on-lending, and derivatives are approved and issued within a strong control environment and clear operational guidelines

4. Cash Flow Forecasting and Cash Balance Management

  • Cash flow forecasting and cash balance management are performed in a cost-effective manner with the appropriate policies in place

5. Operational Risk Management

  • Debt administration and data security with strong controls and well-documented procedures are in place, for the settlement of transactions, maintenance of the financial records, and access to the debt management system
  • Segregation of duties, staff capacity, and business continuity are all supported by the appropriate plans and controls

6. Debt Records and Reporting

  • Debt records are in place with accurate, consistent, and complete debt information
  • Debt reporting is taking place with regularly published information on the debt composition

Appendix F – Audit Team 

The members of the audit team are:

  • Jean-Luc Tétreault, CA-CIA, CGA, CMA, Audit Manager
  • Abdillahi Roble, CGA, Senior Financial Auditor
  • Rim Ben Saad, B. Comm., Senior Financial Auditor
  • Darine Tabbal, B. Comm., Junior Auditor
  • Ziad Shadid, CGA, B. Comm., Audit Manager
  • Michael Allen, B. Comm., Auditor
  • Christian Kratchanov, MBA, CIA, Adm.A., CMC, Chief Audit and Evaluation Executive