RESTRICTED  
  
WT/BFA/W/557  
7 June 2021 
(21-4642) Page: 1/47 
Committee on Budget, Finance and Administration   
 
  
 
 
 
 
 
 
 
 
 
 
 
 
ANNUAL REPORT  
ON THE ACTIVITIES OF THE OFFICE OF INTERNAL OVERSIGHT  (OIO)   
2020-2021 
 
 
  WT/BFA/W/557  
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  Table of Contents  
1   BACKGROUND  ................................ ................................ ................................ .............  3 
2   INDEPENDENT STATUS OF THE OIO  ................................ ................................ ............  3 
3   BUDGET AND STAFFING  ................................ ................................ ..............................  3 
3.1   Budget  ................................ ................................ ................................ .......................  3 
3.2   Staffing  ................................ ................................ ................................ ......................  4 
4   ACTIVITIES CONDUCTED BY THE OIO SINCE JULY 2020  ................................ .............  4 
4.1   Promote high standards of ethical behaviour  ................................ ................................ ... 4 
4.2   Assess the quality of the internal oversight functions  ................................ .......................  5 
4.3   Conduct administrative investigations  ................................ ................................ ............  6 
4.4   Perform internal audits  ................................ ................................ ................................ . 8 
4.5   Provide support and advice to management and stakeholders  ................................ ...........  8 
5   INTERNAL OVERSIGHT ACTIVITY FOR 2021 -2022  ................................ ......................  8 
ANNEX 1 – LIST OF ACRONYMS  ................................ ................................ ......................  10 
ANNEX 2 – INTERNAL AUDIT PLAN FOR 2020 – 2021  ................................ ....................  11 
ANNEX 3 – INTERNAL AUDIT PLAN FOR 2021 – 2022  ................................ ....................  12 
ANNEX 4 – INTERNAL AUDIT FUNCTION – QUALITY SELF -ASSESSMENT  ........................  13 
ANNEX 5 – INVESTIGATION FUNCTION – QUALITY SELF -ASSESSMENT  .........................  38 
 
 
 WT/BFA/W/557  
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  1  BACKGROUND  
1.1.  The Office of Internal Oversight (OIO)  provides for a professional, independent, objective and 
documented assessment of management practices, expenses, budgetary control and allegations of 
misconduct, through the conduct of  internal audits, investigations and any other form s of 
assessment that may be needed  in respect of management, staff and resources of the WTO . 
1.2.  Pursuant to Administrative Memorandum No.9741, the OIO shall report annually to the 
Committee on Budget, Finance and Administration ( CBFA) providing , for informati on, an overview 
of the activities conducted during the year  and indicating any circumstances that it considers may 
have affected its independence or otherwise impeded its ability to fulfil its functions.  
1.3.  In the first section of this report, t he Head of the  OIO confirms the independence of the internal 
oversight function at the WTO . The second section of the document is dedicated to the budget and 
staffing of the OIO. The third section of the document provides details on the activities conducted 
between July 2020 and May 2021 (11 months ). Finally, the OIO's priorities for 20 21-2022 are 
described in the last section of the report .  
2  INDEPENDENT STATUS OF THE OIO  
2.1.  Pursuant to Administrative Memorandum No.9742, and consistent with the standards of the 
International Professional Practice s Framework (IPPF)3, the OIO shall remain independent and free 
from interference when performing its work, and shall confirm its independence  to a level within the 
Organization that allows the internal o versight activity to fulfil its responsibilities.   
2.2.  Based on this  requirement , the Head of the OIO shall confirm to the Director -General and to 
the CBFA , every year,  that the OIO remain ed functionally and operationally independent from the 
WTO Secretariat and its Members in the conduct of its  duties .  
2.3.  In this framework , the Head of the OIO  hereby  certifies that no circumstances have affected, 
in fact or appearance, the independence of the OIO or impeded its ability to fulfil its functions and 
responsibilities in an impartial, unbiased, objective and independent manner . Neither the 
Director -General nor any other WTO senior official  have interfered with the work of the OIO.  
2.4.  Furthermore, t he OIO has received full and unrestricted access to all WTO records and staff 
members  whenever needed . The Head of the OIO ha s also been granted  direct and unrestricted 
access to the Director -General  (or the Deputy Directors -General, while acting ad interim jointly as 
Director -General) , senior management and the Chair of the CFBA.  
3  BUDGET AND STAFFING  
3.1.  In accordance with the International Standards for the Professional Practice of Internal Auditing  
(Institute of Internal Auditors ( IIA) Standard 2030 ), the Head of the OIO must ensure that internal 
oversight resources are appropriate, sufficient and effectively deployed to achieve the OIO's  work 
plan. 
3.1  Budget  
3.2.  The OIO has its own operational budget , which  was determined by the Director -General upon 
the ent ry into function of the current Head of the OIO  (i.e. September 2016) .  
 
1 Administrative Memorandum No.974  – Office of Internal Oversight, OFFICE(15)/101, 
30 November  2015 – par. 35 . 
2 Administrative Memorandum No.974  – Office of Internal Oversight, OFFICE(15)/101, 
30 November  2015  – para. 7 -11. 
3 The International Professiona l Practices Framework (IPPF) is the conceptual framework  promulgated 
by the Institute of Internal Auditors (IIA)  that organizes authoritative guidance  for performing and promoting 
professional internal auditing  activities. The International Standards for t he Professional Practice of Internal 
Auditing  are part of the IPPF – For more details : https://na.theiia.org/standards -guidance/Pages/Standards -
and-Guidance -IPPF.aspx . WT/BFA/W/557  
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  3.3.  The annual budget of the OIO increased by 1 1 per cent  in 2021  (i.e. for a total CHF 485,200), 
as a result of the recruitment of an Investigator at Grade 7 (instead of G rade 6). The bud gets and 
actual costs for 2020 and 20 21 (up to 3 0 April 2021 – i.e. 4 months ) are detailed in Table 1 – Budget 
and actual costs of the OIO (in CHF).  
Table 1 Budget and actual costs of the OIO (in CHF) 
 
2021 2020 
Account Description  
Budget  Actuals  
(30 April ) Budget  Actuals  
Staff / Salary (including pension)  462 200  146 337  410 900  398 343  
Special Service Agreements  15 000  255 15 000  0 
Air & Rail Transportation  8 000  0 8 000  0 
TOTAL  485 200  146 592  433 900  398 343  
 
3.4.  The OIO consumed  92 percent of its annual budget in 20 20, and 30 percent of the budget  in 
2020 (up to 30 April 2021 – i.e. 4 months ).  
3.2  Staffing  
3.5.  Since May 2020, the OIO is composed of  a Head of Office (Grade 10) , an Investigator (Grade  7) 
and an Administrati ve Assistant (Grade 4).   
3.6.  The current Head of the OIO has a five -year non -renewable term of office, which will end in 
September 2021. The process for recruiting the new Head of the OIO was initiated on 15 April 2021 
(Vacancy Notice EXT/F/21 -16) and is expec ted to be completed  before September 2021.  
3.7.  The current Head of the OIO will discuss with the recently appointed Director -General the 
necessity to further align the OIO's budget and staffing to the requirements of the office.  
3.8.  Also, p ursuant to Administrat ive Memorandum No.9744, the OIO's operational budget and 
staffing requirements shall be  determined by the Director -General upon the entry into function of 
each new Head of the OIO, further to a recommendation of the latter. Hence, the new Head of the 
OIO will discuss the OIO's budget and staffing requirements for the next five ( 5) years  with the 
Director -General and  provide recommendations in this respect .  
4  ACTIVITIES CONDUCTED BY THE OIO SINCE JU LY 2020 
4.1.  The activities of the OIO in  2020-2021 were organized around the following f ive (5) pillars:  
 
1) Promote high standards of ethical behaviour ;  
2) Assess the quality of the internal oversight function s; 
3) Conduct administrative  investigations;  
4) Perform internal audits ; and 
5) Provide support and advice  to management and stakeholders . 
4.1  Promote high standards of ethical behaviour  
4.2.  The OIO continued to advocate for the promotion of a respectful, harmonious, inclusive and 
ethical working environment across  the WTO.  
 
4 Administrative Memorandum No.974  – Office of Internal Oversight, OFFICE(15)/101, 
30 November  2015 – par. 12.  WT/BFA/W/557  
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  4.3.  It actively participate d in the '' Respect&Harmony@WTO '' programme, which aims at promotin g 
a more harmonious and safe work environment at the WTO, free from discrimination, harassment 
and abuse of authority.5 More than 80  percent  of WTO Fixed Term and Regular staff members have 
now successfully completed  the mandatory Respect&Harmony@WTO e -learning programme.  
4.4.  The OIO also continued to actively participate  in the Working Group on Ethics, which is 
responsible for  of rev iewing the WTO Standards of Conduct and designing  training s/workshops  on 
Ethics . 
4.5.  Furthermore, t he OIO participated in several Et hics-related virtual events and workshops co-
sponsored by the Human Resources Division ( HRD) Learning Service and Career Development  
Section, such as  webinars on Ethics (17 and 23 November , and 1 and 15 December 2020), i nduction 
sessions for newly hired st aff members (3 and 8 December 2020 , and 4 May 2021) , workshops on 
Micro -aggressions (4 and 6 May 2021) and workshops on Courage and Speaking up (27 May  2021). 
4.6.  The OIO and the HRD Learning Service and Career Development  Section have also been 
exploring the possibility of having a dedicated Ethics Officer at the WTO. Several options are 
currently being analysed , such as  sharing the position with another International Organization  or 
contracting  a part -time expert.  
4.7.  In ord er to be acquainted with good practices applied in other International Organizations, t he 
OIO actively participated in several professional forums, such as  those held by the Representatives 
of Internal Audit Services (RIAS) , the Representatives of Investig ations Services (RIS)  and the Ethics 
Network of Multilateral Organizations (ENMO) . These forums are meant for the  heads of internal 
audit/investigations /ethics  services of International Organizations to establish guidance for internal 
audit/investigations /ethics  in the international public sector .  
 
4.8.  In addition , the OIO participated to several virtual conferences, such as the International 
Federation of Red Cross and Red Crescent  (IFRC) Conference on Fraud (16 -22 November 2020) and 
the 21st Conference of In ternational Investigators  (CII, 3-6 May 2021 ). The objectives of the se 
conference s were to enable and enhance close cooperation and collegiality among the investigative 
offices of  the participating organizations and to facilitate the exchange of information and the 
discussion of critical integrity issues and new developments.  
 
4.2  Assess the quality of the internal oversight function s 
4.9.  At the request of the World Intellectual Property Organization (WIPO) , the OIO conducted an 
External Quality Assessmen t (EQA)  of WIPO's  Investigation function. The principal objectives of the 
EQA were to evaluate the effectiveness of WIPO's Investigation function in carrying out its mission, 
by (1) Assessing the conformity of WIPO 's Investigation function to the standards  set forth in the 
Uniform Guidelines for Investigations  endorsed by the CII , the WIPO Internal Oversight Charter and 
the WIPO Investigation Policy; and  (2) identifying opportunities to enhance the Investigation 
function 's resource management, work processe s and overall value to WIPO.  The EQA report was 
submitted to the Director of WIPO's Internal Oversight Division on 18 December 2020.  
4.10.   The OIO decided to conduct a similar exercise in order to (self) -assess the quality  and 
compliance  of its investigation activities. The results of the Quality Self -Assessment  of the OIO 's 
Investigation function  are detailed in Annex 5 - Investigation Function – Quality Self -Assessment . 
4.11.   According to  the Quality Self -Assessment, the OIO Investigation fun ction generally complies 
with 91  percent  of the standards set forth in the Uniform Guidelines for Investigations  (i.e. 31 out 
of 34 standards). The OIO partially complies with the three (3) other standards. The revised 
Procedure for Administrative Investigations and Disciplinary Actions, which is currently being 
reviewed by the Joint Advisory Committee, contains provisions  for accepting anonymous complaints 
(Standard 22) and reinforcing the protection of whistle -blowers against retaliation ( Standard 12). 
Additionally, the OIO will liaise with the Office of the Legal Counsel to discuss the possibly of 
includ ing, whenever possible, provisions in contracts with third parties specifying that they shall 
cooperate with an admin istrative investigation  (Standard 15) . 
 
5 Based on Administrative Memorandum No. 985 – Right to Work in an Environment free from 
Discrimination, Harassment and Abuse of Authorit y, OFFICE(18)/37, 30 April 2018.  WT/BFA/W/557  
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  4.12.   Separately, the OIO also conducted a Quality Self -Assessment of its Internal Audit function. 
The results of the Quality Self -Assessment of the OIO 's Internal Audit  function are detailed in 
Annex  4 – Internal Audit  Function – Quality Self -Assessment . 
4.13.   According to the results of the Quality Self -Assessment, the OIO Internal Audit function  fully 
or partially complies with all the IIA Standards and Rules of Conduct except IIA Standard 1000 (i.e. 
''The internal audit charte r must be approved by the board or audit committee '').  
4.14.   The OIO identified the following main areas of improvement in order to fully comply with all 
the IIA Standards:  
 
1) The Internal Oversight Charter  (i.e. Administrative Memorandum No.9746), defining 
the purpose, authority, and responsibility of the OIO , should be reviewed  to include 
the definition of internal auditing and  to recognize the nature of consulting 
engagements . The revised Charter should be submitted to the Director -General and 
the CBFA for discussion and approval;  
2) An External Quality Assessment should  be conducted (by an independent assessor);  
3) The resource limitations of the OIO shall be discussed with the new  Director -General; 
and 
4) The effectiveness of risk management processes at the WTO should be evaluated once 
the Governance and Risk Management Officer had been appointed . 
4.15.   The OIO is committed to provide high quality professional services to its stakeholders . 
Therefore, the OIO will continue its efforts to implement the above -mentioned areas of improvement, 
to achieve full compliance with the Code of Ethics and IIA Standards  and to closely monitor the 
relevance, efficiency and effectiveness  of its activities . 
 
4.3  Conduct administrative  investigations  
4.16.   The OIO is the exclusive entity at the WTO responsible for investigating allegations of 
violations  of any WTO norm applicable to s taff members, irrespective of the nature of their contracts, 
and for transmitting to t he Director -General7 the results of such investigations.  
4.17.   Between Ju ly 2020 and May 2021 , the OIO was contacted 12 times  for potential allegations 
of misconduct ('' intakes ''). The OIO conducted a detailed analys is of each of these intakes8. 
Whenever the intakes were related to workplace issues (e.g. conditions of employment, relations 
with supervisors or colleagues or performance management) and not to misconduct, the concerned 
persons were redirected to other channels available at the WTO for address ing such grievances (such 
as the intern al/external Mediators , the WTO Staff Counsellor , the Medical Service, the Staff Welfare 
Officer, the Staff Council  and/or HRD).  
4.18.   The intakes recorded by the OIO were classified into the following categories:  
1) Financial/ Procurement  fraud;  
2) Benefits and entitlements abuse ;  
3) Moral harassment and/or abuse of authority;  
4) Sexual h arassment;   
 
6 Administrative Memorandum No.974  – Office of Internal Oversight, OFFICE(15)/101, 
30 November  2015.  
7 Or, in the case of an alleged violation by the Director -General, a Deputy Director -General, or a 
member of the Office of  the Director -General, to the Chairs of the General Council and of the CBFA.  
8 Two (2) intakes are currently still in the preliminary assessment phase.  WT/BFA/W/557  
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  5) Retaliation ; and  
6) Other violations of the WTO Standards of Conduct.   
4.19.   The percentage of intake s per category of misconduct is provided in C hart 1 – Intakes 
recorded per category (July 2020 – May 2021).   
Chart 1 Intakes  recorded per category  (July 2020 – May 2021) 
 
 
4.20.   No cases of alleged financial and/or procurement fraud were reported to the OIO  between 
July 2020 and May 2021 . 
4.21.   The OIO was involved in five (5) investigations  between Ju ly 2020 and May 2021. A summary 
of these investigations is provided in Table 2 – Summary of investigation cases (Ju ly 2020 – 
May 2021). 
Table 2 Summary of investigation cases (July 2020 – May 2021) 
Type of allegation  Investigation 
opened  Potential 
loss 
(in CHF)  Status  Allegations 
substantiated  Sanction 
applied  
Breach of confidentiality  Yes 0 Closed  Yes Yes 
Retaliation  (1) 0 Closed  No - 
Conflict of interest  Yes 0 Closed  (2) - 
Benefits and Entitlements 
abuse  Yes 8'997  Closed  No - 
Moral harassment and abuse 
of authority  Yes 0 Ongoing  - - 
(1)  The investigation was conducted by an external investigator.  
(2) The investigation was closed following the resignation of the concerned staff member.  
 
WT/BFA/W/557  
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  4.22.   The investigations were conducted in accordance with the WTO procedure for administrative 
investigations9 and the Uniform Guidelines for Investigations .10  
4.23.   The Head of the OIO confirms that the Director -General, the Deputy Directors -General and 
the members of the Office of the Director -General (DGO) have not been the subject (s) of  the 
investigations.  
4.24.   Finally, the OIO participated in several internal disciplinary proceedings and, whenever 
requested, provided support to the Joint Disciplinary Board (J DB) and the Joint Appeals Board (JAB).  
4.4  Perform i nternal audits  
4.25.   The OIO's risk -based Internal Audit Plan for 20 20-2021 was presented to the CBFA in 
October  202011 and is detailed in Annex 2 - Internal Audit Plan for 20 20 - 2021. 
4.26.   Due to resource limitations , priorities identified by the new External Auditor , the 
implementation of new IT systems, the COVID -19 situation  and the fact that a dministrative 
investigations take precedence over its other official duties12, the OIO was unable to comple te all of 
the assignments initially included in the Internal Audit Plan .  
4.27.   The OIO continued m onitor ing the implementation of internal audit recommendations ( based 
on input collected from the concerned Divisions ), as well as of the recommendations made in the 
Trade -Related Technical Assistance external evaluation . The OIO reported separately to the CBFA 
on this matter, on 19 April 2021.13 
4.5  Provide support and advice to management and stakeholders  
4.28.   The OIO provided independent advice to the Director -General  (or Deputy Directors -General, 
while acting ad interim  jointly as Director -General) , senior m anagement  and staff members  to help 
them maintain and promote high standards of ethical behaviour , and fulfil their responsibilit ies 
toward the O rganisation and its Members. In this regard, t he OIO provid ed assurance support to 
several Divisions , whenever requested,  in order to improv e the effectiveness of governance, risk 
management and control processes , and to respond to  potential  ethical dilemmas .  
4.29.   The OIO also responded to ad hoc  requests and questions from Member s.   
4.30.   Finally, t he OIO provided support to  the previous and new External Auditor s (i.e. the German 
Supreme Federal Audit Authority ( Bundesrechnungshof)  and the French Cour des Comptes , 
respectively ), whenever requested. Frequent meetings were held with the External Auditor s, in order 
to share information and leverage the coherence and complementarity of both audit functions . The 
OIO considers that the collaboration and communication with the previous and new  External Auditor s 
has been positive and constructive.  
5  INTERNAL OVERSIGHT ACTIVITY FOR  2021-2022 
5.1.  The OIO's priorities for 20 21-2022 are mainly derived from an assessment of the major risks 
and mitigating controls at the WTO, IPPF requirements and input receiv ed from WTO Senior 
Management  and Members .  
 
 
9 Provisional Procedure for Administrative Investigations and Disciplinary Actions , OFFICE(14)/17, 
16 October  2014.  
10 For more information on the Uniform Guidelines for Investigations, see: http://www.conf -int-
investigators.org/?page_id=415 . 
11 WT/BFA/W/532 – Annual report on the activities of the Office of Internal Oversight 201 9-2020, 
25 September 2020.  
12 Provisional Procedure for Administrative Investigations and Disciplinary Actions , OFFICE(14)/17, 
16 October  2014.  par. 1.30.  
13 WT/BFA/W/5 45 – Status of internal audit rec ommendations ( March  2021), 24 March 2021.  WT/BFA/W/557  
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  5.2.  The OIO identified the following priorities  for 20 21-2022: 
 
1) The Internal Oversight Charter (i.e. Administrative Memorandum No.97414) will be 
reviewed  and submitted to the Director -General  and the CBFA for discussion and  
approval . 
2) In accordance with IIA Standard 1300  – Quality assurance and Improvement program , 
an External Quality Assessment of the OIO's Internal Audit function will  conducted by 
a qualified independent assessor . The results of this exercise will be communicated to 
the Director -General and the CBFA.  
3) The OIO will continue to conduct outreach activities , aiming at  promot ing an ethical 
culture at the WTO,  increas ing the (internal and external) visibility of the OIO and  
strengthen ing the mechanisms in place at the WTO for addressing grievances  and 
ethical dilemmas . The OIO will also continue  collaborat ing with HRD and the other 
Divisions for the promotion and maintenance of a culture of integrity and honesty at 
the WTO.  
4) The OIO will co nduct  the assignments included in the internal audit plan for 
2021-2022, detailed in Annex 3 - Internal Audit Plan for 20 21-2022. The internal audit 
plan may need to be adapted in response to changing risks and/or priorit ies at the 
WTO (and the arrival of the new Head of the OIO) . 
5) The OIO will continue conducting administrative investigations  and providing support 
in disciplinary proceedings, as needed.  
6) The OIO will also continue providing support and advice to management, staff and 
stakeholders on the eff ective discharge of their responsibilities  and will regularly assist 
the Divisions in the implementation of  internal audit recommendations.  Furthermore, 
the OIO will continue providing informal and formal advice on initiatives, policies, 
agreements or proj ect implementation.  
7) Finally, t he OIO will continue networking with other International Organizations with 
the objective of sharing good practices and keeping each other apprised of the latest 
professional developments in internal audit, ethics and investigations. The OIO will 
also maintain its active parti cipation in professional forums ( such as  Representatives 
of Internal Audit Services (RIAS) , Representatives of Investigative Services (RIS) and 
Ethics Network of Multilateral Organizations ( ENMO )).  
5.3.  The OIO will continue repor ting to the CBFA, every year, on the status of its  activities.  
 
14 Administrative Memorandum No.974  – Office of Internal Oversight, OFFICE(15)/101, 
30 November  2015.  WT/BFA/W/557  
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  ANNEX 1 – LIST OF ACRONYMS  
AM  Administrative Memorandum  
CBFA   Committee on Budget, Finance and Administration  
CHF  Swiss Franc (currency)  
CII  Conference of International Investigators  
COVID  Corona virus disease  
DGO  Director-General's Office  
ENMO   Ethics Network of Multilateral Organizations  
EQA  External Quality Assessment  
ERM  Enterprise Risk Management  
ERP  Enterprise Resource Planning (system ) 
HOIA   Heads of Internal Audit Services of International Organizations based in Europe  
HRD  Human Resources Division  
IIA  Institute of Internal Auditors  
IFRC  International Federation of Red Cross and Red Crescent  
ILOAT   Administrative Tribunal of the International Labour Organization  
IPPF  International Profess ional Practices Framework  
JAB  Joint Appeals Board  
JDB  Joint Disciplinary Board  
N/A  Not applicable  
OIO  Office of Internal Oversight  
QAIP  Quality Assurance and Improvement Program  
QSA  Quality Sel f-Assessment  
RIAS  Representatives of Internal Audit Services  
RIS  Representatives of Investigations Services  
TRTA  Trade -Related Technical Assistance  
UN  United Nations  
WIPO   World Intellectual Property Organization  
WTO  World Trade Organization  
 
  WT/BFA/W/557  
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ANNEX 2 – INTERNAL AUDIT PLAN FOR 20 20 – 2021 
Audit subjec t Source  Audit Scope/Objective  2020  2021 
Policies on gifts, 
gratuities and outside 
activities  Risk Assessment  
 Assessment of policies related to:  
- Acceptance of gifts, gratuities and/or 
other favours received by staff 
members from suppliers  or outside 
parties;  
- Remunerated outside activities of staff 
members;  
- Manag ement of the Staff Assistance 
Fund;  and 
- Post-employment obligations.  x   
Crisis management 
and contingency 
planning  Risk Assessment  
 Lessons learnt from the COVID -19 crisis 
management ;  
Analysis of the WTO's d isaster 
preparedness , contingency planning and 
operational resilience.  x  
Procurement  Risk Assessment, 
Management 
request  Assessment of processes and internal 
controls ;  
Compliance with the  Procurement 
Manual and  Chapter IX of the revised 
Financial Rules.    x 
Education Grant  Management 
Request  Review of the economy, efficiency and 
effective ness of processes and controls ; 
Assess ment of  compliance with Staff 
Regulations and Rules .   x 
Access rights in 
Oracle E -Business 
Suite   
 Risk Assessment,  
IT Security audit  Review of security processes and 
measures ;  
Analysis of access rights  / permissions 
and segregation of duties in Oracle  
E-Business Suite (ERP).  x  
Risk Management  IIA Standards  Analysis of WTO's Enterprise Risk 
Management (ERM)   (1) 
Follow -up of 
recommendations 
made in the 
Trade -Related 
Technical Assistance 
external evaluation 
report  Management 
Request  Independent review of the 
implementation of the recommendations 
stated in the WTO TRTA external 
evaluation report.  
 x  
Follow -up of audit 
recommendations  IIA Standards  Periodic review of the implementation of 
internal audit recommendations.  x x 
Ad hoc audits, if any  - To be determined  - - 
(1)  Subject to the appointment of a Governance and Risk Management Officer and the elaboration of  
WTO's Enterprise Risk Management system.  
 
  WT/BFA/W/557  
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  ANNEX 3 – INTERNAL AUDIT PLAN FOR 2021 – 2022  
Audit subject  Source  Audit Scope/Objective  2021 2022 
Policies on gifts, 
gratuities  and outside 
activities  Risk Assessment  
 Assessment of policies related to:  
- Acceptance of gifts, gratuities and/or 
other favours received by staff 
members from suppliers  or outside 
parties;  
- Remunerated outside activities of staff  
members;  
- Manag ement of the Staff Assistance 
Fund; and  
- Post-employment obligations.  x   
Learning and 
Development  Risk Assessment  - Value -for-money analysis of HRD 
Learning and Career Development 
activities.  x  
Procurement  Risk Assessment, 
Management 
request  Assessment of processes and internal 
controls ;  
Compliance with the  Procurement 
Manual and Chapter IX of the revised 
Financial Rules.    x 
Education Grant  Management 
Request  Review of the economy, efficiency and 
effective ness of processes and controls;  
Assessment of compliance with Staff 
Regulations and Rules .   x 
Access rights in 
Oracle E -Business 
Suite   
 Risk Assessment,  
IT Security audit  Review of security processes and 
measures ;  
Analysis of access rights  / permissions 
and segregation of duties in Oracle  
E-Business Suite ( ERP).  (1)  
Risk Management  IIA Standards  Analysis of WTO's Enterprise Risk 
Management (ERM)   (2) 
Follow -up of audit 
recommendations  IIA Standards  Periodic review of the implementation of 
internal audit recommendations.  x x 
Ad hoc audits, if any  - To be determined  - - 
(1)  Subject to finalization o f the WISE (HR D software) project  and the interface s with Oracle E -Business . 
(2) Subject to the appointment of the Governance and Risk Management Officer and the elaboration of 
WTO's Enterprise Risk Management system.  
 
 
    
  WT/BFA/W/557  
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ANNEX 4 – INTERNAL AUDIT FUNCTION – QUALITY SELF -ASSESSMENT  
Last update:  May 2021  
Evaluators: Benoit de Schoutheete and Nathalie Iniguez  
GC = Generally Conforms, PC = Partially Conforms, DNC = Does Not Conform , N/A = Not Applicable  
 
IIA-Standards  Self-Assessment  
IIA-Std Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
1000 The purpose, authority, and responsibility of the internal audit 
activity must be formally defined in an internal audit charter.  
 
Interpretation:  
The internal audit charter is a formal document that defines the 
internal audit activity's purpose, authority, and responsibility. 
The internal audit charter establishes the internal audit 
activity's position within the organization, including the nature 
of the chief audit executive 's functional reporting relationship 
with the board; authorizes access to records, personnel, and 
physical properties relevant to the performance of 
engagements; and defines the scope of internal audit activities.  x     The purpose, authority, and responsibility of the Office of Internal 
Oversight (OIO) are  defined in Administrative Memorandum No.974 - 
Office of Internal Oversight  (OFFICE(15)/101).  
 
The Memorandum establishes the internal audit activity's position 
within the organization, including the nature of the functional reporting 
relationship between the Head of OIO and the Director -General and 
the CBFA; authorizes access to records, personnel,  and physical 
properties relevant to the performance of internal audit engagements; 
and defines the scope of internal audit activities.  Administrative 
Memorandum No.974 
will be revised.  
1000 The internal audit charter must be consistent with the Definition 
of Internal Auditing, the Code of Ethics, and the IIA -Standards.      x   Administrative Memorandum No.974 - Office of Internal Oversight  
(OFFICE(15)/101) stipulates that the OIO staff membe rs govern 
themselves by adherence to all relevant standards and best practices 
which are accepted and applied by other international organizations 
comparable to the WTO and abide by other relevant professional 
standards (i.e. the standards promulgated by t he Institute of Internal 
Auditors - IIA). 
 
Nonetheless, the Administrative Memorandum No.974 will need to be 
updated in order to include the definition of Internal Auditing and 
reference the Code of Ethics and the IIA -Standards, as promulgated by 
the IIA.  Administrative 
Memorandum No.974 
will be revised.  
1000 The internal audit charter must be periodically reviewed by the 
chief audit executive regarding its timeliness and adequacy.             x   Administrative Memorandum No.974 - Office of Internal Oversight  
(OFFICE(15)/101) was issued on 30 November 2015 and needs to be 
reviewed.  
 
This Quality Assessment exercise one of the steps taken to identify the 
necessary revisions to be brought to the Audi t Charter.  Administrative 
Memorandum No.974 
will be revised.  
1000 The internal audit charter must be approved by the board or 
audit committee.  
 
Interpretation:  
Final approval of the internal audit charter resides with the 
board.      x The current audit charter, issued in November 2015, was not 
submitted to the CBFA for approval.  
 
Once revised, the (new) OIO Charter will be submitted to the 
Committee on Budget, Finance and Administration (CBFA) for final 
approval.  Administrative 
Memoran dum No.974 
will be revised and 
submitted to the 
CBFA for approval.    
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1000 The internal audit charter must be acknowledged by senior 
management.  x     Administrative Memorandum No.974 - Office of Internal Oversight  
(OFFICE(15)/101) was approved by the Director -General and 
acknowledged by Senior Management.  
 
Note: The revised OIO Charter will be submitted to the Joint Advisory 
Committee (JAC) and the Director -General for acknowledgment.  Administrative 
Memorandum No.9 74 
will be revised and 
submitted to the 
Director -General for 
acknowledgment.  
1010 The mandatory nature of the Core Principles for the Professional 
Practice of Internal Auditing, the Code of Ethics, the Standards, 
and the Definition of Internal Auditing must be recognized in the 
internal audit charter.    x   Administrative Memorandum No.974 - Office of Internal Oversight  
(OFFICE(15)/101) stipulates that the OIO staff members govern 
themselves by adherence to all relevant standards and best practices 
which are accepted and applied by other international organizations 
comparable to the WTO and abide by other relevant profes sional 
standards (i.e. the standards promulgated by the Institute of Internal 
Auditors - IIA). 
 
However, the document does not specifically mention the mandatory 
nature of the Core Principles for the Professional Practice of Internal 
Auditing, the Code of Ethics, the Standards, and the Definition of 
Internal Auditing promulgated by the IIA.  
The revised OIO Charter will include such mentions.  Administrative 
Memorandum No.974 
will be revised.  
1010 The chief audit executive should discuss the Definition of 
Internal Auditing, the Code of Ethics, and the IIA -Standards 
with senior management and the board.    x   The definition of Internal Auditing, the Code of Ethics, and the 
IIA-Standards will be discussed with the Director -General and the 
CBFA in the framework of the approval of the revised OIO Charter.  Administrative 
Memorandum No.974 
will be revised and 
submitted to the 
Director -General and 
the CBFA for 
approval.  
1100 The internal audit activity must be independent.  
 
Interpretation:  
Independence is the freedom from conditions that threaten the 
ability of the internal audit activity to carry out internal audit 
responsibilities in an unbiased manner. To achieve the degree of 
independence necessary to effectively carry out the 
responsibilities of the in ternal audit activity, the chief audit 
executive has direct and unrestricted access to senior 
management and the board. This can be achieved through a 
dual-reporting relationship. Threats to independence must be 
managed at the individual auditor, engagemen t, functional, and 
organizational levels.  x     The Head of the OIO and other OIO staff members are functionally and 
operationally independent from WTO's Secretariat and from WTO 
Members in the conduct of their duties (Administrative Memorandum 
No.974, Section 3.1).  
 
The Head of the OIO reports directl y to the Director -General and to the 
CBFA (Administrative Memorandum No.974, Section 7). He/she has 
direct and unrestricted access to the Director -General, senior 
management and the Chairs of the General Council and the CBFA 
(Administrative Memorandum No.9 74, Section 8).  
 
An annual report on the activities of the OIO is presented, every year, 
to the Director -General, the External auditors and the CBFA. It its 
annual report, the Head of the OIO confirms its independence and 
certifies that no circumstances h ave affected, in fact or appearance, 
the independence of the OIO, or impeded its ability to fulfil its functions 
and responsibilities in an unbiased, objective and independent manner 
since 2016. Neither the Director General nor any other WTO senior 
officia l have negatively interfered with the work of the OIO.      
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1100 The internal auditors must be objective in performing their 
work.  
 
Interpretation:  
Objectivity is an unbiased mental attitude that allows internal 
auditors to perform engagements in such a mann er that they 
believe in their work product and that no quality compromises 
are made. Objectivity requires that internal auditors do not 
subordinate their judgment on audit matters to others. Threats 
to objectivity must be managed at the individual auditor,  
engagement, functional, and organizational levels.  x     Administrative Memorandum No.974 states that all Internal Oversight 
activities shall remain free of influence by any element in the 
Organization, including for matters of audit selection, scope, 
procedures, frequency, timing or report content, to permit the 
rendering of impartial and unbiased judgement essential to the proper 
conduct of audits.  
 
The OIO has performed its work in an objective manner. The Head of 
the OIO certified to the CBFA , each year since 2017, that no 
circumstances have affected, in fact or appearance, the independence 
of the OIO or impeded its ability to effectively fulfil its functions and 
responsibilities in an unbiased, objective and independent manner .   
1110 The ch ief audit executive must report to a level within the 
organization that allows the internal audit activity to fulfil its 
responsibilities.  x     The OIO reports to the highest level of the Organisation (i.e. the 
Director -General) and to the CBFA. The Head of the OIO reports 
administratively to the Director -General and functionally to the CBFA.  
 
The risk -based plans, budgets and resources of the OIO are submitted 
to the Director -General for approval and to the CBFA for information.  
 
Also, as stated in A dministrative Memorandum No.974, the Head of the 
OIO is selected through an external vacancy notice and appointed by 
the Director -General, after consultation with the Chairs of the General 
Council and of the CBFA. His/her remuneration is established accord ing 
to the WTO official salary scale (Grade 10).    
1110 The chief audit executive must confirm to the board, at least 
annually, the organizational independence of the internal audit 
activity.  
 
Interpretation:  
The internal audit activity must be free from interference in 
determining the scope of internal auditing, performing work, 
and communicating results. The chief audit executive must 
disclose such interference to the board and discuss the 
implications.  x     The Head of the OIO confirmed to the CBFA, every year since 2017, 
that no circumstances have affected, in fact or appearance, the 
independence of the OIO or impeded its ability to effectively fulfil its 
functions and responsibilities in an unbiased, object ive and 
independent manner. Neither the Director General nor any other WTO 
staff member have tried to influence or otherwise interfered with the 
work of the OIO.    
1111 The chief audit executive must communicate directly with the 
board.  x     As stated i n Administrative Memorandum No.974 par. 35, the OIO 
shall report annually to the CBFA. The Head of the OIO reported 
directly to the CBFA at least twice per year since 2017.  
The Head of the OIO had direct and unrestricted access to the CBFA 
and its Chair.      
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1111 The chief audit executive must interact directly with the board.  x     As stated in Administrative Memorandum No.974 par. 35, the OIO 
shall report annually to the CBFA. The Head of the OIO reported 
directly to the CBFA at least twice per year since 2017.  
The Head of the OIO had direct and unrestricted access to the CBFA 
and its Chair.  
 
Additionally, the Head of the OIO had, whenever possible and deemed 
necessary (at least once per year) face -to-face meetings with the 
Chair of the CBFA.  
 
Finally , the OIO often interacted directly with several Members of the 
CBFA, upon their request.    
1112 Where the chief audit executive has or is expected to have roles 
and/or responsibilities that fall outside of internal auditing, 
safeguards must be in place to limit impairments to 
independence or objectivity.  
 
Interpretation:  
The chief audit executive may be asked to take on additional 
roles and responsibilities outside of internal auditing, such as 
responsibility for compliance or risk management activ ities. 
These roles and responsibilities may impair, or appear to 
impair, the organizational independence of the internal audit 
activity or the individual objectivity of the internal auditor. 
Safeguards are those oversight activities, often undertaken by 
the board, to address these potential impairments, and may 
include such activities as periodically evaluating reporting lines 
and responsibilities and developing alternative processes to 
obtain assurance related to the areas of additional 
responsibility.  x     As stated in Administrative Memorandum No.974 par.10, the Head of 
the OIO and other OIO staff must, at all times, ensure that their 
conduct is compatible with the objectivity and independence required 
by their functions.  
 
Furthermore, the OIO has the au thority,  ex officio  or upon request, to 
initiate, carry out and prepare reports on investigations, audits, 
inspections and other evaluations, as it deems necessary to fulfil its 
responsibilities with regard to its oversight functions (par. 22).  
 
These act ivities did not impair, or appear to impair, the organizational 
independence of the internal audit activity or the individual objectivity 
of the Head of the OIO.  
 
The Head of the OIO did not have other roles or responsibilities at the 
WTO outside the respo nsibilities given to the Internal Oversight Office 
(i.e. Internal Audit, Evaluations, Inspections, Investigations and 
Ethics).    
1120 Internal auditors must have an impartial, unbiased attitude and 
avoid any conflict of interest.  
 
Interpretation:  
Conflict  of interest is a situation in which an internal auditor, 
who is in a position of trust, has a competing professional or 
personal interest. Such competing interests can make it difficult 
to fulfil his or her duties impartially. A conflict of interest exist s 
even if no unethical or improper act results. A conflict of 
interest can create an appearance of impropriety that can 
undermine confidence in the internal auditor, the internal audit 
activity, and the profession. A conflict of interest could impair 
an individual's ability to perform his or her duties and 
responsibilities objectively.  x     As stated in WTO Staff Regulation 1.5, staff members shall conduct 
themselves at all times in an appropriate manner and shall avoid any 
action which may adversely reflect on their status as international civil 
servants, or on the integrity, independence and impartiality which are 
required by that status.  
 
Furthermore, according to Administrative memorandum No.974 
par. 38,  to ensure its impartiality and credibility, the OIO may not 
perform any operational duty or be involved in any activity which may, 
pursuant to this Administrative Memorandum, be subject to any form 
of evaluation or audit, or which has been evaluated or audited by the 
OIO. 
 
Finally, as stated in Administrative Memorandum No.974 par.8, the 
staff members of the OIO, in the exercise of their duties, may neither     
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seek nor accept any instruction from any person or entity outside the 
OIO, whether this person or entity is within or outside the WTO.  
 
Since the establishment of the OIO (2016), its staff members did not 
conduct activities which could  be in conflict ( (or be perceived to be in 
conflict) with their professional obligations and/or could impair their 
ability to perform their duties objectively.  
1130 If independence or objectivity is impaired in fact or appearance, 
the details of the impairment must be disclosed to appropriate 
parties. The nature of the disclosure is determined relative to 
the impairment.  
 
Interpretati on: 
Impairment to organizational independence and individual 
objectivity may include, but is not limited to, personal conflict of 
interest, scope limitations, restrictions on access to records, 
personnel, and properties, and resource limitations, such as 
funding.  
The determination of appropriate parties to which the details of 
an impairment to independence or objectivity must be disclosed 
is dependent upon the expectations of the internal audit 
activity 's and the chief audit executive 's responsibilities to 
senior management and the board as described in the internal 
audit charter, as well as the nature of the impairment.  x     The Head of the OIO confirmed to the CBFA, each year since 2017, 
that no circumstances have affected, in fact or appearance, the 
independence of the OIO or impeded its ability to effectively fulfil its 
functions and responsibilities in an unbiased, objective and 
independent manner. Neither the Director General nor any other WTO 
staff member have tried to influence or  otherwise interfered with the 
work of the OIO  
 
The Head of the OIO did not identify any instance which may have 
impaired the independence and/or objectivity of the OIO.    
1130.A1  Assurance: Internal auditors must refrain from assessing 
specific operation s for which they were previously responsible. 
Objectivity is presumed to be impaired if an internal auditor 
provides assurance services for an activity for which the internal 
auditor had responsibility within the previous year.  x     Since September 2016 (i.e. the appointment of the current Head of the 
OIO), the OIO did not audit any area or operation for which one or 
several of its staff members had previous responsibilities. As a matter 
of fact, all the Professional staff members of the OI O have been hired 
externally and never had responsibilities in other areas or operations 
within the WTO.    
1130.A2  Assurance: Assurance engagements for functions over which 
the chief audit executive has responsibility must be overseen by 
a party outside t he internal audit activity.  x     Since September 2016 (i.e. the appointment of the current Head of the 
OIO), the OIO did not conduct assurance engagements for functions 
over which the Head of the OIO (or any other OIO staff member) had 
responsibility.    
1130.A3  Assurance: The internal audit activity may provide assurance 
services where it had previously performed consulting services, 
provided the nature of the consulting did not impair objectivity 
and provided individual objectivity is managed when assigning 
resources to the engagement.  x     Since September 2016 (i.e. the appointment of the current Head of the 
OIO), the OIO did not conduct assurance engagements for functions 
over which the Head of the OIO (or any other OIO staff member)  had 
responsibility.    
1210 Internal auditors must possess the knowledge, skills, and other 
competencies needed to perform their individual responsibilities  
 
Interpretation:  
Proficiency is a collective term that refers to the knowledge, 
skills, and other competencies required of internal auditors to x     The Head of the OIO is a Certified Internal Auditor (CIA) and 
Evaluator : He has also extensive experience in the areas of Internal 
Audit, Investigations, Risk Management and Evaluations. He is an 
active member of the HOIA, RIAS and RIS (professional groups where 
good practices, trends and emerging issues related to Internal audit 
and investigations in International Organisations are d iscussed).      
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effectively carry out their professional responsibilities. It 
encompasses consideration of current activities, trends, and 
emergi ng issues, to enable relevant advice and 
recommendations. Internal auditors are encouraged to 
demonstrate their proficiency by obtaining appropriate 
professional certifications and qualifications, such as the 
Certified Internal Auditor designation and othe r designations 
offered by The Institute of Internal Auditors and other 
appropriate professional organizations.   
The OIO has also an Investigator, who may be called to participate in 
internal audits. The incumbent is currently completing the CIA 
certification (completion expected in 2022).  
 
The knowledge, skills, and competencies of the OIO staff members are 
deemed adequate to perform their responsibilities. If deemed 
necessary, and when internal expertise in not available, the OIO has 
the possibility to hire external consultants or experts (e.g.: forensics 
analyst, etc.) or use the services of other Depar tments (e.g.: cyber 
security officer).  
1210 The internal audit activity collectively must possess or obtain 
the knowledge, skills, and other competencies needed to 
perform its responsibilities.  x     An Investigator (G7 - Fixed Term) joined the OIO in May 2020, to 
reinforce the OIO team. The incumbent has accepted to complete the 
CIA certification.  
 
The collective knowledge, skills, and competencies of the OIO team 
were deemed sufficient to conduct the engagements included in the 
internal audit plans. I f deemed necessary, and when internal expertise 
in not available, the OIO has the possibility to hire external consultants 
or experts (e.g.: forensics analyst, etc.) or use the services of other 
Departments (e.g.: cyber security officer).    
1210.A1  Assura nce: The chief audit executive must obtain competent 
advice and assistance if the internal auditors lack the 
knowledge, skills, or other competencies needed to perform all 
or part of the engagement.  x     Whenever deemed necessary to fulfil its responsibilities, the OIO 
obtained advice and assistance from other Divisions/Services (e.g.: IT 
Security Officer) or from external parties (e.g.: Internal Oversight 
Services of other Geneva -based International Organizations).  The 
Head of the OIO is also a member of the HOIA, RIAS and RIS forums, 
which have regularly been used for obtaining expert advice and good 
practices on several topics.    
1210.A2  Assurance: Internal auditors must have sufficient knowledge to 
evaluate the risk of fraud and the manner in which it is 
managed by the organization, but are not expected to have the 
expertise of a person whose primary responsibility is detecting 
and investigating fraud.  x     The Head of the OIO and the /Investigator have extensive experience 
in conducting administrative investigations at the WTO and in 
assessing and evaluating fraud risk.    
1210.A3  Assurance: Internal auditors must have sufficient knowledge of 
key information technology risks and controls and available 
technology -based audit tec hniques to perform their assigned 
work. However, not all internal auditors are expected to have 
the expertise of an internal auditor whose primary responsibility 
is information technology auditing.  x     The Head of the OIO is a certified SAP professional and has experience 
in implementing Enterprise Resource Planning (ERP) systems.  
 
The staff members of the OIO have sufficient knowledge of the 
information technology systems involved in the audits conducted since 
September 2016. Whenever deemed necessary ( e.g.: when dealing 
with highly specialised information technology), the OIO has used the 
services of other Divisions or external parties.      
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1220 Internal auditors must apply the care and skill expected of a 
reasonably prudent and competent internal auditor. Due 
professional care does not imply infallibility.  x     The OIO staff members strived to always apply due professional care 
and prudency when conducting their assignments.  
No imprudence or lack of due care have been identified by - or 
reported to - the OIO.    
1220.A1  Assurance: Internal auditors must exercise due professional 
care by considering the:  
-Extent of work needed to achieve the engagement 's objectives.  
-Relative complexity, materiality, or significance of matters to 
which assurance procedures are applied.  
-Adequacy and effectiveness of governance, risk management, 
and control processes.  
-Probability of significant errors, fraud, or noncompliance.  
-Cost of assurance in relation to potential benefits.  x     When initiat ing an internal audit, the OIO systematically prepares a 
detailed audit engagement plan, which takes into consideration the 
extent of work needed to achieve the engagement 's objectives; the 
relative complexity, materiality, or significance of matters to wh ich 
assurance procedures are applied; the adequacy and effectiveness of 
governance, risk management, and control processes; the probability 
of significant errors, fraud, or noncompliance; and the cost of 
assurance in relation to potential benefits.    
1220.A2  Assurance: In exercising due professional care internal auditors 
must consider the use of technology -based audit and other data 
analysis techniques.  x     The use of technology -based audit and other data analysis techniques 
is considered when draft ing the engagement plan of each audit 
exercise.  
 
The OIO is also interested in the current opportunities offered by 
emerging technologies, such as Artificial Intelligence. A discussion 
group, composed by Geneva -Based International Organizations, has 
been created to discuss how to take advantage of AI for conducting 
internal audits.    
1220.A3  Assurance: Internal auditors must be alert to the significant 
risks that might affect objectives, operations, or resources. 
However, assurance procedures alone, even when performed 
with due professional care, do not guarantee that all significant 
risks will be identified.  x     When preparing the audit engagement plan, the OIO systematically 
assesses the risks that might affect the objectives of the engagem ent.    
1230 Internal auditors must enhance their knowledge, skills, and 
other competencies through continuing professional 
development.  x     The members of the OIO continuously enhance their knowledge and 
skills through participation to trainings and workshops. They 
participate to several trainings per year, in the areas of Internal Audit, 
Investigations, and Ethics.  
 
They also actively participate to several professional forums such as:  
- Heads of Internal Audit (HOIA),  
- Representative s of Internal Audit Services (RIAS),  
- Conference of International Investigators (CII),   
- Ethics Network of Multilateral Organizations (ENMO).  
 
The Head of the OIO complied with the Continuous Professional 
Education (CPE) required by the IIA Certificati on. 
  
The OIO Assistant was also offered the possibility to follow several 
trainings (e.g.: MS -Word, MS -Access, Oracle, and English).      
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1300 The chief audit executive must develop and maintains a quality 
assurance and improvement program.   
 
Interpretatio n: 
A quality assurance and improvement program is designed to 
enable an evaluation of the internal audit activity 's conformance 
with the Standards and an evaluation of whether internal 
auditors apply the Code of Ethics. The program also assesses 
the effici ency and effectiveness of the internal audit activity and 
identifies opportunities for improvement. The chief audit 
executive should encourage board oversight in the quality 
assurance and improvement program.                x     The OIO has developed this Quality Self -Assessment tool, to evaluate 
conformity of the OIO's activity with IIA and established ethics 
standards.  
 
This tool was used for the first time in 2018, in order to assess 
progress in the efficiency and effectiveness of the inte rnal audit 
activity and to identify opportunities for improvement. The results of 
this assessment were shared with the Director -General and the CBFA.  
 
Furthermore, the OIO has developed an Audit Effectiveness 
Questionnaire, submitted to auditees after each  internal audit 
engagement, to gauge the performance of the OIO during the 
concerned engagement.    
1300 The quality assurance and improvement program must include 
all aspects of internal audit activity.  x     This Quality Self -Assessment tool includes all aspects of the internal 
audit activity.    
1310 The quality assurance and improvement program must include 
both internal and external assessments.    x   The External Auditor (Federal Court of Auditors of Germany) conducted 
a performance audit of the Internal Control system at the WTO in 2016 
(Report of the External Auditor to the CBFA, WT/BFA/W/393, 
10 June 2016).  
 
The OIO was established at the WTO in November 2015, and the Head 
of Office was appointed in September 2016. The quality assurance and 
improvement program currently includes only internal self -
assessments. However, pursuant to IIA standards, an external 
assessment should be conducted within 5 years of the appointment of 
the Head of the OIO. This external quality asse ssment is expected to 
be done in 2021 -2022.  An external quality 
assessment of the 
OIO should be 
conducted in 
2021-2022.  
1311 Internal assessments must include ongoing monitoring of the 
performance of the internal audit activity.  
 
Interpretation:  
Ongoing m onitoring is an integral part of the day -to-day 
supervision, review, and measurement of the internal audit 
activity. Ongoing monitoring is incorporated into the routine 
policies and practices used to manage the internal audit activity 
and uses processes, t ools, and information considered 
necessary to evaluate conformance with the Code of Ethics and 
the Standards.  x     The OIO has developed this Quality Self -Assessment tool, to evaluate 
conformity of the OIO's activity with IIA and established ethics 
standards. This tool has been updated in 2018 and 2020, in order to 
assess progress in the efficiency and effectiveness of the internal audit 
activity and to iden tify opportunities for improvement.  
 
Furthermore, the OIO has developed an Audit Effectiveness 
Questionnaire, submitted to auditees after each individual internal 
audit, to gauge the performance of the OIO during the concerned 
engagement.      
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1311 Internal  assessments must include periodic self -assessments or 
assessments by other persons within the organization with 
sufficient knowledge of internal audit practices.  
 
Interpretation:  
Periodic assessments are conducted to evaluate conformance 
with the Code of Ethics and the Standards.  
Sufficient knowledge of internal audit practices requires at least 
an understanding of all elements of the International 
Professional Practices Framework.  x     The OIO has developed this Quality Self -Assessment tool, to evaluate 
conformity of OIO's activity with IIA and the Code of Ethics. This tool 
has been used for the first time in 2018 and was updated in 2020. This 
tool will be used as reference for the external quality assessment 
foreseen for 2021 -2022.  
 
Also, the External Auditor (Federal Court of Auditors of Germany) 
conducted a performance audit of the Internal Control system at the 
WTO in 2016 (Report of the External Auditor to the CBFA, 
WT/BFA/W/393, 10 June 2016).    
1312 External assessment s must be conducted at least once every 
five years by a qualified, independent assessor or assessment 
team from outside the organization.    x   The OIO was established at the WTO in November 2015, and the Head 
of Office was appointed in September 2016. Pursuant to IIA standards, 
an external assessment should be conducted within 5 years of the 
appointment of the Head of the OIO.  
 
The External Qual ity Assessment of the OIO is foreseen for 2021 -2022.  
 
The External Auditor (Federal Court of Auditors of Germany) conducted 
a performance audit of the Internal Control system at the WTO in 2016 
(Report of the External Auditor to the CBFA, WT/BFA/W/393, 
10 June 2016) .  The External Quality 
Assessment of the 
OIO should be done 
in 2021 -2022.  
1312 The chief audit executive must discuss with the board the form 
and frequency of external assessments.    x   The OIO was established at the WTO in November 2015, and the Head 
of Office was appointed in September 2016. Pursuant to IIA standards, 
an external assessment should be conducted within 5  years of the 
appointment of the Head of the OIO.  
 
The External Quality Assessment of the OIO is foreseen for 2021 -2022.  
 
The form and frequency of the external assessments will be discussed 
with the CBFA in due time.  The External Quality 
Assessment of the 
OIO should be done 
in 2021 -2022.  
1312 The chief audit executive must discuss with the board the 
qualifications and inde pendence of the external assessor or 
assessment team, including any potential conflict of interest.  
 
Interpretation:  
A qualified assessor or assessment team demonstrates 
competence in two areas: the professional practice of internal 
auditing and the extern al assessment process. Competence can 
be demonstrated through a mixture of experience and 
theoretical learning. Experience gained in organizations of 
similar size, complexity, sector or industry, and technical issues 
is more valuable than less relevant exp erience. In the case of 
an assessment team, not all members of the team need to have 
all the competencies; it is the team as a whole that is qualified. 
The chief audit executive uses professional judgment when   x   The OIO was established at the WTO in November 2015, and the Head 
of Office was appointed in September 2016. Pursuant to IIA standards, 
an external assessment will be conducted within 5 years of the 
appointment of the Head of the OIO.  
 
The External Qualit y Assessment of the OIO is foreseen for 2021 -2022.  
 
The qualifications and independence of the external assessor or 
assessment team will be discussed with the CBFA in due time  
 
The results of the External Quality Assessment (to be conducted in 
2021-2022) w ill be comm unicated to the Director -General and to the 
CBFA.  The External Quality 
Assessment of the 
OIO should be done 
in 2021 -2022.    
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assessing whether an assessor or assessment te am 
demonstrates sufficient competence to be qualified.  
An independent assessor or assessment team means not having 
either an actual or a perceived conflict of interest and not being 
a part of, or under the control of, the organization to which the 
internal  audit activity belongs. The chief audit executive should 
encourage board oversight in the external assessment to reduce 
perceived or potential conflicts of interest.  
1320 The chief audit executive must communicate the results of the 
quality assurance and improvement program to senior 
management and the board. Disclosure should include:  
- The scope and frequency of both the internal and external 
assessments.  
- The qualifications and independence of the assessor(s) or 
assessment team, including potential conflicts of interest.  
- Conclusions  of assessors.  
- Corrective action plans.  x     The OIO communicated to - and discussed with - the Director -
General's Office (DGO) and the CBFA the results of the 2018 Quality 
Self-Assessment.  
 
The results of the 2020 -2021 Quality Self -Assessment will be 
presented to the Director -General and the CBFA in 2021.    
1321 Indicating that the internal audit activity conforms with the 
International Standards for the Professional Practice of Internal 
Auditing is appropriate only if supported by  the results of the 
quality assurance and improvement program.  
 
Interpretation:  
The internal audit activity conforms with the Code of Ethics and 
the Standards when it achieves the outcomes described therein. 
The results of the quality assurance and improve ment program 
include the results of both internal and external assessments. 
All internal audit activities will have the results of internal 
assessments. Internal audit activities in existence for at least 
five years will also have the results of external a ssessments.  N/
A     This Standard will be evaluated  after completion of the External 
Quality Assessment foreseen in 2021.  
 
In the meantime, the OIO has indicated that it strives to conform with 
the International Standards for the Professional Practice of Internal 
Auditing (the OIO did not indicate that the internal audit activity 
conforms with the Standards).    
1322 When non -conformance with the Code of Ethics or the 
Standards impacts the overall scope or operation of the internal 
audit activi ty, the chief audit executive must disclose the non -
conformance and the impact to senior management and the 
board  x     Non-conformance with specific Standards was disclosed to the 
Director -General and the CBFA in 2018 (and will be done in 2021).  
 
The obse rved non -conformance with the Standards did not impact the 
overall scope, quality or operation of the OIO's activities.    
2000 The chief audit executive must ensure that internal audit 
resources are appropriate, sufficient, and effectively deployed to 
achieve the approved plan.  
 
Interpretation:  
The internal audit activity is effectively managed when:  
- It achieves the purpose and responsibility included in the 
internal audit charter.  
- It conforms with the Standards.  
- Its individual members  conform with the Code of Ethics and   x   Internal audit resources have been appropriate but not sufficient since 
2016.  
 
The Head of the OIO reported on r esources to the Director -General 
and to the CBFA every year since 2017 and highlighted the OIO's 
resource limitations.  
 
Since May 2020, the OIO has been reinforced with the arrival of an 
Investigator who is expected to also provide support for internal 
audits.  The OIO is currently 
analysing se veral 
options to free up 
additional resources 
for internal audits 
and investigations.  
 
The Head of the OIO 
will discuss about 
resource limitations   
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the Standards.  
- It considers trends and emerging issues that could impact the 
organization.  
 
The internal audit activity adds value to the organization and its 
stakeholders when it considers strategies, objectives, and  risks; 
strives to offer ways to enhance governance, risk management, 
and control processes; and objectively provides relevant 
assurance.   
Pursuant to OFFICE(15)/101, the OIO must give priority to 
administrative investigations. Given the workload in investigations, the 
OIO has not been in a position to fully complete its yearly internal 
audit plans.   with the recently 
appointed Director -
General.  
 
Pursuant to 
Admini strative 
Memorandum 974, 
the new Head of the  
OIO will also discuss 
resources and budget 
requirements with the 
Director -General.   
2010 The chief audit executive must establish a risk -based plan to 
determine the priorities of the internal audit activity, consistent 
with the organization 's goals.  
 
Interpretation:  
To develop the risk -based plan, the chief audit executive 
consults with senior management and the board and obtains an 
understanding of the organization 's strategies, key business 
objectives, associated risks, and risk management pr ocesses. 
The chief audit executive must review and adjust the plan, as 
necessary, in response to changes in the organization 's 
business, risks, operations, programs, systems, and controls.  x     The Head of the OIO established risk -based internal audit pla ns 
detailing the priorities of the internal audit activity for the next two 
years. The risk -based audit plans were updated every year since 2017 
and were adjusted whenever prio rities had changed (in response to 
changes in the WTO's risks).  
 
To develop the risk -based plans, the OIO consulted the Director -
General and selected Senior Managers/Directors. The WTO Risk 
Register was also used as reference for developing the OIO risk -based 
plan. 
 
The OIO risk -based plans were communicated to the Directo r-General 
and to the CBFA on a yearly basis.    
2010.A1  Assurance: The internal audit activity 's plan of engagements 
must be based on a documented risk assessment, undertaken 
at least annually. The input of senior management and the 
board must be considered in this process.  x     The internal audit plans were based on a documented risk assessment, 
taking into consideration the input of Senior Management and the 
Chair/Members of the CBFA.    
2010.A2  Assurance: The chief audit executive must identify and consider 
the expectations of senior management, the board, and other 
stakeholders for internal audit opinions and other conclusions.  x     The internal audit plans took into consideration the expectations of 
Senior Management and the Chair/Mem bers of the CBFA.  
 
Whenever appropriate, the audit plans were modified to accommodate 
special requests arising from the Director -General and/or Members 
(whenever these requests were deemed relevant by the OIO to justify 
changes in its audit plan).    
2020 The chief audit executive must communicate the internal audit 
activity 's plans and resource requirements, including significant 
interim changes, to senior management and the board for 
review and approval.    x     Since 2017, the Head of the OIO communicated, in its annual reports 
to the Director -General (for appro val) and to the CBFA (for 
information), the internal audit plans, resource requirements and 
significant interim changes.    
2020 The chief audit executive must also communicate the impac t of 
resource limitations.  x     The Head of the OIO discussed several times with the Director -
General's Office and several Senior Managers about the impact of 
resource limitations. Resource limitations were also reported to the 
Director -General and the CBFA.      
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2030 The chief audit executive must ensure that internal audit 
resources are appropriate, sufficient, and effectively deployed to 
achieve the approved plan.  
 
Interpretation:  
Appropriate refers to the mix of knowledge, skil ls, and other 
competencies needed to perform the plan. Sufficient refers to 
the quantity of resources needed to accomplish the plan. 
Resources are effectively deployed when they are used in a way 
that optimizes the achievement of the approved plan.    x   Internal audit resources have been appropriate but not sufficient in 
2017-2020. According to the benchmarks, the OIO should be 
composed of at least three Internal Oversight professionals, including 
the Head of Office, one Internal Auditor and one Investigat or. 
 
The Head of the OIO reported on resources to the Director -General 
and to the CBFA every year since 2017;  and highlighted the OIO's 
resource limitations.  
 
Since May 2020, the OIO has been reinforced with the arrival of an 
Investigator who is expected to also provide support for internal 
audits.  
 
Pursuant to OFFICE(15)/101, the OIO must give priority to 
administrative investigations. Given the workload in investigations, the 
OIO has not been in a position to fully complete its yearly internal 
audit pla ns.   The OIO is currently 
analysing several 
options to free up 
additional resources 
for internal audits 
and investigations.  
 
The Head of the OIO 
will discuss about 
resource limitations 
with the recently 
appointed Director -
General.  
 
Pursuant to 
Admini strative 
Memorandum 974, 
the new Head of the 
OIO will also discuss 
resources and budget 
requirements with the 
Director -General.   
2040 The chief audit executive must establish policies and procedures 
to guide the internal audit activity.  
 
Interpretation:  
The form and content of policies and procedures are dependent 
upon the size and structure of the internal audit activity and the 
complexity of its work.  x     Given the current structure of the OIO and the expertise of its 
members, the curr ent procedures at the WTO are deemed sufficient to 
guide the internal audit activity.  
 
Taking into account the small size of the OIO, it is not deemed 
necessary to develop additional policies, procedures or guidelines.    
2050 The chief audit executive should share information and 
coordinate activities with other internal and external providers 
of assurance and consulting services. The chief audit executive 
should consider relying upon the work of other internal and 
external assurance and consu lting service providers.  
 
Interpretation:  
In coordinating activities, the chief audit executive may rely on 
the work of other assurance and consulting service providers. A 
consistent process for the basis of reliance should be 
established, and the chief au dit executive should consider the 
competency, objectivity, and due professional care of the 
assurance and consulting service providers. The chief audit 
executive should also have a clear understanding of the scope, 
objectives, and results of the work perfo rmed by other 
providers of assurance and consulting services. Where reliance x     The Head of the OIO had frequent meetings with the External Auditors 
(i.e. the Federal Court of Auditors of Germany (Bundesrechnungshof; 
and, since 2020, the Cour des Comptes of France), to share 
information and coordinate efforts. Th e External Auditors received a 
copy of all internal audit reports and OIO annual reports to the CBFA.  
 
The OIO also interacted, whenever necessary, with other functions 
within the WTO dealing with grievances and dispute resolution, such as 
the HRD Focal P oints, the Internal Mediator, the Staff Council, the Staff 
Welfare Officer, the WTO Psychologist, the Medical Service, and the 
Legal Counsel to the Administration. The mandate and objectives of 
each of these functions are clea rly defined and understood.      
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is placed on the work of others, the chief audit executive is still 
accountable and responsible for ensuring adequate support for 
conclusions and opinions reached by the internal audit activity.  
2050 The chief audit executive should ensure proper coverage and 
minimize duplication of efforts.  x     The Head of the OIO met regularly (at least two times per year) with 
the External Auditors, in order to coordinate efforts, ensure 
complementarity of audit coverage and avoid duplication of efforts.    
2060 The chief audit executive must report periodically to senior 
management and the board on the internal audit activity 's 
purpose, authority, responsibility, and performance relative to 
its plan and on its conformance with the Code of Ethics and the 
Standards.  x     As stated in Administrative M emorandum No.974, the OIO reports at 
least annually to the Director -General and to the CBFA.  
 
Since 2017, the Head of the OIO frequently reported to the 
Director -General, and at least twice per year to the CBFA.  
 
The annual reports included information ab out the internal audit 
activity 's charter, purpose, authority, independence, performance, 
budget, resources, results, and conformance with the Code of Ethics 
and the Standards.    
2060 Reporting must also include significant risk and control issues, 
including fraud risks, governance issues, and other matters that 
require the attention of senior management and/or the board.  x     The OIO informed relevant Senior Managers whenever significant risk 
or control issues were detected.  
 
The OIO also establis hed a severity rating for the recommendations 
proposed in internal audit reports (Severity: High, Medium, Low). The 
severity of the recommendations is, since 2019, also communicated to 
the CBFA.  
 
Furthermore, the Annual Reports to the Director -General and the CBFA 
contain information about administrative investigations and fraud 
cases.    
2070 When an external service provider serves as the internal audit 
activity, the provider must make the organization aware that 
the organization has the responsibility fo r maintaining an 
effective internal audit activity.  N/
A     The internal audit activity has not been delegated to an external 
service provider.    
2100 The internal audit activity must evaluate and contribute to the 
improvement of the organization 's governance, risk 
management, and control processes using a systematic, 
disciplined, and risk -based approach.  x     In each internal audit engagement, the OIO strived to contribute to the 
improvement of the organization 's governance, risk management, and 
control processes using a systematic, disciplined, and risk -based 
approach.  
 
The OIO also provided support for the establishment and maintenance 
of the WTO Risk Register and Internal Control Framework.      
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2100 Internal audit credibility and value are enhanced when auditors 
are proactive,  and their evaluations offer new insights and 
consider future impact.  x     The OIO proactively searched for good practices, trends and solutions, 
in order to propose relevant and value -adding recommendations to 
auditees.  
 
Furthermore, the Head of the OIO participated to the RIAS, RIS, HOIA 
and ENMO forums, where good practices are shared and discussed 
among International Organizations. Where appropriate,  these good 
practices have been used by the OIO.    
2110 The internal audit activity must assess and make appropriate 
recommendations to improve the organization 's governance 
processes for:  
- Making strategic and operational decisions.  
- Overseeing risk management and control.  
- Promoting appropriate ethics and values within the 
organization.  
- Ensuring effective organizational performance management 
and accountability.  
- Communicating risk and control information to appropriate 
areas of the organization.  
- Coordinating the activities of, and communicating information 
among, the board, external and internal auditors, other 
assurance providers, and management.  x     Whenever deemed necessary, the OIO made appropriate 
recommendations to improve the organizat ion's governance and risk 
management processes (e.g.: review of the procedure for 
administrative investigations and disciplinary sanctions, establishment 
of the WTO Risk Register, drafting of the Internal Control Framework, 
etc.).  
  
The OIO also actively p articipated in the promotion of ethical 
behaviour at the WTO (through participation to the Ethics Working 
Group, the organization of Ethics Townhall meetings/workshops/ 
webinars, the establishment of the Respect&Harmony mandatory 
online training, the parti cipation to the Induction programme for 
newcomers, etc.).  
  
As part of its mandate, the OIO also provided advice to the Director -
General's Office and/or Divisional Directors on topics related to 
operational decisions, risks and controls, etc.    
2110.A1  Assurance: The internal audit activity must evaluate the design, 
implementation, and effectiveness of the organization 's ethics -
related objectives, programs, and activities.  x     As stated in Administrative Memorandum No.974 - Office of Internal 
Oversight - one of the objectives of the OIO is to reinforce a culture of 
accountability and strengthen the ethical climate within the WTO 
Secretariat.  
 
The OIO organised several Ethics -related Townhall 
meetings/workshops/ webinars.  
 
The OIO also conducted the following actions:  
- Establishment of the Respect&Harmony mandatory online training, 
launched in 2019. More than 80  percent  of WTO staff members have 
now completed this training;  
- Participation to the Ethics Working Group, in charge of reviewing 
WTO's Standards of Conduct;  
- Design and facilitation of Ethics Webinars (November and December 
2020).  
 
Also, the Head of the OIO represents the WTO in the Ethics Network of 
Multilateral Org anization (ENMO), in order to remain informed of good 
practices and trends related to Ethics      
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Unfortunately the WTO does not have a dedicated Ethics Officer. The 
option of creating an Ethics Officer position (part -time) is currently 
being discussed. The OI O will evaluate the design, implementation, 
and effectiveness of the organization 's ethics -related objectives, 
programs, and activities after the appointment of the Ethics Officer.  
2110.A2  Assurance: The internal audit activity must assess whether the 
information technology governance of the organization supports 
the organization 's strategies and objectives.  x     The information technology governance was regularly discussed with 
ITSD, in the framework of the establishment of the OIO internal 
oversight plans and the follow -up of the internal audit 
recommendations contained in the internal audit report on IT Security .  
 
Furthermore, the OIO had frequent contacts with the IT Security 
Officer, to discuss issues related to IT and cybersecurity.    
2120 The internal audit activity must evaluate the effectiveness and 
contribute to the improvement of risk management process es. 
 
Interpretation:  
Determining whether risk management processes are effective 
is a judgment resulting from the internal auditor 's assessment 
that: 
- Organizational objectives support and align with the 
organization 's mission.  
- Significant risks are ide ntified and assessed.  
- Appropriate risk responses are selected that align risks with 
the organization 's risk appetite.  
- Relevant risk information is captured and communicated in a 
timely manner across the organization, enabling staff, 
management, and the  board to carry out their responsibilities.  
The internal audit activity may gather the information to 
support this assessment during multiple engagements. The 
results of these engagements, when viewed together, provide 
an understanding of the organization 's risk management 
processes and their effectiveness.  
Risk management processes are monitored through ongoing 
management activities, separate evaluations, or both.    x   The External Auditor (Federal Court of Auditors of Germany) conducted 
a performance aud it on Risk Management at the WTO in 2016 (Report 
of the External Auditor to the CBFA, WT/BFA/W/393, 10 June 2016).  
 
A detailed enterprise -wide Risk Register was developed  by AGSD in 
2016 and 2017. However, the Risk Officer position has remained 
vacant sinc e in 2017. The process for hiring a Compliance, Risk and 
Resilience Officer is currently ongoing (Vacancy Notice EXT/F/21 -11).  
  
The OIO decided to postpone the review of the risk management 
processes pending the appointment of the Compliance, Risk and 
Resilience Officer.  
 
In the meantime, the OIO continued to assess risks in the framework 
of the establishment of its annual plan and of each internal audit 
engagement.  The OIO will evaluate 
the effectiveness of 
risk management 
processes after the 
appointment  of the 
Compliance, Risk and 
Resilience Officer.  
2120.A1  Assurance: The internal audit activity must evaluate risk 
exposures relating to the organization 's governance, operations, 
and information systems regarding the:  
- Achievement of the organization 's strategic objectives.  
- Reliability and integrity of financial and operational 
information.  
- Effectiveness and efficiency of operations and programs.  
- Safeguarding of assets.  
- Compliance with laws, regulations, policies, procedures, and 
contracts.    x   See Q.2120.1 (supra).  The OIO will evaluate 
the effectiveness of 
risk management 
processes after the 
appointment of the 
Compliance, Risk and 
Resilience Officer.    
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2200 Internal Auditors must develop a written plan for each 
engagement.  x     For each internal audit engagement conducted in 2017 -2021, the OIO 
prepared a written engagement plan and audit program.    
2200 The written plan must contain the engagement 's object ives, 
scope, timing, and resource allocations.  x     For each internal audit engagement conducted in 2017 -2021, the 
related internal audit plan contained the objectives, scope, timing, and 
resources of the engagement.    
2200 The plan must consider the organization 's strategies, objectives, 
and risks relevant to the engagement.  x     The internal audit engagement plans took into consideration the 
strategy, objectives, and risks of the WTO relevant to the engagement.    
2201 In planning the engagement, internal auditors must consider:  
- The strategies and objectives of the activity being reviewed 
and the means by which the activity controls its performance.  
- The significant risks to the activity 's objectives, resources, and 
operations and th e means by which the potential impact of risk 
is kept to an acceptable level.  
- The adequacy and effectiveness of the activity 's governance, 
risk management, and control processes compared to a relevant 
framework or model.  
- The opportunities for making si gnificant improvements to the 
activity 's governance, risk management, and control processes.  x     Prior to initiating an internal audit engagement, the Head of the OIO 
meets with relevant Directors, Managers and/or Staff members, to 
gain a sound understan ding of the strategy, objectives, limitations, 
existing internal controls, significant risks and governance structure of 
the operations to be audited.    
2210 Objectives must be established for each engagement.  x     The objectives of each internal audit conducted in 2017 -2020 were 
detailed and documented in the internal audit engagement plans.    
2210.A1  Assurance: Internal auditors must conduct a preliminary 
assessment of the risks relevant to the activity under review. 
Engagement objectives must reflect the results of this 
assessment.  x     Prior to each internal audit engagement, the OIO reviewed the WTO 
Risk Register in order to identify risks relevant to the activity to be 
audited. Furthermore, the internal audit enga gement plan also 
included a section identifying the risks relevant to the engagement 
and/or the activity.    
2210.A2  Assurance: Internal auditors must consider the probability of 
significant errors, fraud, noncompliance, and other exposures 
when developing  the engagement objectives.  x     The OIO considered the probability of significant errors, fraud, non -
compliance, and other exposures when preparing internal audit 
engagement plans.  
 
Also, the OIO maintains a detailed Intake register where all allegations 
of misconduct/fraud are document ed.  
Audit engagements may also consider information contained in the 
Intake Register,    
2220 The established scope must be sufficient to achieve the 
objectives of the engagement.  x     The scope of each internal audit conducted in 2017 -2020 was detailed 
and documented (in the internal audit engagement plans and internal 
audit reports). The established scopes were deemed sufficient to 
achieve the expected objectives.    
2220.A1  Assurance: The scope of the engagement must include 
consideration of r elevant systems, records, personnel, and 
physical properties, including those under the control of third 
parties.  x     The OIO took into consideration relevant IT systems, records, assets 
and/or personnel when defining the internal audit engagement plans.      
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2220.A2  Assurance: If significant consulting opportunities arise during an 
assurance engagement, a specific written understanding as to 
the objectives, scope, respective responsibilities, and other 
expectations should be reached and the results of the consulting 
engagement communicated in accordance with consulting 
standards.  N/
A     No consulting engagements resulted from assurance engagements in 
2017-2020.    
2230 Internal auditors must determine appropriate and sufficient 
resources to achieve engagement objectives based on an 
evaluation of the nature and complexity of each engagement, 
time constraints, and available resources.  
 
Interpretation:  
Appropriate refers to the mix of knowledge, skills, and other 
competencies needed to perform t he engagement. Sufficient 
refers to the quantity of resources needed to accomplish the 
engagement with due professional care.    x   The OIO assigned appropriate and sufficient resources to achieve the 
engagements finalized in 2017 -2020.  
 
However, as above -mentioned, the OIO encountered difficulties for 
fully staffing its team, given the zero -nominal growth of WTO's budget 
since at least 2016.  
 
The Head of the OIO reported on resources to the Director -General 
and to the CBFA every year since 2017; and highl ighted the OIO's 
resource limitations.  
 
Since May 2020, the OIO has been reinforced with the arrival of an 
Investigator who is expected to also provide support for internal 
audits.  
 
Pursuant to OFFICE(15)/101, the OIO must give priority to 
administrative  investigations. Given the workload in investigations, the 
OIO has not been in a position to fully complete its yearly internal 
audit plans.   The OIO is currently 
analysing several 
options to free up 
additional resources 
for internal audits 
and investigat ions. 
 
The Head of the OIO 
will discuss about 
resource limitations 
with the recently 
appointed Director -
General.  
 
Pursuant to 
Admini strative 
Memorandum 974, 
the new Head of the 
OIO will also discuss 
resources and budget 
requirements with the 
Director -Gener al.   
2240 Internal auditors must develop and document work programs 
that achieve the engagement objectives.  x     The OIO developed and documented internal audit programs for the 
engagements conducted in 2017 -2020.    
2240.A1  Assurance: Work programs must include the procedures for 
identifying, analysing, evaluating, and documenting information 
during the engagement. The work program must be approved 
prior to its implementation, and any adjustments approved 
promptly.  x     The internal audit p rograms included work steps for identifying, 
analysing and documenting information related to the concerned 
engagements. The internal audit programs were prepared (and 
approved) by the Head of the OIO.    
2300 Internal auditors must identify, analyse, evaluate, and 
document sufficient information to achieve the engagement 's 
objectives.  x     The OIO considers that it identified, analysed and evaluated sufficient 
information to achieve its 2017 -2020 internal audit engagements.    
2310 Internal a uditors must identify sufficient, reliable, relevant, and 
useful information to achieve the engagement 's objectives.  
 
Interpretation:  
Sufficient information is factual, adequate, and convincing so 
that a prudent, informed person would reach the same 
conclu sions as the auditor. Reliable information is the best x     The OIO based its audit conclusions on information considered as 
sufficient, factual, adequate, reliable and relevant.      
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attainable information through the use of appropriate 
engagement techniques. Relevant information supports 
engagement observations and recommendations and is 
consistent with the objectives for the enga gement. Useful 
information helps the organization meet its goals.  
2320 Internal auditors must base conclusions and engagement 
results on appropriate analyses and evaluations.  x     The OIO's internal audit conclusions and engagement results were 
based on appropriate analyses and evaluations.  
 
The OIO developed an ''Audit Execution (finalization) checklist'', which 
should be completed at the end of each internal audit engagement to 
ensure that the reporting, communication, documentation and follow -
up of the audit results have been properly documented.    
2330 Internal auditors must document sufficient, reliable, relevant, 
and useful information to support the engagement results and 
conclusions.  x     For each audit engagement, the internal auditor(s) created and 
maintained dedicated folders (on paper and electronic formats) where 
the relevant information used to support results and conclusions are 
stored.  
 
The documentation is reviewed by the He ad of the OIO prior to 
finalizing the audit engagement. The OIO developed an ''Audit 
Execution (finalization) checklist'', which is completed at the end of 
each assignment, to ensure that the reporting, communication, 
documentation and follow -up of the aud it results have been properly 
documented.  
 
The Internal Auditor and/or the Head of the OIO assessed, for each 
internal audit assign ment conducted since 2016 whether the 
documentation was sufficient, reliable, relevant, and useful.    
2330.A1  Assurance: The chief audit executive must control access to 
engagement records. The chief audit executive must obtain the 
approval of senior management and/or legal counsel prior to 
releasing such records to external parties, as appropriate.  x     Engageme nt records are stored on a secured electronic directory 
(L:/DIV/OIO). Only the staff members of the OIO (and the ITSD 
Server Administrator) have access to the OIO directory.  
 
Documents on paper format are stored in a secured cabinet (locked) 
located in th e office of the OIO Assistant.  
 
The Head of the OIO always requested approval from the DGO and/or 
the Legal Advisor to the Director -General prior to releasing audit -
related information to external parties (e.g.: documents released to 
the Missions of Norwa y or USA, reports to the CBFA, etc.).    
2330.A2  Assurance: The chief audit executive must develop retention 
requirements for engagement records, regardless of the 
medium in which each record is stored. These retention 
requirements must be consistent with the organization 's 
guidelines and any pertinent regulatory or other requirements.  x     Engagement records should be retained for a minimum period of 
5 years.  
 
The OIO was established in November 2015 (and has been operating 
since September 2016). It retains all engagement records accumulated 
since then in dedicated binders (paper format) and on the OIO 
directory (L:/DIV/OIO, electronic format).      
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The OIO also ke eps all the documents inherited from the Office of 
Internal Audit (i.e. prior to November 2015), on a separate secured 
electronic directory (L:/DIV/OIA). Only the members of the OIO (and 
the ITSD Server Administrator) have access to this Directory.  
2340 Engagements must be properly supervised to ensure objectives 
are achieved, quality is assured, and staff is developed.  
 
Interpretation:  
The extent of supervision required will depend on the 
proficiency and experience of internal auditors and the 
complexit y of the engagement. The chief audit executive has 
overall responsibility for supervising the engagement, whether 
performed by or for the internal audit activity, but may 
designate appropriately experienced members of the internal 
audit activity to perform  the review. Appropriate evidence of 
supervision is documented and retained.  x     The Head of the OIO supervised personally  each audit engagement 
conducted since 2016, to ensure that the work delivered corresponded 
to established objectives and quality standards. The Head of the OIO, 
upon finalization of each internal audit, signed the Audit Execution 
(finalization) checklist.    
2400 Internal auditors must communicate the results of 
engagements.  x     The OIO communicated the results of engagements completed in 
2017-2021 to the Director -General and relevant managers/staff 
members.    
2410 Communications must include the engagement 's objectives, 
scope, and results.  x     The engagement's objectives, scopes, and results were detailed in 
internal audit reports.    
2410.A1  Assurance: Final communication of engagement results must 
include applicable conclusions, as well as applicable 
recommendations and/or action plans. Where appropriate, the 
internal auditors ' opinion should be provided. An opinion must 
take into account the expectations of senior management, the 
board, and other stakeholders and must be supported by 
suffic ient, reliable, relevant, and useful information.  x     The internal audit reports included applicable conclusions and 
recommendations/action plans.    
2410.A2  Assurance: Internal auditors are encouraged to acknowledge 
satisfactory performance in engagement communications.  x     The OIO acknowledged satisfactory performance, whenever applicable, 
in internal audit reports.    
2410.A3  Assurance: When releasing engagement results to parties 
outside the organization, the communication must include 
limitations on distribution and use of the results.  x     The OIO provided detailed summaries of engagement results to the 
members of the CBFA. Documents submitted to the CBFA are subject 
to limitations on distribution and use of the results.  
The OIO did not release engagement results to other parties outside 
the organization.    
2420 Communications must be accurate, objective, clear, concise, 
constructive, complete, and timely.  x     The OIO monitors the quality of its communication after each internal 
audit engagement (through Audit Effectiveness Questionnaires).  
Based on the questionnaires received, and although improvements are 
always welcomed, the OIO considers that the communicat ion has been 
sufficiently accurate, objective, clear, concise, constructive, complete, 
and timely. The OIO has not received comments indicating that its 
communications were unfair, partial and/or biased.       
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IIA-Standards  Self-Assessment  
IIA-Std Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
2421 If a final communication contains a signif icant error or omission, 
the chief audit executive must communicate corrected 
information to all parties who received the original 
communication.  x     No significant errors or omissions have been detected in 
communications made in 2017 -2021.    
2430 Indicating that engagements are "conducted in conformance 
with the International Standards for the Professional Practice of 
Internal Auditing " is appropriate only if supported by the results 
of the quality assurance and improvement program.  x     See Standard Q.1321.1.  
 
This Standard will be evaluated after completion of the External 
Quality Assessment foreseen in 2021.  
 
In the meantime, the OIO has indicated that it strives to conform with 
the International Standards for the Professional Practice of I nternal 
Auditing (the OIO did not indicate that the internal audit activity 
conforms with the Standards).    
2431 When non -conformance with the Code of Ethics or the 
Standards impacts a specific engagement, communication of 
the results must disclose the:  
- Principle(s) or rule(s) of conduct of the Code of Ethics or the 
Standard(s) with which full conformance was not achieved.  
- Reason(s) for non -conformance.  
- Impact of non -conformance on the engagement and the 
communicated engagement results.  x     The OIO considers that the observed non -conformance with the IIA 
Standards did not impact the engagements completed in 2017 -2020.    
2440 The chief audit executive must communicate results to the 
appropriate parties.  
 
Interpretation:  
The chief audit executive is responsible for reviewing and 
approving the final engagement communication before issuance 
and for deciding to whom and how it will be disseminated. 
When the chief audit executive delegates these duties, he or 
she retains overall responsibility.  x     OIO's results were communicated to the Director -General and 
concerned managers/staff members. A summary of the results was 
provided to the members of the CBFA.    
2440.A1  Assurance: The chief audit executive is responsible for 
communicating the final results to parties who can ensure that 
the results are given due consideration.  x     The Head of the OIO communicated the final results to the 
Director -General and concerned m anagers/staff members in charge of 
implementing the proposed recommendations.    
2440.A2  Assurance: If not otherwise mandated by legal, statutory, or 
regulatory requirements, prior to releasing results to parties 
outside the organization the chief audit executive must:  
- Assess the potential risk to the organization.  
- Consult with senior management and/or legal counsel as 
appropriate.  
- Control dissemination by restricting the use of the results.  x     Whenever deemed necessary, the OIO submitted t he draft internal 
audit reports for review to selected staff members (e.g.: the legal 
Counsel to the Administration), prior to releasing the final internal 
audit report. The dissemination of the internal audit reports is 
managed by the Director -General's O ffice.      
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IIA-Standards  Self-Assessment  
IIA-Std Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
2450 When an overall opinion is issued, it must take into account the 
strategies, objectives, and risks of the organization,  and the 
expectations of senior management, the board, and other 
stakeholders. The overall opinion must be supported by 
sufficient, reliable, relevant, and useful information.  
 
The communication will include:  
- The scope, including the time period to which  the opinion 
pertains.  
- Scope limitations.  
- Consideration of all related projects, including the reliance on 
other assurance providers.  
- A summary of the information that supports the opinion.  
- The risk or control framework or other criteria used as a basis 
for the overall opinion.  
- The overall opinion, judgment, or conclusion reached.  x     The OIO was not required to issue overall opinions.    
2500 The chief audit executive must establish and maintain a system 
to monitor the disposition of results communicated to 
management.  x     The OIO maintains a detailed Follow -up Register, to monitor the 
implementations of internal audit recommendations.    
2500.A1  Assurance: The chief audit executive must establish a follow -up 
process to monitor and e nsure that management actions have 
been effectively implemented or that senior management has 
accepted the risk of not taking action.  x     The OIO has established a detailed Follow -up process, to periodically 
monitor the implementations of internal audit recommendations.    
2600 When the chief audit executive concludes that management has 
accepted a level of risk that may be unacceptable to the 
organization, the chief audit executive must discuss the matter 
with senior management.  
 
Interpret ation:  
The identification of risk accepted by management may be 
observed through an assurance or consulting engagement, 
monitoring progress on actions taken by management as a 
result of prior engagements, or other means. It is not the 
responsibility of the  chief audit executive to resolve the risk.  x     In the framework of internal audit engagements, the OIO did not 
identify risks accepted by management that were perceived as 
unacceptable to the Organization.    
2600 If the chief audit executive determines that the matter has not 
been resolved, the chief audit executive must communicate the 
matter to the board.  x     The OIO reports to the CBFA, every year, on the status of 
implementation of internal audit recommendations (with details 
concerning recommendations still pending to be implemented).    
                
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Quality Assessment in case of Consulting Services  Self-Assessment  
IIA-Std Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
1000 The nature of consulting services must be defined in the 
internal audit charter.    x   The nature of consulting services is not defined in Administrative 
Memorandum No.974 - Office of Internal Oversight  
(OFFICE(15)/101).  
 
The revised version of the document will incorporate the nature of 
consultin g services  The revised Internal 
Oversight Charter, to 
be submitted to the 
Director -General and 
to the CBFA, will 
incorporate the 
nature of consulting 
services.  
1130 Internal auditors may provide consulting services relating 
to operations for which they had previous responsibilities.  x     The OIO conducted several consulting services, inside and 
outside the WTO, such as:  
 
1) The OIO Assistant, who previously worked several years in the 
Procurement Service, prepared and delivered a workshop on 
Procur ement Fraud.  
 
2) The OIO conducted the Quality Assessment exercise of WIPO's 
Internal Oversight Division (IOD).    
1130 If internal auditors have potential impairments to 
independence or objectivity relating to proposed 
consulting services, disclosure must be made to the 
engagement client prior to accepting the engagement.  x     No perceived or potential impairments to independence or 
objectivity relating to proposed consulting services have been 
identified since September 2016.    
1210 The chief audit executive declines the consulting 
engagement or obtain competent advice and assistance if 
the internal auditors lack the knowledge, skills, or other 
competencies needed to perform all or part of the 
engagement.  x     The internal auditors had the adequate knowledge, skills, and 
competencies needed to perform the consulting engagements.    
1220 Internal auditors must exercise due professional care 
during a consulting engagement by considering the:  
- Needs and expectations of clients, includ ing the nature, 
timing, and communication of engagement results.  
- Relative complexity and extent of work needed to 
achieve the engagement 's objectives.  
- Cost of the consulting engagement in relation to 
potential benefits.  x     The OIO exercised due professional care when conducting 
consulting engagements.    
2010 The chief audit executive should consider accepting 
proposed consulting engagements based on the 
engagement 's potential to improve management of risks, 
add value, and improve the organization 's operations. 
Accepted engagements must be included in the plan.  x     The Head of the OIO accepted to conduct consulting 
engagements that were perceived to bring added value to the 
WTO (or the external Organization, in the case of WIPO). The 
consulting engagements were included in the  OIO oversight plan.      
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Quality Assessment in case of Consulting Services  Self-Assessment  
IIA-Std Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
2120 During consulting engagements, internal auditors must 
address risk consistent with the engagement 's objectives 
and be alert to the existence of other significant ri sks. x     Risks related to a specific consulting engagement were assessed 
when defining the Engagement plan. Furthermore, throughout 
the entire engagement process, the internal auditor(s) remained 
attentive in order to identify any additional risk which could 
potent ially impact the objectives of the engagement and/or the 
concerned operations.    
2120 Internal auditors must incorporate knowledge of risks 
gained from consulting engagements into their evaluation 
of the organization 's risk management processes.  x     The OIO incorporated knowledge of risks gained from consulting 
engagements into its evaluation of the WTO risk management 
processes.    
2120 When assisting management in establishing or improving 
risk management processes, internal auditors must refrain 
from assuming any management responsibility by actually 
managing risks.  x     OIO staff members did not assume any management 
responsibility (outside the mandate of the OIO)  and did not 
manage risks outside its mandate.    
2130 Internal auditors must incorporate knowledge of controls 
gained from consulting engagements into evaluation of 
the organization 's control processes.  x     The OIO took into consideration the experience gained from 
consulting engagements when evaluating the organization 's 
control  processes.    
2201 Internal auditors must establish an understanding with 
consulting engagement clients about objectives, scope, 
respective responsibilities, and other client expectations. 
For significant engagements, this understanding must be 
documented.  x     The modality (objectives, scope, timing, perceived risks, etc.) of 
each consulting engagement was documented (engagement 
plans), in agreement with the ''client''.    
2210 Consulting engagement objectives must address 
governance, risk management, and control processes to 
the extent agreed upon with the client.  x     Governance, risk management, and control processes were 
included in the scope of consulting engagements, whenever 
requested by - and agreed with the ''clien t''.    
2210 Consulting engagement objectives must be consistent 
with the organization's values, strategies, and objectives.  x     Consulting engagement objectives were consistent with the 
organization's values, strategies, and objectives.    
2220 In performing consulting engagements, internal auditors 
must ensure that the scope of the engagement is 
sufficient to address the agreed -upon objectives. If 
internal auditors develop reservations about the scope 
during the engagement, these reservations must be 
discussed with the client to determine whether to continue 
with the engagement.  x     The scopes of the engagements conducted since September 2016 
were sufficient to address the agreed -upon objectives.    
2220 During consulting engagements, internal auditors address 
controls consistent with the engagement 's objectives and 
be alert to significant control issues.  x     The OIO addressed controls consistent with the engagement 's 
objectives and remained vigilant to significant control issues.      
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Quality Assessment in case of Consulting Services  Self-Assessment  
IIA-Std Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
2240 Work programs for consulting engagements may vary in 
form and content depending upon the nature of the 
engagement.  x     Work programs were tailor -made depending upon the nature of 
the engagement.    
2330 The chief audit executive develops policies governing the 
custody and retention of consulting engagement records, 
as well as their release to internal and external parties . 
These policies are consistent with the organization 's 
guidelines and any pertinent regulatory or other 
requirements.  x     The custody, retention and communication of consulting 
engagement records follow the same rules than for internal audit 
records.    
2410 Communication of the progress and results of consulting 
engagements will vary in form and content depending 
upon the nature of the engagement and the needs of the 
client.  x     Communication was adapted to each consulting engagement.    
2440 The chief audit executive is responsible for communicating 
the final results of  
consulting engagements to clients.  x     The Head of the OIO was responsible for communicating the final 
results of consulting engagements to the relevant ''clients''.    
2440 During consulting engagements, governance, risk 
management, and control  
issues may be identified. Whenever these issues are 
significant to the organization, they  
must be communicated to senior management and the 
board.  x     No significant governance, risk management, or control  
issues were identified in 2017 -2021, which would require specific 
communication to Senior  Management and/or the CBFA.    
2500 The internal audit activity monitors the disposition of 
results of consulting engagements to the extent agreed 
upon with the client.  x     The OIO monitored the disposition of results of consulting 
engagements (whenever it concerned internal engagements).    
              
                
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IIA Rules of Conduct  Self-Assessment  
Rule Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
Integrity  Internal auditors:  
1.1. Shall perform their work with honesty, diligence, and 
responsibility.  
1.2. Shall observe the law and make disclosures expected 
by the law and the profession.  
1.3. Shall not knowingly be a party to any illegal activity or 
engage in acts that are discreditable to the profession of 
internal auditi ng or to the organization.  
1.4. Shall respect and contribute to the legitimate and 
ethical objectives of the organization.  x     To the knowledge of the Head of the OIO, the OIO staff 
members respected the applicable rules of conduct in 
2017-2021. No insta nces of misconduct/lack of integrity on 
their part were recorded in 2017 -2021. The Internal 
auditors performed their work with honesty, diligence, and 
responsibility; observed the law and made disclosures 
expected by the law and the profession (whenever 
applicable); did not knowingly be a party to any illegal 
activity; and respected the ethical values (Code of Conduct) 
of the WTO.    
Objectivity  Internal auditors:  
2.1. Shall not participate in any activity or relationship that 
may impair or be presumed to impair their unbiased 
assessment. This participation includes those activities or 
relationships that may be in conflict with the interests of the 
organization.  
2.2. Shall not accept anything that may impair or be 
presumed to impair their professional judgment.  
2.3. Shall disclose all material facts known to them that, if 
not disclosed, may distort the reporting of activities under 
review.  x     To the knowledge of t he Head of the OIO, the OIO staff 
members did not participate, in 2017 -2021, in activities that 
may have impaired their objectivity, unbiased assessment 
and/or professional judgment.    
Confidentiality  Internal auditors:  
3.1. Shall be prudent in the use and protection of 
information acquired in the course of their duties.  
3.2. Shall not use information for any personal gain or in 
any manner that would be contrary to the law or 
detrimental to the legitimate and ethical objectives of the 
organization.  x     In 2017 -2021, To the knowledge of the Head of the OIO, 
the OIO Internal auditors remained prudent in the use and 
protection of information acquired in the course of their 
duties, and did not use information for any personal gain or 
in any manner that woul d be contrary to the law or 
detrimental to the legitimate and ethical objectives of the 
organization.    
Competency  Internal auditors:  
4.1. Shall engage only in those services for which they have 
the necessary knowledge, skills, and experience.  
4.2. Shall perform internal audit services in accordance with 
the International Standards for the Professional Practice of 
Internal Auditing.  
4.3. Shall continually improve their proficiency and the 
effectiveness and quality of their services  x     The OIO Inte rnal auditors engaged only in services for 
which they had the necessary knowledge, skills and 
experience. Their audit services were delivered, as much as 
possible, in accordance with the International Standards for 
the Professional Practice of Internal Aud iting (with the 
exceptions noted above).  
The OIO strived to continually improve the proficiency, 
effectiveness and quality of its services.    
 
 
    
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ANNEX 5 – INVESTIGATION FUNCTION – QUALITY SELF -ASSESSMENT  
Last update:  May 2021  
Evaluators: Benoit de Schoutheete and Nathalie Iniguez  
GC = Generally Conforms, PC = Partially Conforms, DNC = Does Not Conform  
 
# Standard  Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
1 Investigative 
Office  
Par. 1  Each Organization shall have an Investigative 
Office responsible for conducting 
investigations.  x     The Office of Internal Oversight (OIO) is the exclusive entity 
responsible for investigating allegations of violations of any WTO 
norm applicable to Staff memb ers, irrespective of the nature of their 
contracts.    
2 Objectivity, 
Impartiality, 
Fairness  
Par. 3  The Investigative Office shall maintain 
objectivity, impartiality, and fairness 
throughout the investigative process and 
conduct its activities competently and with the 
highest levels of integrity.  x     Pursuant to WTO Regulation 1.5, staff members shall conduct 
themselves at all times in an appropriate manner and shall avoid  any 
action which may adversely reflect on their status as international 
civil servants, or on the integrity, independence and impartiality 
which are required by that sta tus.  
 
One of the fundamental standards of conduct of the WTO derives 
from the requirement of integrity. Integrity implies not only honesty, 
truthfulness and freedom from corrupting influences but also 
integrity as an international public official. Staff m embers must 
regulate their conduct with the interests of the WTO in view and 
avoid placing themselves in a position where their private interests 
would actually or potentially conflict with the interests of the WTO. 
[...] Integrity, loyalty, independence a nd impartiality are absolute 
requirements.  
 
The Head of the OIO and other OIO staff must, at all times, ensure 
that their conduct is compatible with the objectivity and 
independence required by their functions.  
 
To ensure its impartiality and credibility,  the OIO may not perform 
any operational duty or be involved in any activity which may, 
pursuant to OFFICE(15)/101, be subject to any form of evaluation or 
audit, or which has been evaluated or audited by the OIO.  
 
The Administrative Investigation shall be  conducted with all due 
professionalism and objectivity.  
 
The OIO has strictly adhered to the highest standards of objectivity, 
impartiality, fairness, competence and integrity since 2016. No 
allegations of lack of objectivity, impa rtiality, fairness or in tegrity 
have been substantiated.       
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# Standard  Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
3 Independence  
Par. 3  In particular, the Investigative Office shall 
perform its duties independently from those 
responsible for or involved in operational 
activities and from staff members liable to be 
subject of investigations and shall also be free 
from improper influence and fear of retaliation.  x     The OIO is an operationally independent office inside the WTO 
Secretariat. Except as expressly provided in OFFICE(15)/101, the 
Head of the OIO and other OIO staff are functionally and 
operationally independent from the Secretariat and from WTO 
Members in the conduct of their duties.  
 
Furthermore, in the exercise of their duties, the Head of the OIO and 
other OIO staff members may neither seek nor accept any 
instruct ion from any person or entity outside the OIO, whether this 
person or entity is within or outside the WTO.  
 
Neither the Director -General nor any other WTO staff member may 
seek to influence or otherwise interfere with the work of the OIO. 
The Head of the O IO and other OIO staff must, at all times, ensure 
that their conduct is compatible with the objectivity and 
independence required by their functions.  
 
No OIO staff member may be subject to investigation or disciplinary 
procedure of any kind on the part of the WTO except in accordance 
with paragraphs 20 and 21 of OFFICE(15)/101.  
 
Finally, the Director -General shall protect any staff member from 
retaliation or threat thereof for cooperation with the OIO.  
 
The Head of the OIO reported to the CBFA, each year si nce 2016, 
that no circumstances have affected, in fact or appearance, the 
independence of the OIO or impeded its ability to effectively fulfil its 
functions and responsibilities in an unbiased, objective and 
independent manner. Neither the Director General  nor any other 
WTO senior official have tried to influence or otherwise interfered 
with the work of the OIO.    
4 Conflict of 
interest  
Par. 4  The staff of the Investigative Office shall 
disclose to a supervisor in a timely fashion any 
actual or potential conflicts of interest he or 
she may have in an investigation in which he 
or she is participating, and the supervisor shall 
take appropriate action to remedy the conflict.  x     If it deems it necessary due to conflict of interests or because of t he 
specific expertise necessary for an objective investigation of the 
matter, the OIO may request the Director General to appoint an ad 
hoc Investigator, in which case it shall so inform the Complainant(s).  
 
The Head of the OIO promptly informed the Direct or-General 
whenever an actual or potential conflict of interest appeared at the 
OIO with regards to investigations. The Director -General and the 
Head of the OIO have sy stematically and timely taken all necessary 
measures to remedy all instances of actual o r perceived/potential 
conflict of interest.  
     
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# Standard  Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
Also, to ensure its impartiality and credibility, the OIO may not 
perform any operational duty or be involved in any activity which 
may, pursuant to this Administrative Memorandum, be subject to 
any form of eval uation or audit, or which has been evaluated or 
audited by the OIO.  
5 Procedure re: 
Allegations of 
misconduct 
by staff of the 
Investigative 
Office  
Par. 5  Appropriate procedures shall be put in place to 
investigate allegations of Misconduct on the 
part of any staff member of the Investigative 
Office.  x     Should the need arise to investigate any allegation of misconduct on 
the part of an OIO staff member, including the Head of the OIO, the 
Director -General shall refer the matter to the WTO External Auditor. 
The External Auditor will either investigate the matter itself or, if the 
matter at issue so requires, appoint an outside investigator reporting 
to it. In carrying out an investigation, the External Auditor or the 
outside investigator, as  the case may be, shall apply the WTO 
procedures for investigations and disciplinary matters mutatis 
mutandis.  
 
The Director -General may apply disciplinary sanctions to the Head of 
the OIO or OIO staff member only on the basis of detailed written 
recommend ations of the WTO External Auditor.  In such a case, the 
Director -General shall inform the Chairs of the General Council and 
of the CBFA for information that such sanctions have been applied.     
6 Publication of 
mandate 
and/or terms 
of reference 
of the 
Investigative 
Office and 
annual report 
of its 
activities  
Par. 6  Each Organization shall publish the mandate 
and/or terms of reference of its Investigative 
Office as well as an annual report highlighting 
the integrity and anti -fraud and corruption 
activities  of its Investigative Office in 
accordance with its policies on the disclosure of 
information.  x     The mandate of the OIO is detailed in OFFICE(15)/101 - Office of 
Internal Over sight, which is publicly available on the WTO's website 
and intranet.  
 
The annual reports of the OIO are immediately available to the 
Members (through the CBFA) and, after 3 months, to the general 
public. The annual reports provide information on all the activities 
conducted by the OIO during the year, including in vestigations.    
7 Confidentiali ty 
Par. 7, Par. 21  The Investigative Office shall take reasonable 
measures to protect as confidential any non -
public information associated with an 
investigation, including the identity of parties 
that are the subject of the investigation and of 
parties providing testimony o r evidence. The 
manner in which all information is held and 
made available to parties within each 
Organization or parties outside of the 
Organization, including national authorities, is 
subject to the Organization's rules, policies and 
procedures.  x     The Investigation and any administrative decision taken in relation to 
it shall be strictly confidential. The Investigator , the Complainant(s) 
and any other person called to participate in the Investigation 
including witnesses and any support given to the Investigator shall 
keep confidential any information they may acquire in the context of 
the Investigation indefinitely. An y breach of confidentiality may be 
subject to disciplinary and/or judicial action by the WTO. The fact 
that a piece of information becomes public through no fault of the 
persons participating in the Investigation does not dispense these 
persons from keepin g this information confidential. In case of doubt, 
the opinion of the Investigator shall be sought.  
 The OIO observed 
that the importance 
of preserving 
confidentiality is 
not always well 
understood by staff 
members. 
Therefore , the OIO 
considers that 
additional measures 
could be 
implemented at the   
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# Standard  Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
The sta ff of the Investigative Office shall take 
appropriate measures to prevent unauthorized 
disclosure of investigative information.  If necessary, the Investigator shall take the necessary steps to 
safeguard the confidentiality of a statement, testimony or document 
as long as such steps are consistent with the procedural rights of the 
parties, particularly the audi alteram partem  principle. In case of 
doubt, the Investigator shall opt for a solution safeguarding the 
confidentiality of the testimony or information in general, if the 
Invest igator deems it necessary in order to protect the dignity and 
reputation of any staff member or third party. The Investigator shall 
nevertheless take all possible steps to limit the impact of his/her/its 
choice on the adversarial principle.  
 
The OIO has ta ken all reasonable measures to protect and safeguard 
the confidentiality of investigations, including the following:  
- all participants to an investigation are required to sign an Oath of 
Confidentiality.  
- investigation documents are securely stored on a  specific server 
dedicated to the OIO.  
- paper copies of documents are archived in locked cabinets to 
prevent unauthorized access.  WTO to further 
reinforce the 
safeguarding of 
confidentiality in 
general. Staff 
members dealing 
with confidential 
information (e.g.: 
HRD, Medical 
Service, etc.) 
should be reminded 
(or made aware) of 
what constitutes 
confidential 
information and its 
resulting 
obligations.  
8 Investigative 
findings and 
recommen -
dations 
Par. 8  Investigative findings shall be based on facts 
and related analysis, which may include 
reasonable inferences.  x     Pursuant to OFFICE(15)/101, an investigation is a formal fact-finding  
administrative inquiry. The purpose of an investigation is to examine 
and determine the veracity of allegations of misconduct, as defined 
above, and to report thereon.  
 
Also, the purpose of the Administrative Investigation shall be 
primarily to determine  whether and to what extent the allegation(s) 
made in the Complaint are factually supported. Where appropriate, 
the Investigator shall also qualify legally the facts and propose a 
disciplinary sanction and/or any other solution he/she/it may deem 
in the in terest of the Organization, in accordance with the Staff Rules 
and Regulations.  
 
The Investigator may draw any inference from insufficient 
cooperation on the part of the persons participating in an 
investigation, or if it appears beyond reasonable doubt th at evidence 
has been intentionally falsified, tampered with or destroyed in the 
context of the investigation.  
 
Investigative findings made by the OIO are based on facts and 
related analysis, which may, if deemed necessary, include 
reasonable inferences.      
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# Standard  Statement  G
C P
C D
N
C Analysis / Rationale  Remediating 
actions planned  
9 Investigative 
findings and 
recommen -
dations  
Par. 9  The Investigative Office shall make 
recommendations, as appropriate, to the 
Organization's management that are derived 
from its investigative findings.  x     While OFFICE (14)/17 does not contain specific provisions 
authorizing the OIO to make recommendations (other than related 
to sanctions) to management, the OIO has, whenever deemed 
necessa ry, included such recommendation in its investigation 
reports. The new investigation procedure is expected to include 
specific provisions allowing the OIO to issue recommendations to 
management (Management implication reports).  The new 
investigation 
procedure should 
include provisions 
allowing the OIO to 
issue 
recommendations 
to management  (in 
separate 
management 
implication 
reports).  
10 Nature of 
investigations  
Par. 10  All investigations conducted by the 
Investigative Office are administrative in 
nature.  x     Pursuant to OFFICE( 15)/101, an investigation is a formal fact-finding  
administrative inquiry. All investigations conducted by the OIO have 
been administrative by nature.    
11 Standard of 
proof 
Par. 12  The Standard of Proof that shall be used to 
determine whether a complaint is 
substantiated is defined for purposes of an 
investigation as information that, as a whole, 
shows that something is more probable than 
not. x     The WTO applies the Standard of Proof promulgated by the ILOAT, 
which is ''beyond reasonable doubt''. This Standard of Proof is more 
restrictive that ''More probable than not''.    
12 Protection of 
whistle -
blowers  
Par. 13  A staff member who qualifies as a  "whistle -
blower" under the rules, policies and 
procedures of the Organization shall not be 
subjected to retaliation by the Organization. 
The Organization will treat retaliation as a 
separate act of Misconduct    x   The Director -General shall protect any staff member from retaliation 
or threat thereof for cooperation with the OIO.  
 
He/she and the administration must guarantee, under any 
circumstances, the protection of any person involved in an 
investigation from any pressure, threat or retalia tion originating in 
any WTO staff or body in relation to words spoken or written in the 
context of the investigation.  
 
Pursuant to OFFICE(14)/17, ''[i]n no case may the Complaint be 
anonymous''. However, the OIO has the possibility not to disclose 
the nam e of the Complainant(s), granting a certain level of 
anonymity to the Complainant(s).  
 
Also, allegations of retaliation have been treated as separate acts of 
misconduct.  
 
The new investigation procedure is expected to accept anonymous 
complaints, to conta in provisions for protecting whistle -blowers, and 
to specify that retaliation shall be treated as a separate act of 
misconduct.      
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13 Staff's duty 
to report  
Par. 14  The Organization may require staff to report 
suspected acts of fraud, corruption, and other 
forms of Misconduct.  x     The WTO strongly encourages staff to report suspected acts of fraud, 
corruption or misconduct (''speak up'').    
14 Staff's duty 
to cooperate  
Par. 15  The Organization shall require staff to 
cooperate with an investigation and to answer 
questions and comply with requests for 
information.  x     Pursuant to OFFICE(14)/17, staff members involved in the 
investigative process shall cooperate with an investigation.  
 
The Investigator may require full  and complete cooperation on the 
part of the Complainant(s), the person(s) directly concerned by the 
allegation(s) of the Complainant(s), as well as from witnesses and/or 
declarants. The Investigator may draw any inference from 
insufficient cooperation on their part or if it appears beyond 
reasonable doubt that evidence has been intentionally falsified, 
tampered with or destroyed in the context of the investigation. Any 
WTO staff member shall be under an obligation, if the Investigator 
so requests, to colla borate fully in the Investigation, but may not 
have to incriminate him/herself.  
 
Since 2016, the OIO did not encounter any case of non -cooperation 
requiring corrective actions.    
15 Staff's duty 
to cooperate  
Par. 16  Each Organization should adopt rules, policies 
and procedures and, to the extent that it is 
legally and commercially possible, include in its 
contracts with third parties, provisions that 
parties involved in the investigative process 
shall cooperate with a n investigation.    x   Contracts with third parties do not currently include provisions that 
parties involved in the investigative process shall cooperate with an 
investigation. However, since the WTO does not often work with 
implementing partners in the field, such clauses may not be 
considered relevant or necessary.  
 
Whenever necessary, the OIO called relevant third parties to 
participate in investigations. Their participation remained voluntary 
(they were not be obliged to participate).  The OIO will liaise 
with the Legal 
Couns el to the 
Administration to 
discuss the 
possibility of adding 
such provisions in 
the contracts with 
third parties.  
16 Subject's 
right to be 
heard  
Par. 17  As part of the investigative process, the 
subject of an investigation shall be given an 
opportunity t o explain his or her conduct and 
present information on his or her behalf. The 
determination of when such opportunity is 
provided to the subject is regulated by the 
rules, policies and procedures of the 
Organization.  x     The Investigator shall afford all person(s) concerned by the 
Investigation the possibility of making written comments on any 
testimony or document concerning them that the Investigator 
intends to use for his/her/its report, before the drafting of this 
report.  
 
More generally, th e Investigator shall scrupulously ensure, at every 
stage of the procedure, that the procedural rights of the parties, as 
recognized by the jurisprudence of the ILOAT, are upheld.  
 
Parties may submit any evidence they deem relevant under any 
format, subject  to compliance with Staff Rule 101.1. The 
Investigator may request access to evidence to which the parties 
may not have direct access.  
     
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The OIO has scrupulously ensured that the Subjects of investigations 
are given the opportunity to make written comments or to present 
information on any testimony or document concerning them.  
17 Timeliness of 
investigations  
Par. 18  The Investigative Office should conduct the 
investigation expeditiously within the 
constraints of available resources.  x     The OIO has initiated investigations as expeditiously as possible, 
within the constraint of available resources and the sanitary 
situation.  
 
Pursuant to OFFICE (14)/17, investigation report shall be submitted 
to the Director General as expeditiously as possible, but n o later 
than 45 days from the inception of the Investigation. The OIO has 
strived to respect the deadlines. Whenever necessary, the OIO, after 
having consulted the parties concerned, has requested the Director -
General to extend the deadlines.     
18 Examination 
and records 
of 
information  
Par. 19  The Investigative Office should examine both 
inculpatory and exculpatory information.  x     The OIO systematically included inculpatory and exculpatory 
information in its investigation reports.    
19 Examination 
and records 
of 
information 
collected  
Par. 20  The Investigative Office shall maintain and 
keep secure an adequate record of the 
investigation and the information collected.  x     The OIO keeps detailed records for each investigation case (separate 
binders and files per investigation). Investigation records are stored 
in securely locked cabinets (located in the OIO's office) and on a 
dedicated OIO server. Only OIO staff members have access to the 
records.  The OIO will inq uire 
with the Head of 
Security  the 
possib ility of 
installing secure 
electronic locks on 
OIO's office doors.  
20 Access to 
information, 
records, 
persons, 
premises, 
etc.   
Par. 23,  
Par. 24  For purposes of conducting an investigation, 
the Investigative Office shall have full and 
complete access to all relevant information, 
records, personnel, and property of the 
Organization, in accordance with the rules, 
policies and procedures of the Organization.  
To the extent provided by the Organizatio n's 
rules, policies and procedures and relevant 
contracts, the Investigative Office shall have 
the authority to examine and copy the relevant 
books and records of projects, executing 
agencies, individuals, or firms participating or 
seeking to participate i n Organization -financed 
activities or any other entities participating in 
the disbursement of Organization's funds.  x     In the performance of its functions and responsibilities, and in 
compliance with the applicable international standards, the OIO is 
authorised to:  
i. have full and unrestricted access to all WTO records (irrespective 
of their status and location), premises and property, as well as to all 
personnel (including the Director -General and members of his/her 
office), and require all necessary  assistance from them;  
ii. have access to all third parties performing services delegated to 
them by the WTO, in accordance with contractual terms;  
iii. require any staff member of the Organization to supply such 
information and explanations as may be need ed; 
iv. be available to all staff who wish, in good faith, to report on fraud 
or other forms of misconduct. The OIO shall in all cases respect a 
staff member's wish for confidentiality and take appropriate action to 
protect that staff member.      
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21 Documenta -
tion of 
investigative 
findings and 
conclusions  
Par. 22  The Investigative Office shall document its 
investigative findings and conclusions.  x     The Investigator documents every stage of his/her/its Investigation. 
In particular, the Investigator draft minutes, summaries or reports of 
any testimony or oral statement provided in the context of the 
Administrative Investigation, signed by the witness o r declarant.  
 
The OIO systematically documents each step of the investigation 
process. Also, its findings and conclusions are detailed in the 
investigation reports.    
22 Confidential 
and 
anonymous 
complaints  
Par. 27  The Investigative Office shall accept all 
complaints irrespective of their source, 
including complaints from anonymous or 
confidential sources.    x   The OIO accepts all complaints irrespective of their source, save 
anonymous complaints. The current inves tigation procedure does not 
accept anonymous complaints.  The new 
investigation 
procedure will 
accept anonymous 
complaints  and 
include further 
provisions for 
protecting whistle -
blowers.  
23 Acknowled -
gement  of 
receipt of 
complaints, 
registration 
and review 
and 
preliminary 
evaluation  
Par. 28, 
Par. 29, 
Par. 30 Where practicable, the Investigative Office will 
acknowledge receipt of all complaints.  
 
All complaints shall be registered and reviewed 
to determine wh ether they fall within the 
jurisdiction or authority of the Investigative 
Office.  
Once a complaint has been registered, it will 
be evaluated by the Investigative Office to 
determine its credibility, materiality, and 
verifiability [...] to determine whether  there is 
a legitimate basis to warrant an investigation.  x     Upon receiving a sufficiently documented Complaint, the OIO 
immediately provides a written acknowledgement of receipt, and 
informs the Complainant of the time period within which it intends to 
rule on the initiation of an investigation.  
 
The OIO maintains a detailed intake register where all complaints 
are recorded and followed up. The complaints are systematically 
reviewed to determine whether they fall within the authority of the 
OIO. The credibility, materiality, and verifiability of each allegation is 
assessed to determine whether there is a legitimate basis to warrant 
an investigation.    
24 Case 
prioritization  
Par. 32  The planning and conduct of an investigation 
and the resources allocated to it should take 
into account the gravity of the allegation and 
the possible outcome(s).  x     In practice, the OIO has systematically prioritized investigations 
according to its ava ilable resources, the gravity/severity of the 
allegations, the perceived risk of retaliation and the possible 
outcomes of the investigation. Investigations where there was a risk 
of retaliation for any of the involved parties, or a major risk for the 
WTO, have been given priority.    
25 Corroboration 
of 
information  
Par. 33  The Investigative Office shall, wherever 
possible, seek corroboration of the information 
in its possession.  x     Whenever possible, the OIO sought corroboration of information 
gathered in the framework of an investigation (through witness 
interviews, review of complementary information, etc.).      
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26 Treatment of 
Investigative 
Activity and 
critical 
decisions  
Par. 35  Investigative Activity and critical decisions 
should be documented in writing and reviewed 
with managers of the Investigative Office.  x     The Investigator shall document every stage of his/her/its 
Investigation.  
 
The Investigator's report to the Director General shall contain [...] a 
sufficiently detailed account of the conduct of the Investigation so as 
to allow the Director General and the parties to assess its 
compliance with general principles of international administrative law 
and relevant procedural requirements; a sufficiently detailed account 
of the facts so as to allow the Director General and the parties to 
assess the objectivity and exhaustiveness of the report; sufficiently 
detailed factual conclusions so as to allow the Director General to 
reach an informed decision; [...] . 
 
Investigative activities and critical decisions are systematically  
documented and summarized in the investigation reports (under 
section "Methodology ").  
 
The Head of the OIO reviews the (draft) investigation report, along 
with all the supporting docum ents before it is submitted to the 
Director -General and the parties.    
27 Interviews  
Par. 37  To the extent possible, interviews conducted 
by the Investigative Office should be 
conducted by two persons (Interviews of 
subjects should be conducted by two 
investigators. For interviews of complainants, 
witnesses and other persons, the number of 
interviewers depends on the nature and the 
circumstances of the case.)  x     In practice, each interview conducted by the OIO was performed by 
two persons (usually tw o OIO staff members).  
Furthermore, whenever possible and accepted by the parties, the 
OIO audio recorded and prepared detailed minutes of the interview 
meetings.    
28 Payment and 
expenses re: 
witnesses, 
subject, or 
other sources 
of 
information  
Par. 39  The Investigative Office will not pay a witness 
or a subject for information. Subject to the 
Organization's rules, policies, policies and 
procedures, the Investigative Office may 
assume responsibility for reasonable expenses 
incurred by witnesses or other sources of 
information to meet with the Investigative 
Office.  x     The OIO has never paid a witness or a subject for information.    
29 Assistance 
from external 
parties  
Par. 40  The Investigative Office may engage external 
parties to assist in its investigations.  x     The OIO has requested assistance from external investigators 
(whether from other International Organizations or Consultants) for 
conducting investigations. Since 2016, the OIO used the services of 
external investigators of UNHCR, WIPO and two independent 
consultants. This practice was mainly used whenever the OIO lacked 
internal resources or had any actual or potential (perceived) conflict 
of interest.      
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30 Procedure for 
unsubstan -
tiated 
complaints  
Par. 41  If the Investigat ive Office does not find 
sufficient information during the investigation 
to substantiate the complaint, it will document 
such findings, close the investigation, and 
notify the relevant parties, as appropriate.  x     The OIO prepared an investigation report for each investigation 
opened since 2016, even if the related allegations were found 
unsubstantiated (or lacking evidence). The investigation report was 
systematically shared with the parties.  
 
The Complainant(s) a nd the Subject(s) of an investigation receive 
the investigation report at the same time it is sent by the 
Investigator to the Director General.    
31 Procedure for 
substantiated 
complaints  
Par. 42  If the Investigative Office finds sufficient 
information to substantiate the complaint, it 
will document its investigative findings and 
refer the findings to the relevant authorities 
within the Organization, consistent with the 
Organization's rules, polici es and procedures.  x     See above.    
32 Procedure for 
knowingly 
false 
complaints  
Par. 43  Where the Investigative Office's findings 
indicate that a complaint was knowingly false, 
the Investigative Office shall, where 
appropriate, refer the matter to the relevant 
authorities in the Organization for further 
action consistent with the Organization 's rules, 
policies and procedures.  x     The OIO shall refer to the Director -General whenever a complaint 
appears to be knowingly false. The Director General may sanction 
staff members knowingly making false allegations, statements or 
testimonies or knowin gly submitting false or forged materials.    
33 Procedure for 
witness/  
subject's 
failure to 
comply  
Par. 44  Where the Investigative Office's findings 
indicate that there was a failure to comply with 
an obligation existing under the investigative 
process by a witness or subject, the 
Investigative Office may refer the matter to 
the relevant authorities in the Organization.  x     See above.  
 
The Investigator may draw any inference from insufficient 
cooperation on the part of parties participating in an investigation or 
if it appears beyond reasonable doubt that evidence has been 
intentionally falsified, tampered with or destroyed in the context of 
the investigation. Any WTO staff member shall be under an 
obligation, if the Inv estigator so requests, to collaborate fully in the 
Investigation, but may not have to incriminate him/herself.    
34 Possibility to 
refer 
information 
to national 
authorities  
Par. 45  The Investigative Office may consider whether 
it is appropriate to refer i nformation relating to 
the complaint to the appropriate national 
authorities and the Investigative Office will 
seek the necessary internal authorization to do 
so in cases where it finds a referral is 
warranted.  x     The OIO and the Office of the Legal Counsel have agreed that the 
OIO shall refer to the Legal Counsel to the Administration whenever 
the matter requires the intervention of - or referral to - national 
(Swiss) authorities.    
 
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