RESTRICTED  
  
WT/BFA/W/ 579 
 
1 March  2022 
(22-1847) Page: 1/19 
Committee on Budget, Finance and Administration    
 
 
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 STATUS OF THE IMPLEMENTATION OF EXTERNAL AUDIT RECOMMENDATIONS  
1  BACKGROUND  
1.1.  This document presents the status update concerning the recommendations proposed by the  
External Auditors  and implemented by the Secretariat  as of 21 February 202 2. Annex 1  presents a 
recap of the status and Annex 2 presents a list showing the status of resolution of recommendations 
i.e. pending closure  or ongoing.  
1.2.  On 10 December 2019, the General Council appointed the Cour des Comptes of France as 
External Auditors for a six -year mandate commencing with the financial year ending 
31 December  2020. 
1.3. In April and May 2022, the Cour des Comptes will  review  the recommendations it made in 
July 2021, as well as recommendations that were still pending from the previous External Auditors 
(the German  Bundesrechnungshof) . 
 
2  SUMMARY  OF RECOMMENDATIONS  
2.1.  The Cour de s Comptes  issued a total of 13 recommendations. 10 recommendations related to 
the Financial,  IT and Internal Control area s and 3 recommendat ions related to crisis management.  
2.2. A total of  11 reco mmendations are pending from 2019 and 2020  audits by 
the German  Bundesrechnungshof . 
2.3. The Secretariat has been working on the implementation of all the above recommendations.  
 
_______________  
 
 
 
 
 
 
  
  WT/BFA/W/5 79 
 
- 2 - ANNEX 1: STATUS OF AUDIT RECOMMENDATIONS AS OF 21 FEBRUARY 2022 
 
STATUS OF PAST AUDIT RECOMMENDATIONS AS OF 21 FEBRUARY 202 2 
Audit Activity  Report 
Year Total Number of 
Recommendations  Implementation status  
Closed1 To be closed2 Ongoing3 Open4 
Financial Audit of year end closed as of 31.12.2018  2019 6 5 1 0 0 
Performance Audit o f Human Resources  2019 14 9 2 3 0 
Financial Audit of year end closed as of 31.12.2019  2020 7 6 1 0 0 
Performance Audit o f Human Resources  2020 8 5 2 1 0 
Performance Audit o f Trust Funds  2020 7 5 2 0 0 
Financial Audit of year end closed as of 31.12.2020  2021 10 0 6 4 0 
Performance Audit o f Crisis Management  2021 3 0 0 3 0 
Grand Total    55 30 14 11 0 
55%  25%  20%  
 
 
  
 
1 Closed: Recommendation was implemented by the Secretariat and was validated by the External Auditor s. 
2 To be closed: Recommendation was implemented by the Secretariat following the last External Audit Report in September 202 1 and is to be reviewed and 
validated by the External Auditor s. 
3 Ongoing: Recommendation is accepted and under implementation by the Secretariat.  
  
  WT/BFA/W/5 79 
 
- 3 - ANNEX 2: ONGOING  AUDIT RECOMMENDATIONS AND THOSE TO BE CLOSED  (FEBRUARY 2022)  
No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
60 & 80 Accruals and 
provisions  3.3.1 / 2018  
(German Supreme 
Audit Court Audit)  
 
 
 
 
 
3.3.1 / 2019  
(German Supreme 
Audit Court Audit)  60. WTO should revise its potential risks related to 
disability cases in order to implement possible and 
effective mitigation measures to minimize such risks.  
 
I recommend that WTO should revise its potential risks 
related to disability cases in order to implement possible 
and effe ctive mitigation measures to minimize such risks.  
 
80. I recommend that WTO regularly revise its potential 
risks related to disability cases in order to implement 
possible and effective mitigation measures to minimize 
such risks. In this context, WTO shoul d consider possible 
improvements in insurance.  
  August 2020  to June 2021  
The Secretariat agrees to explore 
this recommendation.  
 
 
 
 
 
February  2022 
WTO has agreed an increase in 
non-medical insurance coverage to 
CHF 500,000/person per case  
starting the 1st of January 2022 . 
(An increase from the previous 
amount of  CHF 200,000).  To be 
closed  Medium  
62 Process 
description 
(HR) 4.1 / 2018  
(German Supreme 
Audit Court Audit)  The absence of process description may lead to a conflict 
of interest as well as limited transparency. This might 
cause unclear tasks and responsibilities. Furthermore, this 
always entails the risk of inefficient and ineffective 
processes as well as poor workflows. Additionally, in parts 
of the processes I detected interface problems, duplication 
of efforts, and redundant workflows. I appreciate that WTO 
already has carried out significant work in terms of process 
mapping and the development of Standard Operating 
Procedures (SOPs) as well as progress to avoid conflic t of 
interest. However, the final adjustments and decisions are 
still pending.  
 
I recommend that WTO finalize the process description 
soon to ensure a smooth workflow with a transparent and 
clear allocation of tasks and responsibilities. Therefore, the 
Human Resources Division should immediately define and 
harmonize the ownership of the processes and clarify the 
roles and responsibilities. On that basis, the Human 
Resources Division should coordinate the finalized process 
description internally with all pro cess participants. The 
consensual version of process descriptions should then be 
authorized accordingly.  June 2019  
Gaps were identified by a 
management consultancy firm in 
early 2018. To address these, the 
Secretariat initiated a project to 
put a robust H uman Resources 
Information System (HRIS) in 
place. Significant work was done, 
in collaboration with an external 
consultant, to map out current 
processes.  
In addition, there are "as -is" 
process workbooks for all HR 
processes indicating the 
tasks/steps, resp onsibilities and 
interactions required. 
Furthermore, the gaps identified by 
the external consultant resulted in 
recommendations to develop 
SOPs. This is in progress. The 
project is estimated to conclude in 
2020.  
 
 
 Ongoing  High   
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Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
October 2019  
HRD has started developing S OPs, 
several have already been finalized 
and the project should conclude in 
2020.  
 
February 2020  
Same as above  
 
August 2020  
The HRIS implementation began on 
10 August, with a scheduled 
completion date of Q2/Q3 2022. 
There are two phases to the 
project: Phase 1 includes HR Core, 
Absence, Compensation, Benefits, 
Recruitment, Reporting, whereas 
Phase  2 includes Learning and 
Development and Performance 
Management.  
The goal is for all HR processes to 
adapt as much as possible to the 
standard of what the HR system 
offers. Due to numerous changes 
to come in the configuration and 
design phase, Standard Operating 
Procedures will need to be 
continuously updated until the HR 
system is implemented.  
 
February 2021  
Ongoing, as detailed in the update 
as at August  2020.  
 
June 2021  
The implementation of this will be 
done subsequent to the 
implementation of HRIS in Q2/Q3 
2022.  
February 2022  
HRIS went live on 20 September 
2021. Phases 2 and 3 , are  
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- 5 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
scheduled for implementation in 
Q3 and Q4 of 2022. This will lead to 
the closure of  the 
recommendation . 
63 Personnel 
files 4.1 / 2018  
(German Supreme 
Audit Court Audit)  I recommend that WTO should implement clear 
instructions for the documentation of all staff related 
matters. These instructions should govern what kind of 
essential information shall be documented and in which 
form.  
 
Despite the high priority of this recommendation 
WTO is still working on it. I recommend that WTO 
should push the HRIS project to finally get results 
after two years.  June 2019 to February 2020  
Agreed. The Secretariat will finalize 
the necessary documentation by 
2020 as this is a component of the 
HRIS project.  
 
August 2020  to June 2021  
Concrete decisions on this matter 
will be made during the 
implementation of the HR IS, 
specifically the Design and 
Configuration stage, as it will be 
evident what types of 
documentation the Secretariat 
should have, as well as what the 
Secretariat can and will store 
within the worker profile in the HR 
system. From this point, the 
Secretariat would be able to decide 
to what extent it will be able to 
house all other types of essential 
documentation electronically – 
stored in SharePoint for example, 
or other secure location and 
eliminate the need to maintain 
physical/p aper files for employees.  
 
February  2022 
HRIS went live on 20 September 
2021. As a pre -requisite to 
migrating personnel files in HRIS , 
assurance of consistency of 
information was imperative. 
Therefore , the recommendation 
can be closed.  
 To be 
closed  High  
64 Personnel 
files 4.1 / 2018  
(German Supreme 
Audit Court Audit)  I recommend that WTO should prescribe a uniform and 
appropriate structure of the personnel files, paper and 
electronic files, as well as limited access rights.  June 2019  
Agreed. The Secretariat will 
develop clear guidelines related to Ongoing  High   
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- 6 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
 
Despite the high priority of this recommendation WTO is 
still working on it. I recommend that WTO should push the 
HRIS project to finally get resul ts after two years.  the documents that ought to be 
contained in the personnel files of 
staff members. This will also cover 
the assurance that the documents 
are maintained in the sam e format.  
 
October 2019  to February 2020  
HRD has started to develop clear 
guidelines and as such this 
recommendation is still in progress  
 
August 2020  to June 2021  
As per the Secretariat's Comments 
regarding recommendation 63, this 
will be a determination made 
during the implementation  of the 
HRIS. Other key aspects that will 
be covered during implementation 
are the access rights / security 
groups to be put in place. This will 
affect not only HR D or ITSD access 
to documentation and information  
within the HR IS, but will also relate 
to the establishment of a 
framework around access rights for 
all employees for areas in scope 
within the system.  
 
February 2022  
HRIS went live on 20 September 
2021. Phases 2 and 3 are 
scheduled for implementation in 
Q3 and Q4 of 2022.This will lead to 
the closure of  the 
recommendation . 
 
72 Accumulated 
annual leave  4.1 / 2018  
(German Supreme 
Audit Court Audit)  According to WTO, the applicable reference period is from 
1 May to 30 April. In fact, the 60 -day rule is not relevant 
as at 31 December and staff may accumulate up to 90 
days as at 31 December. WTO limited leave 
reimbursements to a maximum of 60  days at th e time of 
separation.  June 2019  
The WTO agrees to work towards 
aligning the leave cycle with the 
calendar year and to assess 
measures of governing untaken 
leave.  
 To be 
closed  Medium   
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- 7 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
Eight staff members had an excessive annual leave 
balance of 69 days as at 31 December 2018 (negative 
amount). In two out of the six cases the staff members are 
on special leave without pay. The negative balance of 
28 respective 9.5 d ays should be recuperated from the 
annual leave allocation after their returning in 2019. In five 
cases WTO granted advance leave day up to 10  days for 
family reasons, health and studies as well as preparation 
of retirement. WTO could not provide us with w ritten 
regulations concerning the granting of advance annual 
leave and refers to a "long-standing practice to grant up 
to 10 days exceptional circumstances ". In one case the 
excess leave days (5.5 days) were deducted from the final 
payment because of cessa tion of service.   
 
I recommend that WTO review the staff rules regarding 
the regulations for accumulating annual leave to ensure 
that risks in subsequent years will be reduced as well as to 
implement written regulations concerning the granting of 
advance a nnual leave. In this context WTO also should 
consider aligning  the applicable reference period with the 
calendar year. Furthermore, WTO should implement 
appropriate payment restrictions for untaken annual leave.   February 2020  
Same as above . 
 
August 2020  
Aligning the reference period with 
a calendar year has implications for 
staff membe rs from the Southern 
hemisphere who typically take 
leave from December to January. 
If, for example, excess leave was 
to be reduced in December of a 
given year, such reduction would 
disproportionately affect such staff.  
 
February 2021  
The DDG in charge of 
Administration has instructed all 
Division Directors to adhere to the 
relevant rules and policies relating 
to annual leave. Furthermore, HRD 
has informed staff , on a quarterly  
basis, that the 60-day limit will be 
strictly applied,  despite the  
exceptional circumstances 
surrounding the pandemic . 
 
June 2021  
The Secretariat considers this as 
having been implemented. In 
paragraph 16 of the report, the 
External Auditors wrote "The 
recommendation relating to annual 
leave including, in particular, a 
reorganisation of the practice of 
advance on leave entitlements is 
considered to be implemented. If it 
is actually implemented on some of 
the aspects mentioned by the 
External Auditor, it is not 
implemented on (a) the alignment 
of the leave period over the 
calendar year, (b) the issue of  
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- 8 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
advances on leave entitlements. 
On point (a) the Secretariat rightly 
points out the difficulty 
encountered by staff from the 
Southern hemisphere, when the 
leave period is based on the 
calendar year. Its refusal to 
implement this part of the 
recommendation is justified".  
 
The External Auditors further wrote 
"However, it does not provide any 
evidence documenting the 
withdrawal, or supervision of the 
practice of the advance on leave 
entitlements by a formal 
regulation. Since this aspect is 
significant, the external Auditor 
considers that the 
recommendation continues to be 
"in the process of implementation ".  
 
With reference to the paragraph 
immediately above, the Secretariat 
will prepare an official 
Memorandum to implement the 
recommendation.  
 
February  2022 
Workday has already incorporated 
a limit of five days of advance 
leave. An official memorandum will 
be sent to staff by the end of  
Q1 2022.  
73 Home leave  4.1 / 2018  
(German Supreme 
Audit Court Audit)  In my report from 31 May 2016 I recommended WTO to 
review the rules for HL, especially the calculation of the 
lump sum. In addition, I recommended WTO to consider 
the results and recommendations of the audit conducted 
by the Internal Audit (OIO) as well as its respective June 2019  
The Secretariat agrees and is in  the 
process of finalizing its review of 
the new Home Leave Policy.  
 On 
going   High   
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- 9 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
investigation re garding HL in 2016/2017. Even, OIO 
strongly had recommended to review and adjust the rules 
and guidelines for HL because of detected systemic 
problems and vulnerability to fraud in 2017.  
 
I strongly recommend that WTO should review the rules 
and guidelines  for HL as soon as possible. In this context 
WTO should consider the recommendations by OIO to 
bring the new rules and regulations in line with other 
comparable regulations of International Organizations 
(Benchmark) as well as to avoid excess payments and 
misconduct.  
 
Despite the high priority of this recommendation WTO is 
still working on it. I recommend that WTO should prioritize 
the implementing of a new Home Leave Policy to finally 
get results after five years.  October 2019  to February 2020  
A revised text of the Home Leave 
Policy has been elaborated by HRD 
and received input from the 
AGSD/Travel for its feasibility. The 
document is being finaliz ed. 
 
August 2020  
Two policies have been prepared in 
this regard. These are:  1. Home 
Leave and Family Visit Policy, 
which has been approved by the 
Directo r-General.  2. The 
Methodology for the Calculation of 
Benefits Pertaining to Home Leave, 
Family Visit, R ecruitment and 
Education Grant. This proposed 
revised policy will be submitted to 
the JAC for review by 
30 September 2020. The JAC will 
subsequently make 
recommendations on a revised text 
to the Director -General.  
 
February 2021  
The Methodology for the 
calculation of the benefits 
pertaining to Home Leave, Family 
Visit, Recruitment and Education 
Grant was updated based on the 
recommendations and it was 
incorporated into an updated 
Travel Policy that will be submitted 
in February 2021 for the Joint 
Advisory Committee (JAC)'s 
review. The JAC will subsequently 
make recommendations on a 
revised text to the Director 
General. The delay in the 
submission to the JAC is due to a 
more extensive exercise than 
anticipated being undertaken with 
the updated Travel Policy  
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- 10 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
consolidating and revisiting all 
existing travel policies.  
 
June 2021  
The updated Travel Policy was 
presented to JAC in April 2021 and 
several follow up meetings have 
been held for further clarifications. 
The JAC is currently wor king on 
recommendations on a revised text 
to be submitted to the Director 
General.  
 
February  2022 
The JAC had several exchange s 
with the Travel Unit  and Question 
& Answer sessions with the 
Director of AGSD  and the Travel 
Coordinator  for clarification o f the 
text as well as the implication of 
the consolidation of the various 
policies that are currently in force.   
 
On 22  February, the Chairma n 
responded as follows, to an email 
from the Director of AGSD, "On 
this, I can confirm that last year 
the JAC began  work on this policy, 
but it then had to stop to begin 
working on the … which we 
understood to be priorities.  Work is 
quite advanced and we expect that 
the recommendation … will be 
concluded soon so, unless the DG 
sets different priorities as part of 
the Se cretariat Review, we should 
soon revert to continue work on the 
Travel Policy."   
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- 11 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
79 Accruals and 
provisions  3.3.1 / 2019  
(German Supreme 
Audit Court Audit)  I recommend that WTO apply actuarial principles in future 
to determine its provisions considering the average age 
and health of the employees. In this context WTO should 
consider relevant methods for discounting and indexing in 
its calculations.  August 20 20 
The Secretariat agrees to revise 
the calculation of the disability case 
provision aligned with actuarial 
principles.  
 
February 2021  
Deliberations on and analysis of 
important elements pertaining to 
this issue are ongoing.  
 
June 2021  
The Secretariat agrees to apply the 
actuarial principles for the disability 
case provision as part of the 2021 
financial closing.  
February  2022 
The Secretariat has extended the 
scope of the contract of its 
Actuarial Company to perform the 
calculation of such type of 
provisions for the 2021 year -end 
closure.  To be 
closed  Medium  
84 Early 
retirement  4.1 / 2019  
(German Supreme 
Audit Court Audit)  I recommend that WTO may enter into a separate 
agreement with WTOPP due to compensation payments for 
early retirement. In this agreement WTO and WTOPP 
should determine an acceptable justification and a clear 
calculation as well as an applicable procedure i ncluding 
timelines and documentation.  August 2020  
The actuarial assumptions 
approved by the WTOPP Board 
already include estimates of "Early 
retirements".  Actuarial calculations 
are based on a number of actuarial 
assumptions. These actuarial 
assumptions are periodically 
reviewed by the WTOPP Board and 
adjusted in light of the actual 
experience. The Secretariat and 
the WTOPP agrees to explore 
potential condit ions for a separate 
agreement.  
 
February 2021  
The Secretariat is drafting 
proposed guidance on how and Ongoing  Medium   
  WT/BFA/W/5 79 
 
- 12 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
when compensation payments for 
early retirement will be activated 
for subsequent agreement with the 
WTOPP.  The guidelines will be 
finalized before 30 Ap ril 2021.  
 
June 2021  
An agreement between WTO and 
WTOPP covering compensation 
payments for early retirement has 
been drafted and is awaiting 
discussion and signature.  
February  2022 
The agreement is ready and should 
be signed by 31 March 202 2.  
91 Trust funds  4.2 / 2019  
(German Supreme 
Audit Court Audit)  I recommend that WTO critically review its trust fund 
landscape. As a result, WTO should develop a strategy to 
close trust funds without any activities in 2019 and to 
merge trust funds with similar purposes and donor 
structure. In this context, WTO may har monize main 
processes to better manage the trust funds like controlling, 
funding, and procurement in a separate unit to ensure 
consistency and transparency as well as full compliance 
with WTO Rules and Regulations.   August 2020  
The Secretariat agrees to c ritically 
review the trust fund landscape 
and develop a strategy to limit the 
proliferation of small funds as well 
as to assess closing trust funds 
which had no activity in 2019.  
 
February 2021  
The Secretariat is actively 
engaging its Members in a review 
of the trust fund landscape to 
ensure that its administrative 
practices align with Member s' 
expectations . This includes efforts 
to discourage the proliferation of 
small single purpose trust funds. 
The Secretariat agrees to closely 
monitor trust fund  activity and 
close or consolidate low activity 
funds on an annual basis.  We note 
that due to the global Covid -19 
pandemic, 2020 was an unusual 
year for trust fund activities and as 
a result some trust funds 
anticipated to finish their mandates 
in 2020 wi ll be extended into 2021.  To be 
closed High   
  WT/BFA/W/5 79 
 
- 13 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
June 2021  
A working group on trust funds has 
been set up by the CBFA. Several 
meetings have taken place and the 
aim is to submit a document at the 
CBFA in September/October 2021.  
 
February  2022  
The Working Group issued the 
document WT/BFA/W/551 on the 
Trust Fund Landscape. This 
document will pave the way for the 
Secretariat's revamped approach 
on Trust Fund Management, which 
will likely incorporate the aspects 
that the Auditor flagged.  
93 Trust funds  4.2 / 2019  
(German Supreme 
Audit Court Audit)  I recommend that WTO ensure that all procurement 
activities with higher amounts are subject to a harmonized 
and compliant procurement process to ensure transparent 
and standardized procedures and correct documentation 
as well as to ensure an appropriate value for money.  August 2020  
The Secretariat agrees to review 
the thresholds for procurement 
relating to trust funds.  
 
February 2021  
A robust policy to be developed in 
collaboration with multiple 
divisions with the Secretariat by 
31 October 2021.  
 
June 2021  
The timeline for the development 
of a Policy remains unchanged (by 
31 October 2021).  
February 2022 
The procurement extent of 
procurement by  Trust Funds 
showed that only about  2% of the 
expenses funded by Trust Funds 
fall relate to procurement of goods 
and services that would be 
undertaken through the WTO 
Procurement Section. Most of the 
expenditure of Trust Funds 
pertains to the implementation of To be 
closed  Medium   
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- 14 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
projects  and programmes through 
grants and other agreement 
modalities with implementing 
entities or parties in the field. Other 
expenses are in the nature of travel 
and accommodation for 
participants in technical assistance 
activities provided by the WTO to 
eligib le countries.  With this , the 
recommendation can be closed . 
1 Financial 
Audit, Finance 
and Budget  1.1./ 2020 
(French  Supreme 
Audit Court Audit)  During the preparation of the accounts for the financial 
year 2021, the external Auditor recommends strictly 
applying the IPSAS 1 §21 standard by presenting a 
comparison of the budgeted and actual executed amounts 
in the financial statements submitted for audit, either in 
the form of a separate additional statement, or in the form 
of a "budget " column in the financial statements.   June 2021  
The WTO Secretariat agrees to 
disclose additional information. It 
is to be noted that the budget 
versus actual expendi ture data is 
currently included in Section 2 - 
Regular Budget Performance. The 
WTO Secretariat will consider 
adding in the financial statements 
either a reference to Section 2 data 
or fully include the data together 
with other required information to 
fully comply with IPSAS  1. 
 
February  2022 
The Secretariat has shared a 
proposed format to disclose this 
additional information in the next 
Financial Statements with the 
Auditors.  
 
The Auditors have accepted this 
proposed format.  To be 
closed  High  
2 Financ ial 
Audit; 
Finance and 
Budget  1.1./ 2020 
(French Supreme 
Audit Court Audit)  During the preparation of the accounts for the financial 
year 2021, the External Auditor recommends strictly 
applying the policy provisions of paragraphs 127 and 128 
of the IPSAS 1 standard, in light of the practical 
recommendations of the IFRS, by setting out in the notes 
the details useful for understanding the financial 
statements and the complete information of the governing 
bodies combining factual explanations and figures.   June 2021  
The WTO Secretariat agrees to 
disclose additional information to 
provide further context to the 
readers of the financial statements. 
It is to  be noted that extensive 
information on expenditure split 
into various categories is already 
included in Section 2 Regular To be 
closed  High   
  WT/BFA/W/5 79 
 
- 15 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
Budget Performance. The WTO 
Secretariat will consider adding in 
the financial statements either a 
reference to Section 2 data or full y 
include the data together with 
other required information to fully 
comply with IPSAS 1.  
 
February 202 2 
The Secretariat has shared a 
proposed format to disclose this 
additional information in the next 
Financial Statements with the 
Auditors . 
 
The Auditors have accepted this 
proposed format.  
3 Financ ial 
Audit; 
Finance and 
Budget  1.1./ 2020 
(French Supreme 
Audit Court Audit)  During the preparation of the accounts for the financial 
year 2021, the external Auditor recommends including 
additional information in the financial statements in the 
form of a detailed reconciliation of budgetary elements 
with the net cash flows generated by operating, 
investment and financing activities.   June 2021  
The WTO Secretariat agrees to 
provide additional information in 
the financial statements regarding 
the reconciliation of the budget 
result with the net cash flows.  
 
February  2022 
The Secretariat has shared a 
proposed format to disclose this 
additional information in the next 
Financial Statements with the 
Auditors .  
 
The Auditors have accepted this 
proposed format . To be 
closed  High  
4 Financ ial 
Audit; 
Internal 
Controls  3.1./ 2020  
(French Supreme 
Audit Court Audit)  Before the end of the current financial year 2021, the 
External Auditor recommends finalising the "WTO 
Secretariat Internal Control Framework ": (i) by 
supplementing it with operational elements to ensure its 
control and efficiency (identification of key process 
managers, their responsi bilities, their accountability 
conditions, etc.); (ii) by establishing an appropriate 
system for the annual evaluation to support the letter of June 2021  
The WTO Secretari at agrees to 
finalize the current draft of the 
WTO Internal Control Framework 
by the end of the current financial 
year. The implementation of the 
Framework, including the 
identification of controls and their 
corresponding owners, will be Ongoing  High   
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- 16 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
representation relating to the internal control produced by 
the general management .  completed during t he next financial 
year as it falls under the 
responsibility of the Compliance, 
Risk and Resilience Officer, for 
which the recruitment is ongoing.  
 
February 2022  
The Internal Control Framework 
was submitted to the DGO  by the 
previous Chief of the Office of 
Internal Oversight , for review and 
approval . 
5 Financ ial 
Audit; 
Management 
IT systems  3.2./ 2020 
(French Supreme 
Audit Court Audit)  The External Auditor recommends implementing a 
business continuity plan aimed at operational availability 
of the procedures and actions of the business divisions in 
the event of a crisis directly or indirectly affecting IT 
resources, and provide for regular formalised tests to 
ensure its validity and effectiven ess over time.  June 2021  
The WTO Secretariat agrees with 
this recommendation. While 
currently there are various 
temporary solutions providing 
business continuity on critical IT 
solutions, Information Technology 
Solutions Division (ITSD) and 
Administration and General 
Services Division (AGSD) will start 
an initiative to develop the WTO 
Secretariat's business continuity 
management following ISO 
standards with the aim to have 
cross divisional capability 
prioritizing the business continuity 
of ke y business functions, known 
within the organization and fully 
tested. The plan for such a 
deliverable was presented to the 
DGO on Friday 25 June 2021. The 
guidance given is that a much 
wider business continuity 
management system is necessary. 
This work wil l be outsourced to 
companies with extensive and 
relevant experience, following the 
procurement rules of the WTO.  
 
 Ongoing  Medium    
  WT/BFA/W/5 79 
 
- 17 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
February 2022  
Terms of reference to engage an 
external supplier to help the 
Secretariat build comprehensive 
systems were drafted in 
December  2021. Senior 
management decided to include 
this effort within the structural 
review under an "Improve risk 
management" initiative. This 
initiative will be launched on 
21 February. ITSD and AGSD will 
be represented as part of the 
expert group worki ng on this 
initiative and will ensure the 
External Auditor's recommendation 
is fully considered . 
6 Financial 
Audit; 
Management 
IT Systems  3.2. / 2020  
(French Supreme 
Audit Court Audit)  The external Auditor recommends establishing a formal 
segregation of duties matrix to ensure (i) that the profiles 
defined during the implementation of Oracle EBS 
integrated management software comply with the 
principles of segregation of duties; (ii) reviewing this 
matrix annually; (iii ) conducting, on this basis, an 
exhaustive qualitative review of user accounts in order to 
ensure compliance with this matrix; (iv) identifying non -
compliant profiles and take the necessary corrective 
measures.   June 2021  
The WTO Secretariat agrees with 
this recommendation. ITSD and 
AGSD will work together on the 
implementation and monitoring of 
a segregation of duties matrix.  
 
February 2022  
ITSD is finalizing the matrix of 
existing roles and current 
functions. To be discussed with 
AGSD to identify incompatible 
functions and how to segregate if 
possible.  The deadline for this is  
the end of  Q2 2022.  
 Ongoing  Medium   
7 Financ ial 
Audit, 
Management 
IT Systems  3.2./ 2020 
(French Supreme 
Audit Court Audit)  The External Auditor recommends: (i) formalising the 
change management procedure on Oracle EBS integrated 
management software  and implementing a process to 
ensure that all changes put into production have been 
tested and validated, (ii) restricting authorised access to 
the development and production environment in the new 
formalised policy, (iii) at least, in the event that this  
segregation of duties is found to be unachievable for 
operational reasons, carrying out a hierarchical review of 
ex-post validation of changes at least on a quarterly basis.   June 2021  
ITSD will implement either of the 
following two procedures: a 
procedure for the application 
Branch Manager to review once a 
quarter the list of changes put into 
production including the tests and 
validation steps that accompanied 
them or inclusion of all chang es to 
Oracle OEBS put into production ongoing  Medium    
  WT/BFA/W/5 79 
 
- 18 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
within its existing change 
management procedure so that 
every change gets validated by its 
Change Advisory Board (CAB) 
before being implemented in 
production.  
 
February 2022  
ITSD is reviewing the existing 
internal chan ge management 
process in order to include these 
specific changes on Oracle EBS 
within the existing process.  
8 Financ ial 
Audit; 
Provisions  4.2./ 2020  
(French Supreme 
Audit Court Audit)  The external Auditor recommends implementing and 
documenting a comprehensive actuarial model for 
assessing the provisioning of future compensation costs 
for staff invalidity cases.   June 2021  
The WTO Secretariat agrees to 
adopt an actuarial model for the 
invalidity case provision.  
 
February 2022  
The Secretariat has extended the 
scope of the contract of its 
Actuarial Company to perform the 
calculation of such type of 
provisions for the 2021 year -end 
closure.  To be 
closed  Medium   
9 Financial 
Audit; HR 
data 
assumptions  4.2./ 2020 
(French Supreme 
Audit Court Audit)  The External Auditor recommends : (i) formalising the 
validation of data, assumptions used and methodology 
used by the actuary for the calculation of the pension plan 
and health insurance commit ments, and (ii) conducting 
sensitivity analyses for all critical assumptions considered 
(discount rate, in particular).  
 June 2021  
The WTO Secretariat agrees to 
prepare a document outlining the 
review procedures over the 
actuaries' inputs.  
 
February  2022 
A guideline document for the 
validation of data has been 
prepared by HRD. The 
recommendation will be 
implemented in the process for the 
finalization of the 2021 Financial 
Statements .  
 To be 
closed  Medium   
10 Financial 
Audit; 4.4./ 2020  The External Auditor recommends capitalising the 
receivables claimed by the WTO due to the June 2021  To be 
closed  High   
  WT/BFA/W/5 79 
 
- 19 - No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
Finance and 
Budget  (French Supreme 
Audit Court Audit)  reimbursements it makes to the Secretariat staff members  
chargeable to US income tax .  The WTO Secretariat will assess 
the prospect of fully recording the 
receivables that it claims due to the 
reimbursements it makes to the 
staff members chargeable to US 
taxes.  
 
February 2022  
Recommendation to be 
implemented in the process for the 
finalization of the 2021 Financial 
Statements . 
11 Performance 
Audit; Crisis 
Management  4.1./2020 
(French Supreme 
Audit Court Audit)  The External Auditor recommends submitting a proposal 
to the Ministerial Conference that, in the event of a major, 
unexpected and prolonged crisis , the Director -General be 
given the necessary special powers for the flexible and 
proactive management of the Secretariat, including the 
possibility of delegating powers to certain directors.  February  2022 
The WTO Secretariat Senior 
Management is assessing the 
appropriate manner in which to 
address the substantive aspects of 
this recommendation .   ongoing  High  
12 Performance 
Audit; Crisis 
Management  4.4./ 2020  
(French Supreme 
Audit Court Audit)  The External Auditor recommends finalizing, in accordance 
with future crisis management plans, a set of regulations 
to be submitted, depending on their particular nature and 
scope, to either the governing bodies or senior 
management for approval, so as to provide a framework 
for teleworking when major crisis  situations make it 
necessary. This set of texts specifically focused on crisis 
management should, in any event, form part of the overall 
legal framework for teleworking, which could possibly be 
renewed in the light of the experience gained during the 
COVID -19 pandemic.  February  2022 
The WTO Secretariat has shared 
with Senior Management proposals 
on how to address the 
recommendation.   Ongoing  High 
13 Performance 
Audit; Crisis 
Management  5.2./ 2020  
(French Supreme 
Audit Court Audit)  The External Auditor recommends formalizing the 
monitoring of the Organization's performance through 
quantified means and performance indicators. These 
indicators should be defined by each service and 
transmitted to the Financial Operations Directorate for  
consolidation. In the longer term, this monitoring could 
form the basis for an annual performance report separate 
from the Annual Report and the Financial Performance 
Report.  February 2022  
This recommendation has a 
corelation to the setting of 
strategic level objectives by the 
Organization. Therefore, it will be 
looked  into during  the fourth 
quarter of 2022.  Ongoing  High 
 
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