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WT/BFA/W/ 603 
 
5 September  2022 
(22-6601) Page: 1/13 
Committee on Budget, Finance and Administration    
 
 
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SECRETARIAT'S RESPONSES TO THE FOLLOW -UP TO OUTSTANDING  
RECOMMENDATIONS OF THE EXTERNAL AUDITORS  
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 31 July 2022. Annex 1 shows the status 
of addressing the recommendations that are still are not yet closed.  
1.2.  The External Auditors ( Cour des Comptes  of France ) conducted a financial audit in May 2022 , 
during which they also reviewed the status of implementation of recommendations from previous 
financial and performance audits.  
2  SUMMARY  OF RECOMMENDATIONS  
2.1.  In 2021 t he Cour de s Comptes  conducted a financial audit and a performance audit  subsequent 
to which they ma de 13 recommendations. 10 recommendations related to the financial audit and 
3 recommendations related to the performance audit on crisis management.  
2.2.  The Secretariat implemented 6 recommendations deriving from the financial audit and is 
working on implemen ting the 3 recommendations pertaining  to crisis management . 
2.3.  Concerning the recommendations from the audits conducted in 2019 and 2020 by the previous 
External Auditors (the  German Budgesrechnungshof ) the Secretariat implemented 
6 recommendations out of the 11 presented in the previous update. The Secretariat will keep on 
working on the remaining ones.  
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- 2 - ANNEX 1: ONGOING  AUDIT RECOMMENDATIONS AND THOSE TO BE CLOSED  (JULY  2022)  
No Issue  Reference: 
Chapter, Year  
end Recommendation  Secretariat response  Status  Priority  
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 enta ils 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 significa nt work in terms of process 
mapping and the development of Standard Operating 
Procedures (SOPs) as well as progress to avoid conflict of 
interest. However, the final adjustments and decisions are 
still pending.  
 
I recommend that WTO finalize the process de scription 
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 respo nsibilities. On that basis, the Human 
Resources Division should coordinate the finalized process 
description internally with all process participants. The 
consensual version of process descriptions should then be 
authorized accordingly.  June 2019  
Gaps wer e identified by a management 
consultancy firm in early 2018. To 
address these, the Secretariat initiated 
a project to put a robust Human 
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, 
responsibilities and interactions 
required. Furthermore, the gaps 
identified by the external consultant 
resulted in recommendati ons to develop 
SOPs. This is in progress. The project is 
estimated to conclude in 2020.  
 
October 2019  
HRD has started developing SOPs, 
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 
Develo pment and Performance 
Management.  Ongoing  High   
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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 scheduled for 
implementation in Q3 and Q4 of 
2022.This will lead to the closure of  the 
recommendation . 
July 2022  
Phase 2 of the HR IS project is scheduled 
for implementation before the end of the 
year. The completion of this phase  will 
close the recommendation.  
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.  
 
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  
Agreed. The Secretariat will develop 
clear guidelines related to 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 
same format.  
 
October 2019  to February 2020  
HRD has started to develop clear 
guidelines and as such this 
recommendation is still in progress . Ongoing  High   
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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 establishme nt 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 . 
July 2022  
Phase 2 of the HRIS project is scheduled 
for implementation before the end of the 
year. The completion of this phase will 
close the recommendation.  
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 
investigation regarding HL in 2016/2017. Even, OIO 
strongly had recommended to review and adjust the rules 
and guidelines for HL becau se 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 Internationa l Organizations June 2019  
The Secretariat agrees and is in the 
process of finalizing its review of the 
new Home Leave Policy.  
 
October 2019  to February 2020  
A revised text of the Home Leave Policy 
has been elaborated by HRD and 
received input fro m the AGSD/Travel for 
its feasibility. The document is being 
finalized.  
 
August 2020  
Two policies have been prepared in this 
regard. These are:  1. Home Leave and 
Family Visit Policy, which has been Ongoing  High   
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(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.  approved by the Directo r-General.  
2. The Methodology for t he Calculation 
of Benefits Pertaining to Home Leave, 
Family Visit, Recruitment 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 consolidating and revisiting all 
existing travel policies.  
 
June 2021  
The updated Travel Policy was 
presented to the JAC in April 2021 and 
several follow up meetings have been 
held for further clarifications. The JAC is 
currently working 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 a nd  
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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 of the 
JAC responded as follows, to an email 
from the Director of A GSD, "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 other policies  
which we understood to be 
priorities.  Work is quite advanced and 
we expect that the recommendation s on 
the other policies will be concluded soon 
so, unless the DG sets different 
priorities as part of the Secretariat 
Review, we should soon revert to 
continue work on the Travel Policy."  
 
July 2022  
The Secretariat notes the comments 
made by the External Auditors 
specifically with reference to 
paragraph  17 of their most recent follow 
up report to the recommendations. In 
this regard the Secretariat will aim to 
conclude on this before the next interim 
audit.  
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 
calcula tion as well as an applicable procedure including 
timelines and documentation.  August 2020  
The actuarial assumptions approved by 
the WTOPP Management 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 Management 
Board and adjusted in light of the actual 
experience. The Secretariat and the 
WTOPP agre es to explore potential 
conditions for a separate agreement.  
 Ongoing  Medium   
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February 2021  
The Secretariat is drafting proposed 
guidance on how and when 
compensation payments for early 
retirement will be activated for 
subsequent agreement with the WTOPP. 
The guidelines will be finalized before 
30 April 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 shoul d be 
signed by 31 March 2022 .  
July 2022  
Additional technical questions raised by 
the administration required another 
round of discussion with the WTOPP and 
the Legal Counsel to clarify the scope of 
the cases to be covered.  This revised 
version of an agreement is being 
considered for final review by the 
WTOPP Manage ment Board , with 
finalization foreseen in Q4 of 2022.  
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 o f the trust fund 
landscape to ensure that its 
administrative practices align with Ongoing  High   
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Members' expectations. This includes 
efforts to discourage the proliferation of 
small single purpose trust funds. The 
Secretariat agrees to closely monitor 
trust fund activit y 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 will be 
extended into 2021.  
 
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/B FA/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.  
July 2022  
The recommendation  is being addressed 
as part of the ongoing performance 
audit of trust funds.  
2 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 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 pro vide 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 Budget 
Performance. The WTO Secretariat will Ongoing  High   
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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 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.  
July 2022  
In the next year's Financial Statements, 
the Secretariat will extend the narrative 
of the tables of the notes to the Finan cial 
Statements to provide additional 
context and explanation of the financial 
data reported.  
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 responsibilities, their accountability 
conditions, etc.); (ii) by establishing an appropriate 
system for the annual evaluation to support the letter of 
representation relating to the internal control produced by 
the general management.   June 2021  
The WTO S ecretariat 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 
completed during the 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 Of fice of Internal Oversight , 
for review and approval . 
July 2022  
The newly appointed Head of the Office 
of Internal Oversight (as at June 2022)  Ongoing  High   
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is providing input, which will allow t he 
WTO Secretariat to assess the 
appropriate manner to address the 
substantive aspects of this 
recommendation.  
5 Financial 
Audit; 
Management 
IT systems  3.2./ 2020  
(French Supreme 
Audit Court Audit)  The External Auditor recommends implementing a 
business continui ty 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 effectiveness 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 key 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 will be 
outsourced to companies with extens ive 
and relevant experience, following the 
procurement rules of the WTO.  
 
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 
working on this initiative and will ensure Ongoin g Medium   
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the External Auditor's recommendation 
is fully considered . 
July 2022  
The Secretariat acknowledges the 
comments of the Auditors on this 
pending recommendation and will 
prioritize the implementation , 
progressing on the initiative described in 
February 2022 . 
7 Financial 
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 procedur e 
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 changes to 
Oracle OEBS put into production 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 
change management process in order to 
include these specific c hanges on Oracle 
EBS within the existing process.  
July 2022  
ITSD wrote a  formal procedure  on 
change management in Oracle EBS and 
shared it with the Auditors.  The auditors 
will check in November  2022 how the 
procedure is applied before closing the 
recommend ation. Open Medium   
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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.  
 
July 2022  
Since the last Secretariat response to 
the recommendations of the External 
Auditors, the Transformation Office 
within the Secretariat and the 
transformation Steering Committee 
composed of top management have 
conducted extensive work on risk 
management prac tices and are issuing 
several items for 
implementation.   Given that action, the 
Secretariat is considering how to 
address the External Auditor's 
recommendation within the context of 
that work on risk management and 
seeks to develop a comprehensive 
approach  in light of the various steps to 
be taken on those topics.  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.   
July 2022  
The WTO Transformation Office is 
actively working on the Risk 
Management practices at the WTO. 
Given the close link between the risk 
and crisis management, the WTO 
Secretariat will take a comprehensive 
approach to both the risk and crisis 
management.   Ongo ing High  
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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 Financ ial Performance 
Report.  February 2022  
This recommendation has a cor relation 
to the setting of strategic level 
objectives by the Organization. 
Therefore, it will be looked into during 
the fourth quarter of 2022.  
 
July 2022  
Same as above . Ongoing  High 
 
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