Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package) June 2003 (updated May 2015) The Secretary Department of Treasury and Finance 1 Treasury Place Melbourne Victoria 3002 Australia Telephone: +61 3 9651 5111 Facsimile: +61 3 9651 2062 dtf.vic.gov.au Authorised by the Victorian Government 1 Treasury Place, Melbourne, 3002 © State of Victoria 2014 This work is licensed under a Creative Commons Attribution 3.0 Australia licence. You are free to re-use the work under that licence, on the condition that you credit the State of Victoria as author. The licence does not apply to any images, photographs or branding, including the Victorian Coat of Arms, the Victorian Government logo and the Department of Treasury and Finance logo. Copyright queries may be directed to IPpolicy@dtf.vic.gov.au ISBN 978-1-922222-26-8 (pdf) Published May 2015. If you would like to receive this publication in an accessible format please email information@dtf.vic.gov.au This document is also available in Word and PDF format at dtf.vic.gov.au Contents 1. Introduction .................................................................................................... 1 1.1 Preliminary ...................................................................................................................................1 1.2 Background ..................................................................................................................................3 2. Financial management governance and oversight .......................................... 5 2.1 2.2 2.3 2.4 2.5 2.6 3. Financial code of practice ............................................................................................................5 Financial governance ...................................................................................................................6 Financial risk management ........................................................................................................14 Authorisations............................................................................................................................16 Internal audit .............................................................................................................................19 External audit .............................................................................................................................21 Financial management structure, systems, policies and procedures ............. 23 3.1 Financial management structure ...............................................................................................23 3.1.1 Public sector agency financial management team structure .......................................23 3.1.2 Chief Finance and Accounting Officer (CFAO) ..............................................................24 3.1.3 Policies and procedures................................................................................................24 3.1.4 Chart of accounts..........................................................................................................25 3.1.5 Managing outsourced financial services ......................................................................26 3.2 Information technology systems ...............................................................................................27 3.2.1 Information technology management .........................................................................27 3.2.2 Information technology operations .............................................................................28 3.2.3 Security .........................................................................................................................29 3.2.4 Development ................................................................................................................29 3.2.5 Change control .............................................................................................................30 3.3 Education and training ...............................................................................................................30 3.4 Policies and procedures .............................................................................................................31 3.4.1 Revenue ........................................................................................................................31 3.4.2 Cash handling ...............................................................................................................33 3.4.3 Bank accounts...............................................................................................................34 3.4.4 Cash flow forecasting ...................................................................................................35 3.4.5 Procurement .................................................................................................................36 3.4.6 Expenditure ..................................................................................................................37 3.4.7 Employee costs .............................................................................................................38 3.4.8 Commission on employee payroll deductions .............................................................39 3.4.9 Physical and intangible assets ......................................................................................40 3.4.10 Liabilities 41 3.4.11 Reconciliations..............................................................................................................42 3.4.12 Administration of discretionary financial benefits .......................................................42 3.4.13 Information collection and management.....................................................................44 4. Financial management reporting .................................................................. 47 4.1 Internal financial management reporting..................................................................................47 4.2 Reporting requirements in terms of Part 7 of the FMA.............................................................48 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) i 4.3 Other external reporting............................................................................................................51 4.4 Financial performance management and evaluation ................................................................51 4.5 Financial management compliance obligations ........................................................................52 4.5.1 Compliance with Directions..........................................................................................52 4.5.2 Taxation ........................................................................................................................53 4.5.3 Purchasing card ............................................................................................................54 4.5.4 Thefts and losses ..........................................................................................................55 4.5.5 Risk management framework and processes...............................................................56 4.5.6 Treasury risk management ...........................................................................................57 4.5.7 Foreign exchange risk management.............................................................................59 4.5.8 Commodity risk management ......................................................................................60 ii Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 1. Introduction The Standing Ministerial Directions (the Directions) are given pursuant to section 8 of the Financial Management Act 1994 (FMA). They have legislative force and must be complied with. 1.1 Preliminary Direction – Purpose and application The Directions support the FMA by specifying matters that must be complied with by Government Departments and public bodies to: implement and maintain appropriate financial management practices; and achieve a consistent standard of accountability and financial reporting. The Directions specify high-level requirements for financial management. This allows Government Departments and public bodies to develop specific systems, procedures and compliance practices, which must be: tailored to their own situation; and approved and monitored within their own governance requirements. For the purposes of these Directions, Government Departments and public bodies are collectively termed ‘Public Sector Agencies’. Those parts of this document that are of binding legal effect are those parts under the headings ‘Directions’ and ‘Procedure’. The remaining parts are advisory in nature and provide guidance in best practice. Direction – Date of effect The Directions came into force on 1 July 2003. Until 1 January 2004 a public sector agency was exempt from full compliance with the Directions in Part 2 if it was in good faith complying with each of those Directions to the greatest extent reasonably possible. Direction – Definitions ‘Accountable Officer’ has the same meaning as in section 3 of the FMA. ‘Business Rules’ are the rules made by the Deputy Secretary, Budget and Financial Management, Department of Treasury and Finance. ‘Directions’ mean these Standing Directions. ‘Financial Reporting Directions’ are directions given by the Minister for Finance for the accounting treatment and reporting of financial transactions. ‘Government Department’ has the same meaning as ‘Department’ as defined in section 3 of the FMA. ‘Public sector agency’ means any public body as defined in section 3 of the FMA or any Government Department. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 1 ‘Responsible Body’ means for a: government department, the Accountable Officer; and every other public sector agency, the board In the event that a person or body is declared to be an authority for the purposes of the definition of ‘authority’ in section 3 of the FMA, anything in these Directions applying or referring to a Government Department applies or refers also to that person or body, unless a Direction explicitly provides otherwise. Direction – Abbreviations ‘AASB’ means Australian Accounting Standards Board. ‘ATO’ means Australian Taxation Office. ‘BFMG’ means the Budget and Financial Management Guide. ‘CFAO’ means Chief Finance and Accounting Officer. ‘CFO’ means Chief Finance and Accounting Officer. ‘DTF’ means the Department of Treasury and Finance. ‘FBT’ means Fringe Benefits Tax. ‘FMA’ means the Financial Management Act 1994. ‘FRD’ means Financial Reporting Directions. ‘GST’ means Goods and Services Tax. Direction – Delegation a) Pursuant to section 7 of the FMA, the Minister for Finance delegates to the Deputy Secretary, Budget and Financial Management in DTF all relevant powers and functions of the Minister in sections 8, 50 and 51 of the FMA as necessary for the Deputy Secretary to: give Financial Reporting Directions; make Business Rules; determine the rate of commission payable in respect of payroll deductions for health insurance (except in the case of Medibank); STIPULATE the form of the Model Financial Report referred to in Direction 4.2; require all Public Sector Agencies to include in the reports required by part 7 of the FMA or by these Directions details relating to particular matters or things (whether in doing so the Deputy Secretary is exercising the powers and functions in sections 8, 50 or 51 of the FMA); provided that those Directions, rules or requirements are not inconsistent with anything in these Directions, and Exercise any power referred to in section 41A of the Interpretation of Legislation Act 1984 in respect of any Financial Reporting Direction, Business Rule, determination, stipulation or requirement. b) At least annually, a Financial Reporting Direction will be given stipulating which Australian accounting standards (AAS’s and AASB standards) and Urgent Issues Group Consensus Views are applicable for a particular reporting period. 2 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) c) Pursuant to section 7 of the FMA, the Minister for Finance delegates to each Accountable Officer all relevant powers and functions of the Minister in section 8 of the FMA as necessary for the Accountable Officer to determine the rate of commission payable in respect of voluntary deductions other than for health insurance. Direction – Exemptions The Minister for Finance may by written direction exempt persons or things, or a class of persons or things in a specified case or class of case, from the provisions of the Directions, whether unconditionally or on specified conditions or conditions additionally imposed and either wholly or to such an extent as is specified or otherwise determined. Where an exemption is sought, the application for exemption must be in writing, state the reasons why the exemption is necessary and include specification of proposed alternative action or procedures. Alternative action or procedures must not be implemented until approved by the Minister for Finance. Each Accountable Officer must maintain a register of exemptions granted by the Minister for Finance and make the register available for inspection by the Auditor-General. Exemptions will be evaluated on a case-by-case basis by DTF. Further information on Exemptions can be located on the Department of Treasury and Finance website (http://dtf.vic.gov.au). Only agencies that are connected to the Victorian Government common virtual private network can access this site. Please contact your portfolio coordinator directly if you have problems with access. 1.2 Background Structure of the Directions The Directions have been drafted in consideration of leading edge financial management practices. The Directions are now based around three key components of sound financial management as illustrated below. Key components of leading edge financial management Financial management governance and oversight Financial management structure, systems, policies and procedures Financial management reporting Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 3 Financial management governance and oversight Governance is about the processes by which a public sector agency is directed, controlled and held to account. The Directions on financial management governance and oversight set standards for Public Sector Agencies, which should be incorporated as fundamental elements in an overall governance framework. Financial management structure, systems, policies and procedures The Directions for financial management structure, systems, policies and procedures set standards for all Public Sector Agencies to achieve sound systems of internal control to support financial management. Financial management reporting The Directions for financial management reporting set standards for Public Sector Agencies to assist them in measuring and managing performance and to ensure financial management reporting is consistent with applicable statutory reporting obligations. Presentation of each Direction Each Standing Direction is comprised of the following: Background – (where relevant) this is an explanatory section, which seeks to provide the user with an understanding of the compliance obligation; Direction – A statement which sets out the compliance obligation (this is mandatory in nature); Procedure – this sets out the method of achieving the compliance obligation and is mandatory in nature; and Guidelines – these serve to explain and clarify the underlying principles and objectives of the Direction and provide any relevant information to enable the user to interpret the requirements in the correct context. The Guidelines are not mandatory in application and are to be used as reference only. Further supplementary material – where appropriate. This information can be found on the Department of Treasury and Finance website (http://dtf.vic.gov.au). Please contact your portfolio coordinator directly if you have problems with access. This supplementary material in the Directions is denoted by the following symbol . This was previously referred to as ‘Guidance Material’. The supplementary material is not mandatory in application and is to be used as reference only. Rules – these serve to explain and clarify the underlying principles and objectives of specific Directions and is denoted by the following symbol . They also enable the user to interpret the requirements in the correct context. Rules are to be used in assessing compliance with specific Directions. 4 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 2. Financial management governance and oversight ‘Broadly speaking, corporate governance generally refers to the processes by which organisations are directed, controlled and held to account’1, and is underpinned by principles of openness, integrity and accountability. ‘Governance is concerned with structures and processes for decision-making, accountability, control and behaviour at the top of organisations’2. ‘It influences how the objectives of an organisation are set and achieved, how risk is monitored and assessed and how performance is optimised.’3 Strong governance and oversight of a public sector agency’s financial management is a core component of its broader governance framework. The Directions on financial management governance and oversight have been prepared in light of the principles of good corporate governance and best practice recommendations for listed companies and in line with community expectations, which set a necessarily high standard for Public Sector Agencies. 2.1 Financial code of practice Background Public sector agencies are expected to develop and implement a financial code of practice on matters related to the probity of their financial management. The code of practice will be public sector agency specific and will reflect existing public sector agency policies. It will also alert or serve to remind personnel of the relevant external requirements applicable to the public sector agency. Direction Public sector agencies must implement and maintain a financial code of practice. Procedure a) A public sector agency is required to have a financial code of practice setting out a cohesive statement of the public sector agency’s internal processes to ensure probity in the public sector agency’s financial management. If the public sector agency has an existing Code of Practice, this will need to be reviewed against the requirements in this Direction and updated as required to ensure compliance. 1 ANAO Discussion Paper, Corporate Governance in Commonwealth Authorities and Companies, 1999 2 IFAC, Governance in the Public Sector: A Governing Body Perspective, 2001 3 ASX Corporate Governance Council, Principles of Good Corporate Governance and Best Practice Recommendations, March 2003 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 5 b) Matters to be covered in the financial code of practice include: Independence; Tendering; Procurement; Conflicts of interest; Use of credit cards; Personal relationships with the public sector agency’s customers and providers; Integrity; Accountability; Corporate opportunities; Confidentiality; Fair dealing; Protection and proper use of the public sector agency’s assets; and Encouraging the reporting of unlawful or unethical behaviour. c) Each public sector agency is required to develop and maintain an appropriate internal management structure with responsibility for: Implementing the code of practice; Determining the employees required to comply with the code of practice (‘relevant employees’) and reviewing this on an annual basis; Communicating the requirements to all relevant employees and the initial management of any queries raised by those employees; Requiring and monitoring relevant employees’ compliance with the code of practice; and Initiating appropriate action for breaches of the code of practice. 2.2 Financial governance Direction A public sector agency must establish robust and transparent financial governance policies and procedures directed to the oversight of its financial management which should be incorporated as fundamental elements of a public sector agency’s overall governance framework. Particular attention must be paid to the systems of financial reporting, risk management, internal control and the adequacy of management reporting. Procedure a) The governance and oversight of the financial management of a public sector agency is the responsibility of the Responsible Body. 6 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) b) The Responsible Body, in its financial oversight and governance role is to: review all financial reports that are provided to parties external to the public sector agency, prior to their release but subsequent to the approval of the reports by the CFAO in accordance with Direction 4.3(c); work with management to develop the strategic directions for the public sector agency, set performance indicators, set performance targets, review performance management information and reports against those targets; monitor and oversee the financial performance of the public sector agency on an ongoing basis ensuring appropriate human and financial resources are available; oversee and ensure that procedures are in place that will result in effective and efficient budgeting; ensure a balance of authority so that no single individual has unfettered powers over the finances of the public sector agency; ratify the appointment or removal of the CFAO, where appropriate; Review, ratify and oversee the public sector agency’s systems of risk management and financial internal controls; approve and monitor the progress of major capital expenditure, capital management, acquisitions and divestitures; meet often enough to undertake its financial governance role effectively, if it comprises more than one person; establish appropriate arrangements to ensure that public funds and resources are used economically, efficiently, effectively, with due propriety, and in accordance with the statutory or other authorities that govern their use; and undertake an annual review of its own performance in respect of its financial governance. see Guideline 1 below c) The Responsible Body may, at its sole discretion, formally delegate some of its responsibilities as set out in (b) to an Audit Committee, Finance Committee or equivalent. However: this will not diminish the ultimate responsibility of the Responsible Body to oversee the financial performance of the public sector agency and to ensure the integrity of the financial reporting; and the Responsible Body is to retain oversight responsibility for the relevant actions and activities of its delegates. d) For public sector agencies (excluding government departments), on an annual basis the Accountable Officer and the CFAO should formally state to the Responsible Body that: the public sector agency’s financial reports present fairly, in all material respects, of the public sector agency’s financial condition and operational results in accordance with the requirements of the FMA including the Directions; the financial report is founded on a sound system of risk management and internal compliance and control which implements the policies adopted by the Responsible Body; and the public sector agency’s risk management and internal compliance and control system is operating efficiently and effectively in all material respects. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 7 Audit committees e) Each public sector agency must, unless an exemption has been obtained, appoint an audit committee to oversee and advise the public sector agency on matters of accountability and internal control affecting the operations of the public sector agency. Government departments are not eligible for an exemption. see Guideline 2 below f) At least two members of the audit committee must be independent and these members are to be identified as independent in the public sector agency’s annual report. see Guideline 3 below g) Where the Responsible Body is a board the audit committee is to be comprised of at least three members all of whom are non-executive directors and a majority of whom are to be independent. h) If the Responsible Body is supported in its financial management responsibilities by an audit committee and/or any other committee: the committee should have a Charter that clearly sets out the role and responsibilities, composition, structure and membership requirements; the Charter must be approved by the Responsible Body and provided to each member of the committee; and the Charter must be formally reviewed by the Audit Committee periodically, but at least every three years, with recommendations for updates approved by the Responsible Body. i) Each committee is to: be adequately resourced; be of sufficient size, independence and technical expertise to discharge its mandate effectively; undertake an annual review of its own performance and report the results of that review to the Responsible Body; be fully accountable to the Responsible Body; meet often enough to discharge its role and responsibilities effectively and no less than four times a year; and minute the meetings reflecting work done by the committee to address its roles and discharge its responsibilities. The minutes are to be provided to the Responsible Body at the next meeting or, where the Responsible Body is not a board, a defined and agreed interval, after each audit committee meeting. see Guideline 4 below j) Where the Responsible Body has been exempted from creating an audit committee the Responsible Body must: actively assume all the usual roles and responsibilities of an audit committee including those responsibilities specifically set out in these Directions; and take appropriate steps to ensure these responsibilities are fully discharged. see Guideline 5 below 8 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) k) The Accountable Officer and the CFAO are not to be members of their own public sector agency’s audit committee but are to attend relevant aspects of audit committee meetings by standing invitation. l) Unless an exemption has been obtained the Chairperson of the audit committee is to be one of the independent members of that committee. m) Unless an exemption has been obtained the Chairperson of the Responsible Body must not also be the Chairperson of the audit committee. Member qualifications of audit committees n) All members of a public sector agency audit committee must have and maintain: basic financial literacy; reasonable knowledge of the public sector agency’s own risks and controls; integrity, objectivity, accountability, honesty and openness; dedication of time and effort; an enquiring mind; independence of judgement; relevant industry knowledge; and business experience in the public or private sector. see Guideline 6 below o) Members of an audit committee who do not have the requisite level of financial literacy and/or industry knowledge at the time of their appointment must undertake induction training before attending an audit committee meeting and additional training, as appropriate, to raise their competency to the level described in (n) above. As a minimum requirement the prescribed level of competence must be achieved within the first six months of membership of that committee. p) At least one member of an audit committee must have appropriate expertise in financial accounting or auditing. see Guideline 7 below q) All members of audit committees are required to take appropriate and timely action to ensure they have the requisite understanding of the public sector agency’s structure, operations and financial management risks to enable them to discharge their responsibilities. r) The CFAO is to provide all newly appointed Audit Committee members with all necessary and relevant information regarding the Committee’s responsibilities and the public sector agency’s operations and background to enable them to understand the public sector agency and their duties and responsibilities. The CFAO is to agree which information is necessary and relevant with the Audit Committee Chairman. s) Membership of the audit committee is to be reviewed by the Responsible Body on a periodic basis, and at least every three years. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 9 Relationship of audit committee with management, advisors and experts t) The audit committee must have direct access to the internal and external auditors without management present. u) The audit committee must have: Direct access to the Accountable Officer, the CFAO and the public sector agency’s management, through the Accountable Officer, when required; and The right to seek explanations and additional information. v) The audit committee must be able to seek independent, expert advice to assist it in undertaking its oversight responsibilities. Requirements for government departments w) For government departments, on an annual basis the CFAO should formally state to the audit committee and the Accountable Officer that: the financial reports present fairly, in all material respects, of the public sector agency’s financial condition and operational results in accordance with the requirements of the FMA including the Directions; the financial report is founded on a sound system of risk management and internal compliance and control which implements the policies adopted by the Accountable Officer (as Responsible Body); and the Department’s risk management and internal compliance and control system is operating efficiently and effectively in all material respects. x) Government departments are required to monitor and report to the Minister for Finance, through the Department of Treasury and Finance, on their compliance with the requirements of the FMA and the Directions. y) Government departments are required to obtain and report to the Minister for Finance, through the Department of Treasury and Finance, on compliance with the requirements of the FMA and the Directions of all public sector agencies within their portfolio. z) Each government department must endeavour to identify instances of non-compliance with taxation legislation by itself or a public sector agency within their portfolio and it must inform the Minister for Finance, through the Department of Treasury and Finance, of instances of non-compliance so identified. see Guideline 8 below Guidelines Guideline 1 i. External financial reports reviewed by the Responsible Body will typically include: annual budgets, forward estimates and forecasts; and other related reports, in particular significant financial reporting to external parties including other Public Sector Agencies. 10 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) ii. It is recommended that the Responsible Body’s oversight of a public sector agency’s financial performance be based on periodic financial information and associated performance indicators. In discharging its responsibilities it is anticipated that the Responsible Body will: monitor performance against targets incorporated into budget papers, business plans, targets, forecasts and similar; make appropriate enquiries to understand the reasons and implications for divergences between actual and expected performance; ensure it has sufficient information to assess management initiatives, to correct or mitigate unfavourable results and to reinforce or enhance favourable results; approve and monitor management’s actions to correct or mitigate unfavourable results; and review and authorise the release of financial information to ensure it: – is factual; – does not omit material information; and – is expressed in a clear, balanced and objective manner that allows stakeholders to assess the impact of the information on their decision-making. iii. It is recommended that where the Responsible Body has a Charter or equivalent document, it should clearly articulate the role of the Responsible Body and the responsibility and accountability relationships between the Minister, the Responsible Body, the Accountable Officer and the CFAO in financial management. iv. There is nothing in these Directions that prevents the operational aspects of the Responsible Body’s oversight and governance role being delegated to management in accordance with Direction 2.4. Guideline 2 i. An audit committee may be a committee of the Responsible Body or be appointed by the Responsible Body to undertake, among other functions, the oversight of: financial performance; the financial reporting process; the scope of work, performance and independence of the internal auditor; ratification of the engagement and dismissal by management of any chief internal audit executive; the scope of work and performance of the external auditor; the operation and implementation of the risk management framework; matters of accountability and internal control affecting the operations of the public sector agency; The effectiveness of management information systems and other systems of internal control; the acceptability, disclosure of and correct accounting treatment for significant transactions which are not part of the public sector agency’s normal course of business; Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 11 the sign-off of accounting policies; and the specific matters to which it is required to direct its attention as set out in 2.3 Financial Risk Management, 2.5 Internal Audit and 2.6 External Audit. ii. The role may, at the public sector agency’s discretion, be extended to cover other matters appropriate for the consideration of such a committee. Guideline 3 i. With respect to committees, an independent person is one who is independent of the management of the public sector agency, and: within the last three years has not been employed in an executive capacity by the public sector agency or a related organisation or been a director after ceasing to hold such employment; within the last three years, has not been a principal of a material professional advisor or a material consultant to the public sector agency or a related organisation, or an employee materially associated with the service provider; is not a material supplier or customer of, the public sector agency, or a related organisation or an officer or otherwise directly or indirectly associated with a material supplier or customer; has no material contractual relationship with the public sector agency or a related organisation other than as committee member of the public sector agency; has not served on the Responsible Body (if it is a board) or the committee for a period which could, or could reasonably be perceived to materially interfere with the person’s ability to act in the best interests of the public sector agency; and is free from any interest and any business or other relationship which could, or could reasonably be perceived to, materially interfere with the committee member’s ability to act in the best interests of the public sector agency. ii. Family ties and cross-directorships may be relevant in considering interests and relationships which may compromise independence. iii. In the context of these guidelines ‘materiality’ should be considered from the perspectives of both the public sector agency and the individual committee member/candidates. Guideline 4 i. The role and responsibilities of each committee is to be set out in its Charter and should be: sufficiently detailed to ensure there is: – no ambiguity; – clear guidance on key aspects of the committee’s operations; and – no overlap in the activities of individual committees. regularly reviewed for relevance and consistency with the needs of the Responsible Body. 12 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) ii. In addition: an annual programme is to be prepared detailing the number, date, time and key matters for attention at each meeting; agendas and papers should be prepared and circulated in advance of each Committee meeting and in sufficient time for members of the committee to read and absorb their contents; and committee members should undertake an annual evaluation of the performance of the Committee and report their conclusions to the Responsible Body. Guideline 5 Where an exemption to create an audit committee has been granted, the Responsible Body itself should actively seek to evidence the discharge of all the public sector agency’s financial oversight and governance obligations. Meeting the requirements of this Direction may include the Responsible Body meeting specifically in a separate meeting to address financial management issues. Guideline 6 With respect to the qualifications of members of the audit committee: i. Basic financial literacy is defined as the ability to read and understand financial statements, including financial statements, including the income statement, balance sheet, statement of recognised income and expense and cash flow statement. This may also include an understanding of the following, where a public sector agency is subject to their impact: generally accepted accounting principles (GAAP); Financial Reporting Directions; budget memoranda; and Budget and Financial Management Guide (BFMG) published by the Department of Treasury and Finance. ii. All Audit Committee members should have access to updated copies of the above material and undertake periodic financial reporting and other relevant updates/training to ensure they stay current as to relevant developments in accounting and finance within the public sector agency. Guideline 7 Appropriate expertise may have been developed from one or a combination of: relevant past employment experience in an accounting profession; Requisite professional qualification in accounting; or comparable experience with financial oversight responsibilities. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 13 Guideline 8 The Department of Treasury and Finance will provide detailed in Taxation Compliance Rules to assist public sector agencies to meet their compliance obligations in relation to: Australian Business Number (ABN); Goods and Services Tax (GST); Pay As You Go (PAYG); Fringe Benefits Tax (FBT); Deductible Gift Recipient (DGR); Income Tax Exempt Charity (ITEC); and Energy Credits Scheme. Each Public sector agency is accountable for meeting its Commonwealth tax obligations in its own right. More information on the Taxation Compliance Rules can be found on the Department of Treasury and Finance website at http://dtf.vic.gov.au 2.3 Financial risk management Background Enterprise-wide risk management establishes processes for identifying, analysing, monitoring and managing these risks and opportunities which could prevent a public sector agency from achieving its business objectives. It includes making links between risks and rewards and resource priorities. Risk management involves putting control activities in place to manage risk and opportunities throughout the public sector agency by developing risk management plans which cover the full range of a public sector agency’s activities including its financial management. This Direction assumes that a public sector agency has taken appropriate steps to introduce an approach to enterprise-wide risk management that is appropriate to the public sector agency and requires that a sufficient level of attention be given to the risks associated with its financial management. Direction An effective approach for the identification, assessment, monitoring and management of financial management risks must be established and maintained as part of the public sector agency’s overall risk management framework. Procedure a) The Responsible Body must: ensure there is a financial risk management policy and internal control system in place which addresses the risks associated with the financial management of the public sector agency and which clearly articulates the public sector agency’s expectations and internal accountabilities for management of those risks including the roles and respective accountabilities of the Responsible Body, audit committee, management and internal audit; 14 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) ensure management has implemented an effective framework to proactively identify, assess, monitor, manage and report, on an ongoing basis, the significant financial risks to which the public sector agency is exposed to as a result of, and in the course of its activities and responsibilities; have a clear understanding of the nature, likely impact and potential consequences of the significant financial management and related risks facing the public sector agency and be informed of any significant changes in these; on a regular basis and no less than annually, critically appraise and challenge the financial risk profile prepared by management to enable it to make an informed assessment about its completeness and accuracy and the appropriateness of the arrangements in place for managing and monitoring those risks; provide clear guidance on the level and categories of financial management risk it regards as acceptable for the public sector agency; provide oversight and supervision of financial management risks and the implementation of the related management plans/treatment strategies; and regularly, and no less than annually, review the effectiveness of the public sector agency’s system of risk management and internal control. b) A public sector agency must implement and maintain an effective and ongoing process to identify risks associated with the financial management of the public sector agency, assess their likelihood and potential impact under a varied set of assumptions and proactively manage those risks. This is expected to include a framework for: identifying the financial risks related to the public sector agency’s objectives as detailed in its strategic plan; identifying new financial risks as they emerge and changes in previously identified risks; deciding what initiatives, programs or other actions are needed to deal with the financial risks in a positive, proactive, cost effective way; identifying or designing and implementing financial controls to ensure the actions are carried out as planned; ensuring appropriate information systems and systems of internal control exist to facilitate reporting on financial risk exposures and mitigation strategies; monitoring the implementation and operation of the financial risk management process and reporting to the governing body; and the preparation of a list of annual action items to be reviewed and discussed by the Responsible Body of the public sector agency. Guideline For risk management requirements, refer to Direction 4.5.5 Risk Management Compliance. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 15 2.4 Authorisations Direction Each public sector agency must establish and maintain authorisations covering the overall financial management of the public sector agency, and must establish and maintain authorisations covering the creation of financial obligations (including contingent liabilities and obligations) on behalf of the public sector agency. These authorisations must ensure that financial management and the creation of financial obligations are undertaken by staff with appropriate levels of authority and understanding of business operations. Authorisations must be to positions rather than specific individuals, and must be to employees of the public sector agency. For the purposes of this Direction: ‘Department’ means a department within the meaning of the Public Administration Act 2004; ‘Office’ means an office specified in section 16(1) of the Public Administration Act 2004; ‘Responsible Body’ in respect of a Department means the Minister, or the Ministers jointly if there is more than one Minister, of that Department; ‘Responsible Body’ in respect of an Office means the Minister for the time being administering the enabling legislation for that Office; ‘Responsible Body’ in respect of all public sector agencies that are not, for the purposes of this Direction, either Departments or Offices, means the board or, in the absence of a board, the person or body that is charged with the oversight of the public sector agency’s operations; and ‘Secretary of that Department’ means ‘Accountable Officer of that Department’. Requirements for Departments Until Departments transition to the Victorian Government Purchasing Board’s (VGPB) new policy framework that came into operation on 1 July 2013, the Responsible Body in respect of that Department may delegate to the Secretary of that Department some or all of the powers and responsibilities of a Responsible Body given by this Direction, but only up to the accreditation limit applicable to that Secretary’s Department as determined by the VGPB’s purchasing accreditation of that Department. After a Department has transitioned to the VGPB’s new policy framework, the Responsible Body in respect of that Department may: a) confer any limit on Departmental officers; and/or 16 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) b) delegate to the Accountable Officer of that Department the power to give financial authorisations for the creation of obligations for any amount up to but not exceeding $10 million; and may also: c) delegate to the Accountable Officer some or all of the responsibilities of the Responsible Body under this Direction except the power to give financial authorisations exceeding $10 million. Requirements for Section 16(1) Public Administration Act 2004 Offices The Responsible Body in respect of an Office may: a) confer any limit on employees of the Office; and/or b) delegate to the person with the functions of a public service body Head in respect of the Office (as determined by section 16 of the Public Administration Act 2004) the power to give financial authorisations for the creation of obligations for any amount up to but not exceeding $10 million; and may also: c) delegate to the person with the functions of a public service body Head in respect of the Office (as determined by section 16 of the Public Administration Act 2004) some or all of the responsibilities of the Responsible Body under this Direction except the power to give financial authorisations exceeding $10 million. Procedure a) The Responsible Body must give clear financial authorisations to specific positions within the public sector agency. b) All authorisations must be given so as to cease immediately upon the change in name of the specified position or a substantial and material change in the duties of the position. c) The authorisations are to be retained pursuant to the relevant legal requirements for document retention and record keeping. d) Where more than one financial authorisation is assigned to a particular position internal control procedures must not be compromised. e) A register of financial authorisations must be established and maintained. see Guideline below f) The Responsible Body must review the public sector agency’s authorisations and the register of financial authorisations annually and make any necessary changes. g) The Responsible Body must at least annually review the categories and types of financial authority and make any necessary changes. h) A financial authorisation cannot be given to another position by the person authorised. i) An authorisation cannot be given to a contractor or consultant. j) Audit trails must be maintained to demonstrate compliance with this direction. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 17 Guideline The register of financial authorisations should contain the following details: transaction type, for example financing, investing and operational types; list of positions holding financial authority for each transaction type; dollar caps for each transaction or authorisation type; list of staff names holding positions (this should be regularly updated and communicated to all relevant staff including the holders of authorised positions and members of the financial management team); and specimen signatures for each holder of an authorised position. Signatures may be in an electronic format. Mechanisms must be in place to enable continuous and efficient running of the public sector agency in the absence of the holders of an authorised position. A person acting in a position has the authority of that position. In the event of a total restructure of a public sector agency (for this purpose ‘total restructure’ means a restructure affecting 50 per cent or more of the positions in the public sector agency), financial authorisation should be reassessed and reapproved within one calendar month. 18 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 2.5 Internal audit Background Internal audit is commonly defined as an independent appraisal activity within a public sector agency, for the review of operations as a service to the Responsible Body and management. It is a control which functions by measuring and evaluating the effectiveness of other controls. Internal audit is a key assurance mechanism available to the Responsible Body to support the discharge of its governance and oversight responsibilities. Public sector agencies are required to establish, maintain and resource an internal audit function. The work is to be carried out by suitably qualified staff, independent of management and free of operational duties. Where an exemption is granted the Responsible Body must take alternative steps to secure an appropriate level of assurance from alternative in-house assurance activities and/or compliance functions that are sufficiently robust and rigorous. For simplicity the term internal audit is used in these Directions to encompass both in-house internal audit and the outsourcing of the internal audit function to an appropriately qualified third party. Direction Each public sector agency must, unless an exemption has been obtained, establish and maintain an adequately resourced independent internal audit function appropriate to the needs of the public sector agency. Government departments are not eligible for an exemption. Procedure a) An internal audit charter is to be approved by the Audit Committee and is to: provide for the internal audit function to report to senior management; provide for the internal auditor to have direct access to the Chairman of the audit committee; provide for internal audit function to have full, free and effective access at all reasonable times to all records, documents and employees of the public sector agency and the right to seek information and explanations; and set out the independent status of the internal audit function and its personnel. b) An annual internal audit plan is to be developed by the internal auditor to address relevant elements of the public sector agency’s risk profile. c) The internal audit plan is to be approved by the audit committee. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 19 d) On an annual basis the audit committee is to: review the adequacy and focus of the internal audit work plan and its fit with the public sector agency’s risk profile and the work of the external auditors; review the internal audit function’s performance, its authority, the adequacy of its resources and the proposed allocation of those resources; take steps to confirm that the internal auditor has not been unduly influenced by management or experienced any problems with management; and meet separately and privately with management and the internal auditors if necessary to ensure free, frank and open communications. e) In addition the audit committee should make appropriate enquiries to: approve and review management’s proposals as to how the public sector agency plans to respond to advice received from the internal auditor and direct management accordingly; monitor actions taken by management to resolve issues raised by internal audit; and advise management to adopt and address the accepted recommendations from internal audit on a timely basis. see Guideline below Guideline Specific matters to which consideration will be given in determining whether an exemption is to be granted include: the public sector agency’s size and scale; the public sector agency’s complexity/diversity; the nature of the public sector agency’s business in terms of the risk exposure of the business; its overall risk profile; its financial risk management profile; relevant external issues; public sector agency changes; the history of past issues and incidents; the existence of viable alternative mechanisms to provide adequate assurance on matters of compliance and the operation of internal controls; and the alternative assurance and compliance mechanisms on which the Responsible Body proposes to rely. 20 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 2.6 External audit Background Under the Audit Act 1994, the Auditor-General is responsible, on behalf of the Parliament for the external audit of the financial operations and resource management of the Victorian public sector. Accordingly the primary role of the Auditor-General is to provide information and audit assurance to the Parliament, independently of public sector agencies and the Government. An open, honest and effective working relationship will facilitate the work of the Auditor-General and maximise the benefits of the external audit process for the public sector agency. Direction Public sector agencies must establish and maintain a constructive, open working relationship with the Auditor-General and his duly appointed agents and representatives. Procedure a) The audit committee is required to take appropriate steps to ensure all members have a clear and detailed understanding of and are satisfied with the: scope of work to be undertaken by the external auditor; audit process; and overall audit approach. b) All external audit reports including performance audits completed by the Auditor-General or his or her agent are to be considered by the audit committee. c) The Auditor-General or his or her representative is to be invited to attend relevant meetings, or relevant parts of meetings, of the audit committee as an observer. d) At appropriate times during the course of each year the audit committee is to meet with the Auditor-General or his or her agent or representative to: discuss the proposed audit objectives with a view to eliminating duplication of audit activities with the internal audit function; obtain a briefing on the proposed external audit process; understand the Auditor’s views on any accounting issues which may impact on the financial statements; and discuss the outcomes of the external audit. e) The audit committee is to meet privately with the Auditor-General or his or her agent at least once a year to ensure free, frank and open communication. f) The audit committee is to: recommend how the Responsible Body should act on advice received from external auditors and ensure management take appropriate action; monitor actions taken by management to resolve issues raised by external audit; Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 21 monitor whether accepted recommendations of the external auditors are adopted and addressed by management on a timely basis; investigate the reasons for any material adjustments to the accounts; and review the impact of actions taken by management intended to resolve issues. g) The Responsible Body should ensure that all staff in the public sector agency adopt a cooperative and conservative approach with the external auditors on relevant auditing matters. 22 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 3. Financial management structure, systems, policies and procedures A public sector agency’s system of internal control is designed to support the effectiveness and efficiency of operations, to deliver reliable internal and external reporting, and achieve compliance with laws and regulations. Underpinning the system of internal control is the financial management structure, systems, policies and procedures that contribute to reliable financial information and to the safeguarding of assets, including prevention and detection of fraud. The Accountable Officer and, for public sector agencies other than government departments, the Responsible Body are responsible for the system of internal control. The Directions for financial management structure, systems, policies and procedures set minimum standards for public sector agencies to achieve sound systems of internal control to support financial management. 3.1 Financial management structure 3.1.1 Public sector agency financial management team structure Direction The CFAO must ensure that there is a structure for the financial management team with clearly defined roles and responsibilities to adequately support sound financial management. Procedure a) Roles and responsibilities for positions within the financial management team structure must be defined and documented to ensure the most effective and efficient allocation of tasks and resources. Prerequisite skills, qualifications and experience for each position must also be defined and documented. b) Financial management is defined to encompass: budgeting; financial reporting; accounts receivable/payable; procurement; taxation; asset management; financial systems; accounting policies; cash management; project management – financial aspects; payroll; and management reporting. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 23 3.1.2 Chief Finance and Accounting Officer (CFAO) Direction The Responsible Body must ensure financial management leadership is secured from a suitably experienced and qualified Chief Finance and Accounting Officer (CFAO). Procedure a) The prerequisite skills, qualifications and experience for the CFAO must be clearly defined and documented together with position description, role, duties, rights and responsibilities. see Guideline 1 below b) The CFAO must endorse financial reports submitted to senior management in any public sector agency, including reports submitted to the Responsible Body, and peak boards and management groups. see Guideline 2 below Guideline 1 The CFAO should hold at least tertiary level accounting qualifications and membership of the Institute of Chartered Accountants in Australia (ICAA), CPA Australia, National Institute of Accountants (NIA), or equivalent. Guideline 2 The purpose of the CFAO review is to ensure that the financial information presented in the reports is endorsed as to its completeness, reliability and accuracy. 3.1.3 Policies and procedures Direction Public sector agencies must establish and maintain documented policies and procedures to set out requirements for complete and accurate processing of authorised transactions. Procedure a) The Responsible Body must ensure there are formal, documented policies and procedures in relation to financial administration and management. see Guideline below b) There must be effective and efficient communication of policies and procedures to all officers either manually or electronically. c) There must be quality assurance mechanisms in place for monitoring, review and assessment of compliance with policies and procedures. Guideline i. The policies and procedures for financial administration and management should incorporate, the following: legislation under which the public sector agency operates; public sector agency financial management structure; chart of accounts of the public sector agency; 24 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) policy and procedure details for areas of financial management covered by these Directions, including use of information technology related to financial matters, where appropriate; standard forms to be used in financial management; A list of exemptions obtained from the Minister for Finance and all relevant supporting documentation; Accounting Standard Pronouncements of the Australian Accounting Standards Board; and conflicts of interest details. ii. Policies should be ratified by the Responsible Body or other delegate approved by the Responsible Body. Procedures should be ratified by the CFAO. iii. There should be sound control over policies and procedures to ensure only authorised versions are in use at any point in time. iv. There should be a process for periodic review of financial management policies and procedures (at least every two years, or more frequently at the discretion of the Responsible Body). The review should be designed to continuously improve the policies and procedures and reflect changes in the business/operations, technologies and best practice trends in financial management. 3.1.4 Chart of accounts Direction Public sector agencies must establish and maintain a chart of accounts to accurately reflect transactions in the financial records for management decision-making purposes and to ensure compliance with external reporting requirements. Procedure a) The CFAO or an approved delegate is responsible for the development and maintenance of a chart of accounts. see Guideline below b) There must be effective and efficient communication of the chart of accounts to all officers within the public sector agency, either manually or electronically. c) A government department must use any chart of accounts issued by the Minister for Finance as a basis for aligning its activities for the purposes of consistency in reporting. d) There should be an explanatory note to each account within the chart of accounts that describes the nature and purpose of the account, as a means to delineate the boundary lines between capital, revenue and expense items and assist categorisation of transactions. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 25 Guideline The chart of accounts should be: properly controlled (it is recommended that all changes be approved by the CFAO or their delegate); maintained and updated in a timely manner reacting to the needs of the public sector agency; aligned with the objectives of the public sector agency; aligned with the consolidated reporting requirements of the Department of Treasury and Finance; sufficiently detailed and logically structured to allow useful and timely management reporting and financial reporting consistent with legislative requirements; in the case of Government Departments provide for effective budgeting, reporting and monitoring of the output management principles and practices; and A relationship table between the chart of accounts and that issued by the Minister for Finance should be established and maintained. 3.1.5 Managing outsourced financial services Direction Public sector agencies must ensure effective management of outsourced financial functions to obtain the required levels of service and maintain compliance with the FMA, the Financial Management Regulations 2004 and these Directions. Procedure a) Prior to outsourcing financial functions either in full or part, the costs and benefits must be analysed and the outsourcing decision approved by the Responsible Body. see Guideline below b) The financial services to be provided under an outsourced arrangement must be able to be detailed in a contract, service level agreement or equivalent, together with performance indicators and measures. c) Performance against the contract, service level agreement or equivalent, must be regularly monitored and reviewed, including a review (at least annually) by the Accountable Officer, or delegate such as the CFAO. If the Accountable Officer is not the Responsible Body, the results of the review should be reported to the Responsible Body. d) Outsourced financial functions must be subject to internal and external audit scrutiny. Guideline i. Different aspects of the financial function can be outsourced. Examples of outsourced financial functions may include: actuarial services, investment consulting, debt collection and maintenance of the ledger or other financial systems. However, the public sector agency remains responsible for ensuring that the third party provider is meeting the requirements of the FMA, these Directions and any other relevant legislation. 26 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) ii. Before outsourcing a cost-benefit analysis should be undertaken. The cost-benefit analysis should include. the costs and basis for estimating the cost; the benefits and basis for estimating the benefits; an assessment of planned non-financial benefits; potential risks associated with outsourcing the function and how they will be mitigated; and a recommendation for proposed future action. 3.2 Information technology systems 3.2.1 Information technology management Direction A public sector agency must ensure that the direction, strategy and use of information technology in the public sector agency are consistent with and appropriate for its sound financial management. Procedure a) The Responsible Body must review the use of information technology for financial management on at least an annual basis. see Guideline below b) The Responsible Body must conduct or review (at least annually) an assessment of information technology risks and their impact on financial management. Guideline This review is in relation to technology used for financial management and should include, but not be limited to, whether: there are the appropriate skills available within the public sector agency, to support the information technology environment and whether obtaining external support may be necessary; the current level of reliance on information technology is still considered to be appropriate; there are appropriate controls over information technology that is currently being employed; and the impact of changes to financial applications and IT infrastructure has been adequately assessed and understood. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 27 3.2.2 Information technology operations Direction The Responsible Body must strongly support information technology operations to support financial management and make it as widely available as possible. Procedure a) At least annually, the public sector agency must formally assess the impact of information technology that supports financial management not being available for an extended period. This should include review and testing of a formally documented disaster recovery plan and business continuity plan. b) The public sector agency must ensure up-to-date backups are maintained for all financial management systems and data being used. see Guideline below c) A register of licences for financial management software must be maintained. In addition, regular audits or verification reviews of the register must be performed (at least annually). d) Error logs must be identified, reviewed and followed up regularly to monitor access to and transactions through financial management systems. e) Where financial systems are connected externally to the internet, controls must be in place to prevent these connections from undermining system security. Controls may include: firewalls; security logs; and encryption. Guideline i. The policy for the frequency of backups of financial management information should be ratified by the Responsible Body (in accordance with Direction 3.1.3, Guideline (ii). Backups should be taken at appropriate intervals based on the volume of data input and criticality of information. As a guide, where financial transactions are processed daily, daily backups should be taken. ii. The backups should be stored in an off-site, secure location and be periodically checked to ensure that the backups are being performed adequately (any backups stored onsite should be kept in a fireproof safe and checked periodically). iii. The public sector agency should ensure the backup cycle includes rotation and periodic replacement of storage media. iv. Annual backups should be stored for the period required under the Public Records Act 1973, unless there is a requirement to store for a longer period. 28 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 3.2.3 Security Direction The financial management system must have levels of security to ensure that only authorised people have access to transactions. Procedure On at least an annual basis, a formal assessment must be performed of whether financial management information that is sensitive to the public sector agency and stakeholders is appropriately controlled and secured. The adequacy of the following controls must be considered: security policies; password controls, for both applications and operating platforms; segregation of incompatible duties and user access levels being commensurate with roles and responsibilities; and restricted physical access to the computer room and other sensitive financial management technology assets. 3.2.4 Development Direction The CFAO, in consultation with appropriate technical input, must regularly review and address the developments in financial management systems needed to ensure the most appropriate technological support for financial management practices. Procedure a) At least annually, a review of whether the use of spreadsheets, manual files or core financial processes would be more efficiently or effectively conducted or delivered through the use of a more formal application package or automated system must be undertaken. b) Public sector agencies must develop or adopt a formal information technology development methodology for development of financial management systems and technology. see Guideline 1 below c) For all proposed financial management system developments there must be a business case that is approved by the information technology steering committee (or Responsible Body or executive team, where an information technology steering committee does not exist) and end users. see Guideline 2 below d) For all developments that proceed, there must be project management processes in place including: status reporting of the project to the project sponsor. see Guideline 3 below Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 29 Guidelines Guideline 1 The methodology may be: Internally developed and applied across the public sector agency’s development projects; or Be supplied by an external vendor as part of a specific project. For example, by a tender requirement that the supplier has a development methodology that can be applied to the project. Guideline 2 The business case for the development of financial management systems should include the approach to the development, proposed benefits and associated measures, budget, key risks and actions to address risks. Guideline 3 For large or complex projects, status reporting is expected through to a project steering committee that meets at least every two months, and more frequently as required. 3.2.5 Change control Direction Changes made to financial management systems must be authorised and implemented in a controlled manner to ensure the integrity of financial management data is maintained. Procedure Public sector agencies must have a change control and management process. Guideline The process should include: a formal process for requests for program changes; formal user signoff that the changes have been made in accordance with the user requirements; signoff that appropriate testing has been performed, including consideration of unit, systems, regression, user and other forms of testing; and migration to the production environment is appropriately controlled. 3.3 Education and training Direction Public sector agencies must ensure financial management staff are appropriately educated and trained to fulfil their financial management responsibilities. 30 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) Procedure Training and education needs for the financial management team must be reviewed, at least annually, by the CFAO or their delegate and a program must be developed to address these needs. see Guideline below Guideline i. The assessment of training and education needs should be documented and communicated to the CFAO and should form the basis for allocation of a specific education and training budget for the financial management team. ii. Implementation of a program for addressing training and education needs should be monitored on an annual basis and reported to the CFAO or their delegate. iii. Where appropriate a public sector agency should incorporate the following elements in its education and training model: a performance evaluation system linked to the requirements for financial management; a training needs analysis, up front and periodically, as required; facilitation of on the job/self paced learning; and a formal training evaluation process. 3.4 Policies and procedures 3.4.1 Revenue Direction Public sector agencies must implement and maintain an effective internal control framework over revenue transaction processing and management to ensure that revenue is completely and accurately identified, recorded and collected. Procedure a) Policy and procedures for recognising and recording revenue and corresponding receipts must be developed and implemented. see Guideline 1 below b) Responsibility for revenue and related transactions must be delegated to appropriate officers in accordance with Direction 2.4. see Guideline 2 below c) The levels of charges for goods or services provided must be documented and approved by the CFAO, and must be reviewed at least annually by a delegate of the CFAO and a recommendation made to the Responsible Body as to how they should be updated. see Guideline 3 below Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 31 d) A register of outstanding receivables balances that ages the outstanding balances and is used by management to monitor and follow up on overdue debtors must be maintained. An analysis of aged debtors must be reported to the CFAO, or a delegate of the CFAO, on a monthly basis. see Guideline 4 below e) A Public sector agency must regularly assess revenue that is to be foregone, waived or written off. Revenue foregone, waived or written off must be approved by the CFAO or other officer within the approved financial management delegations. see Guideline 5 below f) For Government Departments, appropriation revenue received for the provision of outputs may only be recognised as revenue following certification by the Treasurer. Guidelines Guideline 1 The policies and procedures for recognising and recording revenue should cover: identification and recording of revenue accrued to the public sector agency, irrespective of any subsequent cash inflow; how charges for goods or services are determined and approved, including consideration of legal and taxation requirements such as for GST purposes; the timing and process for billing to ensure customers are billed as soon as practicable after goods and services are provided; A standard template for billing customers that includes appropriate internal control features; credit policies and negotiation of payment terms; recording of revenue and corresponding debtors in the financial records; processing of receipts; requirements for follow up of outstanding debtors; the audit trail that substantiates the receipt of individual revenue transactions; periodic and regular review of credit worthiness of customers and collectability of receivables; and treatment of bad and doubtful debts. Guideline 2 With respect to the delegation of responsibility for revenue, there should be segregation of duties between roles and responsibilities for initiating debtors/revenue, cash collection/banking of money, and processing credit notes, waivers and write-offs to the greatest extent practicable. Guideline 3 Public Sector Agencies should refer to BFMG 21 Setting Fees and Charges Imposed by Departments and Budget Sector Agencies. This can be located on the Budget and Financial Management website (http://bfm.dtf.vic.gov.au). Only agencies that are connected to the Victorian Government common virtual private network can access this site. Please contact your portfolio coordinator directly if you have problems with access. 32 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) Guideline 4 Collection of revenue should be maximised through application of appropriate collection and follow-up procedures. These procedures should identify: the priorities for outstanding debtor follow up (to ensure the cost of follow up does not significantly overweigh the benefit of collecting the debt); steps to take for debts that are outstanding for specified periods of time eg: verbal follow up and/or letters requesting payment and the point at which the debt should be referred to legal action or to an outsourced debt collection specialist, if appropriate; and requirements for documentation of the actions taken. Guideline 5 There should be an adequate audit trail to evidence the approval of revenue foregone, waived or written off. 3.4.2 Cash handling Direction Public sector agencies must implement and maintain an effective internal control framework over cash handling and banking so that cash from all sources is completely and accurately identified, banked and recorded in the financial records. Procedure a) Policy and procedures for cash collection and handling must be developed and implemented. see Guideline 1 below b) Responsibility for cash handling must be delegated to appropriate officers in accordance with Direction 2.4. see Guideline 2 below c) All sources, locations and methods of cash collection must be identified and approved by the CFAO and articulated in the policies and procedures. Guidelines Guideline 1 The policies and procedures for cash collection and handling should cover the following: complete, accurate, timely and secure receipting of incoming moneys such as postal remittances, cash taken at approved cash collection points, money taken by credit card, or other electronic media; use of sequentially numbered receipts; timeliness, process and frequency of banking – as a guide banking should be performed daily unless the total collections has not exceeded $500, in which case banking should always be performed at intervals of no more than 5 working days; complete, accurate and secure recording of incoming moneys in the accounting and financial records; arrangements for secure storage of incoming moneys and moneys held that have not been banked; Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 33 the circumstances, if any, under which an incoming cheque can be cashed and/or change given; process, audit trail and approval requirements for cancelling receipts; treatment of personal cheques that may be received and should be kept separate from public monies; cash reconciliation requirements; nature, extent and procedures for control over petty cash and other cash floats; handover of cash from one officer to another; daily procedures for closing off any cash registers; audit trail requirements over cash transactions that ensures it is possible to follow up dishonoured transactions; securing of documentation; and the review of adequacy of insurance. Guideline 2 Delegation of the responsibility for cash handling must be performed in accordance with Direction 2.4. Segregation of duties should be maintained at all times between cash handling and other conflicting roles and responsibilities including cash, bank reconciliations, banking, and invoicing and credit note processing. 3.4.3 Bank accounts Direction Public sector agencies must implement and maintain an effective internal control framework over the establishment and management of bank accounts to ensure balances are accurately reflected in the financial records and bank accounts are operated efficiently and effectively. Procedure a) Bank accounts must only be opened with the express written approval of the Responsible Body or its delegate. b) A Public sector agency must have as few banking institutions and bank accounts as practicable. The number of bank accounts and institutions used for banking should be reviewed at least annually by the CFAO. c) All bank accounts must be reconciled, at least on a monthly basis. d) Bank accounts are only to be closed with the approval of the Responsible Body or its delegate. e) All collections must be paid into the appropriate bank accounts completely, accurately and in a timely manner. see Guideline below f) A register of bank accounts and facilities should be maintained. 34 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) Requirements for government departments All new bank accounts opened and all bank account closures by government departments must be reported to the Department of Treasury and Finance. Guideline Section 15 of the FMA provides for the opening and maintaining by a government department of bank accounts with a bank or banks. 3.4.4 Cash flow forecasting Direction Public sector agencies must implement and maintain an effective internal control framework over cash flow forecasting and cash flow management to ensure cash deficits and surpluses can be effectively managed. Procedure a) Cash forecasting must be performed to ensure sufficient cash is available to operate the business of the public sector agency, to maximise investment opportunities and minimise borrowing costs. see Guideline below b) Cash forecasts must be regularly compared (at least monthly) against actual cash flows, updated as required and reported to the CFAO. c) Government departments and other public sector agencies who are required to bank into the Public Account must: prepare and provide the Department of Treasury and Finance with long-term cash flow forecasts on a 12 month rolling basis; prepare and provide, on a monthly basis to the Department of Treasury and Finance, detailed daily estimates of cash flows for the next two forecast months; and prepare and provide the Department of Treasury and Finance with daily advice on Public Account receipts and payments. Guideline Three levels of rolling forecasts of cash flows are recommended for public sector agencies: long-term strategic forecasts, based on annual budget estimates, and used to plan for significant cash flows and any contingencies; short-term tactical forecasts, usually prepared monthly to provide detailed estimates of the cash flows expected; and weekly operational forecasts, where appropriate, which allow public sector agencies’ immediate cash flow requirements to be met. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 35 3.4.5 Procurement Background Section 54L of the FMA empowers the Victorian Government Purchasing Board (VGPB) to make supply policies. These policies are to be consistent with these Directions. All Accountable Officers of government departments and other staff of government departments must comply with supply policies. This means that the following organisations must comply with the supply policies: all government departments; Office of the Chief Commissioner of Police; Auditor-General’s Office; Office of Public Prosecutions; Victorian Electoral Commission; Office of the Ombudsman; Office of the Commissioner for Public Employment; Essential Services Commission; Office of the Legal Ombudsman; and Office of the Victorian Privacy Commissioner. Direction Public sector agencies must implement and maintain an effective internal control framework over procurement activities to ensure procurement of goods or services is authorised in accordance with business needs and within a documented framework of procurement policies and procedures. Procedure a) Relevant mandatory elements in relation to procurement are included at Directions 2.1 Financial Code of Practice, 3.1.5 Managing Outsourced Financial Service and 3.4.6 Expenditure b) A public sector agency must ensure that its framework of procurement policies and procedures are based on the following principles: value for money; open and fair competition; accountability; risk management; and probity and transparency. c) In addition, a public sector agency must comply with the Victorian Industry Participation Policy issued by the Victorian Government. Guideline For more information refer to the Victorian Government Purchasing Board website at www.vgpb.vic.gov.au or to access the Guide for the Acceptance of Performance Bonds by public sector agencies refer to the Department of Treasury and Finance website at www.dtf.vic.gov.au. 36 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 3.4.6 Expenditure Direction Public sector agencies must implement and maintain an effective internal control framework over expenditure transaction processing and management to ensure that disbursements (including but not limited to grants, capital expenditure, salaries and wages, and other recurrent expenditure) are appropriately authorised and incurred in accordance with business needs, and captured in the financial records. Procedure a) Policy and procedures for the timely and accurate recording of committed expenditure must be developed and implemented. see Guideline 1 below b) Officers with appropriate financial delegations are responsible for approving expenditure and related transactions. see Guideline 2 below c) A system to pay all debts as and when they are due and payable and to ensure early payment discounts are fully utilised where appropriate must be implemented. d) Payments must be made in a secure and efficient manner that takes advantage of technologies. e) Policies and procedures must specifically address and be established in the following expenditure types: capital expenditure; travel; hospitality; personal expense reimbursement; gifts; employee advances; petty cash; Purchasing Card Rules for Use and Administration issued by the Department of Treasury and Finance. f) Refer to Direction 4.5.3 g) All public sector agencies must report to the Minister for Finance, within one month of becoming aware of, any material and substantial breach of policies and procedures relating to the expenditure transaction processing and management and the management action taken by the public sector agency in response to this breach. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 37 Guidelines Guideline 1 The policy and procedures for timely and accurate recording of expenditure should cover requirements in Direction 3.4.6 in addition to: identification and recording of expenditures incurred irrespective of any subsequent cash flow; expenditure only to be incurred when duly approved, within available budgets and for authorised purposes; systems to ensure all disbursements and payments are approved by an appropriately authorised officer; procedures to ensure that disbursements and payments are not duplicated; payments only being made on original tax invoices or in accordance with ATO tax rulings in this area, with instances of non compliance monitored by the CFAO; an audit trail which substantiates payments and demonstrates that internal control systems and procedures have been adhered to; a mechanism for periodic review of all major suppliers for performance and competitiveness should be established; and mechanisms to ensure all legal and taxation requirements, such as for GST and FBT are satisfied. Guideline 2 With respect to the approval of expenditure, where practical, appropriate segregation of duties within the procurement and payment processes would typically incorporate segregation of the following: initiating expenditure; approving expenditure; receipt of goods and services; invoice verification and processing; disbursement and payments processing; and maintenance of vendor records. 3.4.7 Employee costs Direction Public sector agencies must implement and maintain an effective internal control framework over financial transaction processing for employee expenses and for employee expense management to ensure that salaries, wages and other employee costs (including full-time, part-time and casual employees) are authorised and paid accurately, efficiently, and in a timely and secure manner. 38 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) Procedure a) A system of internal control must be established and documented in relation to the capture, approval, processing and payment of employee expenses such as salary and wages and associated leave expenses. see Guideline 1 below b) There must be independent review and approval of salary and wage data (including all masterfile changes) prior to processing salary and wage payments. c) There must be security over payroll data including personnel files, payroll reports and other sensitive employee information. d) Payments must be made in a secure, timely, and accurate manner. see Guideline 2 below e) Leave entitlement balances and corresponding liabilities must be recorded and monitored with a view to ensuring they are minimised at all times to avoid any significant impact upon cash flow. Guidelines Guideline 1 With respect to the establishment of a system of internal control, there should be segregation of duties between roles and responsibilities for the: capture and authorisation of salary and wage information; processing, including data entry and maintenance, of salary and wage information; approval of salary and wage payments and adjustments; processing of the salary and wage payments; and maintenance of an audit trail which substantiates salary and wage payments and demonstrates that internal control systems and procedures have been adhered to. Guideline 2 To ensure that payments are made in a secure, timely and accurate manner, where possible a public sector agency should take advantage of appropriate technology in relation to electronic payments of employee expenses at all times. 3.4.8 Commission on employee payroll deductions Direction Public Sector Agencies must recover the costs associated with voluntary payroll deductions from gross pay by charging the payee a commission on amounts deducted. Procedure a) Commission must not be charged on taxation, superannuation or other mandatory deductions. b) Any commission which is collected must be brought to account as revenue. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 39 c) In the case of health insurance deductions, each public sector agency must enter into arrangements with all health insurance funds to collect the commission annually with: the rate of commission payable on contributions determined by DTF; and the rate of commission payable indexed annually in accordance with the ‘annual rate’ set by the Treasurer under section 5(4) of the Monetary Units Act 2004. see Guideline below d) In the case of any other deductions, the Accountable Officer must determine the rate of commission. Guideline The rate of commission on health insurance contributions, relevant to the current financial year is published on the DTF website (www.dtf.vic.gov.au). The rate from 1 July 2015 is $11.80 per contributor, per annum. 3.4.9 Physical and intangible assets Background Section 44B (1) of the FMA requires public sector agencies to maintain a register of assets held or managed by it. Section 44B (2) provides that the register is to be in the form, and contain the information determined by the Minister for Finance after consultation with the Victorian Managed Insurance Authority (VMIA). Direction Public sector agencies must implement and maintain an effective internal control framework for asset management to ensure that assets are identified, recorded accurately and accounted for in accordance with Australian Accounting Standards. Procedure a) Policy and procedures for asset identification, recording and management must be established and maintained. see Guideline 1 below b) Depreciation and amortisation must be calculated in accordance with relevant accounting standards and taxation requirements. see Guideline 2 below c) Assets must be kept in secure custody and used for authorised purposes only. d) Proper authority in the form of financial delegations or specific authorisation must be obtained before acquiring, transferring or disposing of an asset. e) Proper policies and procedures must be documented for the revaluation of assets including appropriate approvals for changes to asset values in accordance with financial delegations. 40 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) f) Records and details must be maintained in relation to contingent assets as required for Public sector agency needs, and to satisfy accounting standards and disclosure requirements. g) Records and details for intangible assets must be sufficient to ensure compliance with accounting standards and disclosure requirements, in addition to any operational needs of the business. Guidelines Guideline 1 The policies and procedures for asset identification, recording and management should incorporate the following: recognition of assets upon receipt or commissioning; verification of the physical existence, location and condition of assets and inventories on a regular basis and requirements for the asset register to be reconciled against the records of the public sector agency. This should be conducted by someone other than to whom the asset has been assigned; complete and accurate records of inspections made with respect to maintenance needs and actions taken should be maintained; and the creation or purchase of an asset requires standard expenditure procedures to be followed. Financial delegations of authority should specify those officers able to authorise the transfer or disposal of an asset. Guideline 2 The public sector agency should have its depreciation policies and rates clearly articulated in the relevant internal documentation, such as an accounting policy document. The allocation of depreciation expense to outputs should be recorded. 3.4.10 Liabilities Direction Public sector agencies must implement and maintain an effective internal control framework for the incurrence and management of liabilities to ensure they are incurred and managed in line with proper procedures and the public sector agency’s objectives. Procedure a) Policy and procedures must be developed to ensure that liabilities are incurred for authorised purposes only and that proper authority is obtained prior to incurring liabilities. see Guideline below b) Officers with appropriate authorisation or financial delegations are responsible for incurring liabilities c) Records and details must be maintained in relation to contingent liabilities and contingent assets as required for Public sector agency needs and to satisfy accounting standards and disclosure requirements. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 41 Guideline The policies and procedures for the management of liabilities should cover: requirements for complete and accurate recording of liabilities as and when they are incurred; liabilities to be accounted for in accordance with the public sector agency’s approved accounting policies and applicable accounting standards and other requirements; and mechanisms to ensure liabilities are settled when they become due and payable. 3.4.11 Reconciliations Direction Public sector agencies must implement and maintain procedures to ensure that reconciliations are completed and reviewed in a timely manner to ensure the accuracy of the financial records. Procedure Procedures in relation to the completion, review and monitoring of reconciliations must be implemented. Guideline i. These should include, where appropriate: responsibility for reconciliation completion; responsibility for reconciliation review; frequency of reconciliations completion; prioritisation of key reconciliations; completion deadlines; requirements for reconciling items to be followed up and cleared; format of reconciliations; and appropriate supporting documentation to be attached. ii. There should be separation of duties between responsibilities for the preparation and review of reconciliations. 3.4.12 Administration of discretionary financial benefits Background A discretionary financial benefit is a financial benefit given to a person or body for a specified purpose directed at achieving outcomes sought by government policy. Examples of discretionary financial benefits include grants, sponsorships and donations. A discretionary financial benefit does not include a financial benefit received by a person or body as consideration for goods or services provided by them under an agreement entered into on commercial terms or a transfer of funds to a government entity for the purpose of funding non contestable output delivery. Direction When administering discretionary financial benefits, public sector agencies must implement and maintain effective financial management controls to ensure that a transparent process 42 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) delivers measurable efficient and effective financial management and accountability outcomes sought by Government policy. Procedure Policy and procedures for the financial management of discretionary financial benefit programs must be developed and implemented, where applicable. Any policies and procedures must be consistent with the FMA and the Directions. Guidelines Guideline 1 Policies and procedures for the financial management of discretionary financial benefits should be developed within the public sector agency’s broader financial management frameworks. They should include: procedures for determining the financial viability of financial benefit recipients to deliver the desired outcome; delegations for the approval of financial benefit recipients and for payments to such recipients; procedures for the authorisation of payments made to financial benefit recipients; separation of duties between the appraiser of applications, approval of offers and making financial benefit payments; requirement to establish financial reporting requirements of financial benefit recipients in the terms and conditions of a funding agreement; mechanisms and responsibilities for monitoring the use of, and acquitting, financial benefits; procedures for the recovery of financial benefits in a timely and effective manner when and if necessary in circumstances where there is an ineffective delivery of the desired outcome; and identification of the financial management information technology or other system requirements to ensure effective financial management and accountability for financial benefits. Guideline 2 There are a number of other elements that need to be considered in relation to the overall management and administration of discretionary financial benefits, these include the following: Establishing the need for a financial benefit program: – Each financial benefit program will require a clearly defined objective and a business case which analyses the need for the program, alternate effective means of achieving the program objective and explores alternative sources of funding in terms of a loan or Commonwealth or private funding etc. Establishing performance measures: – To determine the outcome and effectiveness of a financial benefit program, it is essential to design relevant and meaningful performance measures and indicators at the commencement of the program. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 43 Financial risk management: – Financial benefit program management resource limitations and other financial risks associated with such programs should be identified and mitigated through a documented financial risk management strategy at the planning stage. – At the operational stage of a program, a sound performance information system that focuses on continuously identifying and treating emerging financial risks should be available as a management tool. Ensuring value for money: – The design of a value for money financial benefit program needs to include the best mix of funding sources, the identification of efficient administrative support costs, (where appropriate) the use of on-line financial benefit application, appraisal and management systems (to streamline the application and selection process, reduce administrative costs and increase the transparency of discretionary financial benefit administration) and strategies to manage relationships and cooperatively streamline and reduce duplication of effort. Establishing selection criteria for discretionary financial benefits: – To achieve transparency and effective selection of financial benefit recipients the design of a financial benefit program needs to include evidence based selection criteria. Management of effective financial benefit funding agreements: – The design of funding agreements needs to include clearly defined terms and conditions to facilitate effective outcomes and minimise ongoing monitoring effort. The management of agreements needs to include procedures for monitoring payments, recipient organisations and progress of outcomes as well as arrangements for financial accountability through effective financial benefit acquittal. Evaluation of financial benefit programs: – Procedures need to test the adequacy of performance information and evidence of the quality, efficiency and effectiveness of a program, as well as, whether the program achieved the outcome it was designed to achieve. Reporting: – In the absence of tailored public performance reports, the accountability to report to the Parliament and the public is best achieved through disclosure in budget papers and/or Departmental annual reports. 3.4.13 Information collection and management Background The objectives of this Direction are to ensure that the collection and storage of information is appropriately managed; and to provide assurance that reliable and accurate information is available for the purposes of risk management and financial and operational reporting. The integrity of information maintained by an organisation can be enhanced by the following factors: robust data collection processes, collation procedures and methods; consistent interpretation, classification and storage of information; and adequate risk identification, assessment and mitigation strategies to ensure data quality. 44 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) Accordingly, public sector agencies must take reasonable steps to ensure the accuracy and completeness of information collected and stored, which supports reporting by establishing appropriate policies, standards and controls to direct governance and risk management activities. Direction Public sector agencies must take reasonable steps to ensure that data is accurate and adequate when it is collected, and that its accuracy is maintained during subsequent use and reporting. The standard for accuracy and adequacy is to be determined by reference to what is expected for the purposes of effective risk management and financial and operational reporting. Procedure a) Appropriate policies and procedures for information collection, storage and dissemination must be developed, implemented and maintained, reflecting regular risk assessments related to key agency sets of data. b) Responsibility for the integrity of significant sets of data must be delegated to appropriate officers by the Accountable Officer. c) Public sector agencies must on a regular basis conduct a review of their obligations under this Direction. Guideline This Direction requires that public sector agencies take necessary steps to ensure a prudent approach to information management, and that a sufficient level of attention be given to associated risks. Public sector agencies should investigate any errors or deficiencies upon discovery. The outcomes of the investigation, along with any corrections made, should be clearly documented to reduce the possibility of similar occurrences. Public sector agencies should consider the disclosure of any factors that may compromise data accuracy at the time of publishing the information. The disclosure could provide information regarding: the source of the information; the manner in which it has been stored and processed; and any known vulnerabilities inherent in the information, impacting on its reliability. In complying with this Direction, relevant public sector agencies should refer to the requirements of the Victorian Government Risk Management Framework as espoused in Direction 4.5.5 Risk Management Compliance. The use of information technology (IT) for data collection, processing and storage presents a range of security and control considerations that are specific to an IT environment. In complying with this Direction, relevant Public Sector Agencies should also refer to the Whole of Victorian Government ICT Policy on Information Security Management issued by the Government Services Group of the Department of Treasury and Finance, and Direction 3.2 Information Technology Systems. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 45 Additional guidance on the creation, maintenance, destruction, transfer and storage of information can be found on the Public Record Office Victoria website: www.prov.vic.gov.au. This guidance is consistent with public sector record management obligations under the Public Records Act 1973. Furthermore, Public Sector Agencies should also consider their statutory obligations under the Information Privacy Act 2000 and any other relevant legislation, in assessing information management risk. Guidance on the application of the Information Privacy Act can be found on the Victorian Privacy Commissioner’s website: www.privacy.vic.gov.au. 46 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 4. Financial management reporting Financial management reporting is designed to provide analysis and information that supports a public sector agency’s decision making, the management of its finances and the measurement and management of its performance. It should be part of a suite of management reports that help focus the public sector agency on meeting its strategic and operational goals and objectives. It should also be part of the mechanism by which compliance with external reporting requirements is achieved in accordance with the requirements of the FMA. The Directions for financial management reporting set standards for public sector agencies to ensure financial management reporting that will assist the public sector agency in measuring and managing performance and ensuring consistency with applicable statutory reporting obligations. 4.1 Internal financial management reporting Direction Public sector agencies must implement and maintain timely, accurate, appropriate and effective reporting on financial matters for use in management decision making and to support broader operational management reports. Procedure a) The requirements of the public sector agency for financial management information must be identified and used as a basis for the design, preparation and distribution of internal financial management reports. see Guideline 1 below b) Financial management reports must be tabled and discussed by the Responsible Body or at another recognised senior forum as determined by the Responsible Body, on a timely basis to ensure financial information is adequately monitored and acted on. see Guideline 2 below c) Prior to release, internal financial management reports must be reviewed by the CFAO, or delegate for internal financial management reports that are not material. d) The financial systems used by the public sector agency must support internal financial management reporting to the level of detail and within the timeframes required. see Guideline 3 below Guidelines Guideline 1 i. Internal financial management reports of a public sector agency should be prepared monthly, on an accruals accounting basis or modified accruals method, and cover: income statement (profit and loss, income and expenditure); balance sheet; Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 47 statement of recognised income and expense; cash flow; and public sector agency financial key performance indicators (KPIs) (including, in the case of government departments, performance measures for objectives and outputs as published in the budget papers). ii. Reports should include variance analysis of budget to actual including discussion on reasons for variations where appropriate and any action taken to address the variations. Reporting should include monthly, year to date (YTD), prior year comparatives and current forecast data where appropriate. iii. The reporting format should remain consistent from period to period. Changes made should reflect changes in the business, improvements in the presentation or changes based on feedback obtained from end users. iv. Reporting should be aligned with the objectives and needs of the public sector agency in terms of the nature and extent of reporting, level of detail and frequency. v. Feedback on internal reporting should be sought and obtained from end users on a regular basis to ensure reporting remains relevant. Guideline 2 i. Appropriate financial management reports (and/or summary reports) should be presented and discussed at various levels within the public sector agency including the executive team and business management. There should be evidence that this has occurred. ii. To ensure reporting is timely and appropriate, the public sector agency should develop a monthly reporting timetable that allows sufficient time for report preparation, review and distribution for all financial management reports. iii. Quarterly reports to the Expenditure Review Committee of Cabinet (ERC) should be in accordance with the deadlines set by the Department of Treasury and Finance. Guideline 3 An adequate audit trail should be maintained in the production of financial management reports for the changes made when compared to the underlying financial systems. Where necessary, the public sector agency’s chart of accounts, or equivalent, should be appropriate to cater for this, whilst also satisfying external reporting requirements. 4.2 Reporting requirements in terms of Part 7 of the FMA Background The annual report is the principal medium through which Public Sector Agencies discharge their accountability to the Parliament, government and the people of Victoria. The annual report should assist these users in making decisions about the utilisation of resources in the relevant entities. Annual reports therefore should provide both general and financial information about the operations and performance of public sector agencies, together with assessments of results and financial position. The FMA requires that the annual report of a relevant public sector agency comprise (a) a report of operations and (b) financial statements. 48 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) Direction The public sector agency must develop procedures to ensure timely and accurate preparation of all reports required under Part 7 of the FMA. Procedure Financial statements required under Part 7 of the FMA a) The financial statements must be prepared in accordance with: Australian accounting standards (AAS and AASB standards) and other mandatory professional reporting requirements (including urgent issues group consensus views); Financial Reporting Directions; and business rules. b) The financial statements are to comprise the following: income statement; balance sheet; statement of recognised income and expense; and cash flows statement; and notes to the financial statements. c) The financial statements must where applicable be signed and dated by the Accountable Officer, CFAO and a member of the Responsible Body, stating whether, in their opinion: the financial statements present fairly the financial transactions during the reporting period and the financial position at the end of the period; the financial statements are prepared in accordance with this direction and applicable Financial Reporting Directions; and the financial statements comply with applicable Australian accounting standards (AAS and AASB standards) and other mandatory professional reporting requirements (including urgent issues group consensus views). d) The financial statements must be expressed to the nearest dollar except where the total assets, or revenue, or expenses of the public sector agency are greater than: $10 000 000, when the amounts shown in the financial statements may be expressed by reference to the nearest $1 000; or $1 000 000 000, when the amounts shown in the financial statements may be expressed by reference to the nearest $100 000. e) The financial statements must be reviewed and recommended by the Audit Committee or Responsible Body prior to finalisation and submission. f) The financial statements of government departments must present fairly and in accordance with the requirements contained within the Model Financial Report for Victorian Government Departments. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 49 Report of operations required under Part 7 of the FMA g) The report of operations should include qualitative and quantitative information on the operations of the public sector agency and should be prepared on a basis consistent with the financial statements prepared by the public sector agency pursuant to the FMA. This report should provide users with general information about the entity and its activities, operational highlights for the reporting period, future initiatives and other relevant information not included in the financial statements. h) The report of operations must be prepared in accordance with the requirements of the Financial Reporting Directions. i) The report of operations for government departments must be presented in accordance with the guidelines contained within the Model Financial Report for Victorian Government Departments. j) The report of operations must be signed and dated by the Accountable Officer in the case of a government department or, in the case of any other public sector agency, a member of the Responsible Body. k) * * * * * (Requirement now contained in FRD 8C). Comparison with actual results l) Government departments must include in their annual report, but not forming part of the audited financial report, a comparison between their portfolio financial statements published in Budget Paper No. 4 and actual results for the portfolio for the corresponding financial year. m) The comparison between portfolio budget and actual figures referred to in (l) above must be presented as a set of financial statements in the same format and consolidation basis as those for the portfolio set out in Budget Paper No. 4 for the financial year. These financial statements are to be referred to as ‘budget portfolio outcomes’. Lodgement of annual reports n) In relation to a financial year each public sector agency must provide a copy of its financial statements and report of operations either directly or via the portfolio Department, in the form of its annual report, to: Deputy Secretary Budget and Financial Management Division Department of Treasury and Finance 1 Treasury Place East Melbourne Victoria 3002 Consolidated financial report for the state o) Financial information for the purposes of meeting the state’s consolidated financial reporting requirements in section 24 and 25 of the FMA must be forwarded to the Department of Treasury and Finance in the format and by the date determined by the Deputy Secretary, Budget and Financial Management Division. Guideline The Model Financial Report can be located on the Department of Treasury and Finance website (http://dtf.vic.gov.au). 50 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 4.3 Other external reporting Direction A public sector agency must develop procedures to ensure that it meets all other external reporting requirements in a timely and accurate manner. The requirements include those contained in the Strategic Management Framework (SMF), as appropriate, and as issued from time to time by the Department of Treasury and Finance. Procedure a) Public sector agencies must identify all of their external reporting requirements. b) External financial reports must be delivered completely, accurately and in a timely manner. c) Prior to release, external financial reports must be reviewed by the CFAO or their delegate. d) and da) Refer to Direction 4.5.4 Guideline The Strategic Management Framework can be located on the Department of Treasury and Finance website (http://dtf.vic.gov.au). Only agencies that are connected to the Victorian government common virtual private network can access this site. Please contact your portfolio coordinator directly if you have problems with access. 4.4 Financial performance management and evaluation Direction Public sector agencies must develop appropriate financial management performance indicators and monitor performance against these to identify key statistics and trends for use in management decision-making. Procedure a) Financial key performance indicators (KPIs) must be developed by the Responsible Body working with management, including the CFAO and the Accountable Officer. b) The financial KPIs must be designed to measure and monitor financial management performance of the public sector agency. c) Performance against financial KPIs must be measured, monitored and reported on a regular basis (at least quarterly, unless the financial KPI is an annual measure) to the Responsible Body. d) The Responsible Body must ensure that procedures are implemented to monitor financial KPIs. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 51 Requirements for government departments e) Government departments must: set performance indicators for its departmental objectives in accordance with the business rules contained in Budget and Financial Management Guidance BFMG-08 Objectives Specification, Performance Indicators published by the Department of Treasury and Finance. set output performance targets in accordance with the business rules contained in Budget and Financial Management Guidance BFMG-09 Output Specification, Performance Measures published by the Department of Treasury and Finance. Guideline i. Regular measurement and reporting on performance indicators will promote a culture of continuous performance improvement. ii. Financial KPIs for individual financial management team members should be developed and included as part of their annual (or other) performance management process. These financial KPIs should be directly aligned with the financial KPIs of the financial management team as a whole. iii. Performance of financial management team members should be measured and monitored as part of the public sector agency’s performance management. iv. Financial KPIs should be aligned with key objectives of the finance function and Public sector agency as a whole and should be simple to use and understand. v. In terms of measuring a government department’s performance, financial KPIs should provide the tools for assessing the government department’s performance for the delivery of outputs (products and services) including the: attainment of departmental objectives; and delivery of departmental outputs. vi. BFMG-08 and BFMG-09 can be located in the Budget and Financial Management website (http://bfm.dtf.vic.gov.au). Only agencies that are connected to the Victorian government common virtual private network can access this site. Please contact your portfolio coordinator directly if you have problems with access. 4.5 Financial management compliance obligations 4.5.1 Compliance with Directions Direction Public sector agencies must certify that they have complied with all applicable Directions. Procedure Public sector agencies must— a) certify annually, using the form provided by DTF for the purpose, that they have complied with all applicable Directions; b) conduct an annual review of their obligations under these Directions; and c) identify and rectify any failure or deficiency in complying with these Directions. 52 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) Guideline Compliance with the Directions is generally monitored through the Financial Management Compliance Framework. Certification of compliance should be made annually to the Responsibly Body and/or audit committee (or equivalent). Those public sector agencies subject to the Financial Management Compliance Framework are also expected to certify their compliance with these Directions annually to their Relevant Minister as per the requirements of the Financial Management Compliance Framework. For more information on the Financial Management Compliance Framework, refer to the Department of Treasury and Finance website at http://dtf.vic.gov.au. 4.5.2 Taxation Direction Public sector agencies must demonstrate that they are complying with the legal requirements of the Commonwealth of Australia relating to taxation obligations and concessions. Procedures Public sector agencies must in respect of the requirements and regimes established under the laws of the Commonwealth of Australia— a) certify annually that they have met requirements in relation to taxation compliance and concessions; b) conduct an annual review of compliance with requirements in relation to taxation and concessions; c) develop and maintain taxation policies and procedures for use by agency staff; d) develop and implement a taxation education program for agency staff; and e) identify and rectify any taxation compliance issues. Guideline Compliance with the Taxation Direction and Procedure is monitored through the Taxation Compliance Rules and associated guidance. Certification of compliance should be made annually to the Responsibly Body and/or audit committee (or equivalent). Those public sector agencies subject to the Financial Management Compliance Framework are also expected to certify their taxation compliance status annually to their Relevant Minister as per the requirements of the Financial Management Compliance Framework. For more information on the Taxation Compliance Rules, refer to the Department of Treasury and Finance website at http://dtf.vic.gov.au. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 53 4.5.3 Purchasing card Direction Public sector agencies that operate a purchasing card must comply with the following Purchasing Card procedure. Procedure a) Public sector agencies which operate a purchasing card (‘card’) must: establish their own facility account, including a maximum monthly account limit, directly with the card provider; ensure only one card is issued to each employee approved as a cardholder; ensure cardholders use the Card for official business and that purchases of goods and services are for government purposes; require cardholders to provide supporting documentation for all transactions and ensure that monthly statements are reviewed and approved by the appropriate financial delegate, and that any discrepancies identified with the cardholder or provider are resolved in a timely manner; ensure cardholders hold a financial delegation and their individual transaction limits do not exceed this delegation; ensure that all individual card limits do not exceed $25 000, unless approved by the Minister for Finance; ensure adequate monitoring and security procedures are in place; include in the internal audit program a review of the Card scheme and the use of cards issued; and certify annually that they have followed this Purchasing Card procedure. See Guidelines 1 and 2 below b) The accountable officer must provide a written report to the Minister for Finance and the public sector agency’s audit committee in the event of a significant instance of unauthorised use of a purchasing card, as soon as an inquiry into the unauthorised use has been completed. See Guideline 3 below c) Each public sector agency to report annually to the Minister for Finance all instances of unauthorised use of its purchasing cards for the period ending 30 June. See Guideline 3 below Guidelines Guideline 1 Public sector agencies are required to report annually on their compliance with Procedure (a), as part of their annual compliance with the Directions generally. This is monitored through the Financial Management Compliance Framework. All instances of unauthorised use (as defined by the Purchasing Card Rules for Use and Administration (the Rules)) must be reported annually to the Minister for Finance, in accordance with Procedure (c). 54 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) In addition to the requirements above, in the event of a significant instance of unauthorised use of a purchasing card, in accordance with Procedure (b), the accountable officer must provide a written report to the Minister for Finance and the public sector agency’s audit committee as soon as an inquiry into the unauthorised use has been completed. A copy of this report should also be provided to the relevant Minister. Guideline 2 When implementing the necessary internal controls for the card, public sector agencies and cardholders are encouraged to apply the principles set out in the Rules, issued by the Department of Treasury and Finance. The Rules outline guiding principles and procedures that should be followed in relation to the use and administration of the Card. More detailed guidelines or policies, relating to the use and administration of the Card may also be issued by Public Sector Agencies subject to them being consistent with the Rules. For more information on the Rules, refer to the Department of Treasury and Finance website at http://dtf.vic.gov.au. Only agencies that are connected to the Victorian government common virtual private network can access this site. Please contact your portfolio coordinator directly if you have problems with access. Guideline 3 A significant instance of unauthorised use should be determined by reference to Section 7 ‘Unauthorised use’ of the Rules. 4.5.4 Thefts and losses Direction Public sector agencies must comply with the following thefts and losses procedure. Procedure a) The Responsible Body must ensure that all cases of suspected or actual theft, arson, irregularity or fraud in connection with the receipt or disposal of money, stores or other property of any kind whatsoever under the control of a public sector agency are notified to the Minister for Finance and the Auditor-General as follows: in respect to the receipt or disposal of money: – if the amount is equal to or exceeds $1 000, at the time of the occurrence with an incident report to be provided within two months; or – if the amount is less than $1 000 annually for the period ending 30 June together with an incident report. in respect to stores and property of any kind: – if the value is equal to or exceeds $20 000, at the time of occurrence with an incident report to be provided within two months; or – if the value is less than $20 000, annually for the period ending 30 June together with an incident report. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 55 b) an incident report prepared for the purposes of paragraph (b) must state, in addition to any other information that it appears appropriate to include: whether internal controls and systems have been reviewed; whether any weaknesses in internal controls and systems have been identified and have or will be rectified; the status of any proceedings, investigations or disciplinary actions; and what has been recovered, whether by way of money, stores, other property or insurance. Guideline The Thefts and Losses Rules set out the principles to be applied and followed in relation to the monitoring and reporting of instances of thefts and losses. Public sector agencies are required to report annually on their compliance with Procedures (a) and (b), as part of their annual compliance with the Directions generally. This is monitored through the Financial Management Compliance Framework. All instances of thefts and losses must be reported to the Minister for Finance and the Auditor-General, in accordance with Procedure (a) either at the time of occurrence or annually. In addition to the requirements above, the Accountable Officer must provide a written report to the Minister for Finance and the Auditor-General as soon as an inquiry into the theft or loss has been completed. A copy of any notification provided to the Minister for Finance and the Auditor-General should be provided to the relevant Minister. 4.5.5 Risk management framework and processes Direction The Responsible Body must ensure the public sector agency complies with the mandatory requirements set out in the Victorian Government Risk Management Framework. Procedure a) The Responsible Body must include a statement of attestation in the public sector agency’s annual report that the agency has complied with the mandatory requirements of the Victorian Government Risk Management Framework. b) For public sector agencies with an Audit Committee, this statement must be verified by the Audit Committee. Guideline Further guidance and a template statement of attestation is provided in the Victorian Government Risk Management Framework. 56 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 4.5.6 Treasury risk management Background The objectives of this Direction are to ensure that treasury risks are effectively identified, assessed, monitored and managed by public sector agencies, and that the strategies adopted by public sector agencies are consistent with the overall objectives of the Government. The State has a conservative philosophy for the management of treasury risks and accordingly, public sector agencies are encouraged to develop specific measures that best address the borrowing and investment risks of their business. Direction Public sector agencies are required to undertake all borrowings, investments and financial arrangements with a financial institution that is either a State owned entity or has a credit rating, assigned by a reputable rating agency, that is the same as or better than the State of Victoria4 subject to the following exceptions: where a public sector agency has been granted specific borrowing or investment powers under its constituting legislation, this Direction will not apply (see explanatory note); where the investment is cash on hand in a transactional bank account with an ADI; where the financial arrangement is a foreign currency hedging transaction of less than $1 000 000 undertaken with an ADI; where a public sector agency is operating a bank overdraft as part of its normal transactional banking operations; where amounts invested by the public sector agency with an ADI, excluding cash on hand in a transactional bank account, do not in aggregate exceed $2 000 000; where the public sector agency holds money, other than money held on trust for the State or a public body, invested pursuant to a statutory function to hold it on trust for a known beneficiary; or where, following consultation with the public sector agency’s portfolio Minister, the Treasurer has in writing approved otherwise. Explanatory note: Where a public sector agency merely has general powers to do things necessary or convenient to perform its functions or achieve its objects, this Direction will apply to that Agency’s borrowings or investments. Where specific borrowing and/ or investing powers are provided e.g. investment powers for registered funded agencies under the Health Services Act 1988, this Direction will not apply to those investments. Procedure Relevant public sector agencies must— a) conduct an annual review of their obligations under this Direction; and b) identify and rectify any failure or deficiency in complying with this Direction. 4 The State of Victoria was rated AAA by Standard and Poor’s and Moody’s at the time of issuing this Direction. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 57 Guideline This Direction requires that public sector agencies take the necessary steps to ensure a prudent approach to treasury management and requires that a sufficient level of attention be given to the risks associated with its operation. For example, as part of the Government’s prudent approach to treasury risk management, the Government has established the Treasury Corporation of Victoria (TCV) and the Victorian Funds Management Corporation (VFMC) to centrally manage the State’s borrowing, investing and financial market activities. Public sector agencies that conduct any borrowing and/ or investment transactions with these agencies would comply with this Direction. TCV manages the State’s borrowings and short-term deposits and facilitates financial arrangements to hedge, protect or manage the value of assets and liabilities. VFMC manages the State’s long-term investments and implements diversified investment strategies. Public sector agencies should be aware that TCV or VFMC do not offer bank overdrafts and leases. TCV can advise on appropriate funding, hedging and short term investing structures taking into account the financial requirements and risk appetite of the public sector agency. Where it is clear that an Agency has a long term investment need, the Agency can approach VFMC directly. Agencies investing with VFMC must also develop an investment policy statement that— a) contains guidelines for the management of the public body’s investments; b) prior to being formally made or changed, has been given to DTF in draft for review and comment; c) has been approved by the responsible body; and d) when made or changed, has been provided to DTF together with, for noting, a copy of the minute documenting the approval of the responsible body. The Department of Treasury and Finance can provide guidance with respect to this requirement (refer contact details below). Transition arrangements In terms of transition arrangements, there may be a number of public sector agencies that, prior to the issuance of this policy, have entered into short-term investments, such as term deposits with commercial banks that may incur break costs if they are withdrawn prior to maturity. Where substantial break costs for early withdrawal exist, these short-term investments are permitted to continue to maturity, after which the proceeds must be invested with the centralised agencies. Department of Treasury and Finance contact details: The Assistant Director, Financial Risk Management Department of Treasury and Finance Level 5, 1 Treasury Place Melbourne VIC 3002 58 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 4.5.7 Foreign exchange risk management Background The objectives of this Direction are to ensure that foreign exchange risks are effectively identified, assessed, monitored and managed by public sector agencies, and that the strategies adopted by public sector agencies are consistent with the overall objectives of Government. The State has a conservative approach to the management of foreign exchange risks and accordingly, public sector agencies are encouraged to develop specific measures that best address the foreign exchange risk of their business. Direction A public sector agency that has a foreign currency exposure that is in aggregate AUD1 000 000 or more and is known with certainty (with respect to the timing and a minimum quantity) must fully hedge the exposure. Except with the prior written approval of the Treasurer, all hedging transactions must be executed with TCV. A public sector agency that has a foreign currency exposure that is in aggregate less than AUD1 000 000 and is known with certainty must hedge the exposure where it is considered material. The transaction must be with TCV or an Authorised Deposit-Taking Institution (ADI). The accountable officer must verify that the requirements have been complied with. Exemptions to the requirements of this Direction may only be obtained with the written approval of the Treasurer. This Direction does not apply to foreign currency exposures incurred by a public sector agency where the funds are managed by VFMC, or by VFMC acting as trustee on behalf of a public sector agency, nor does it apply to money held on trust for the private sector. Procedure Relevant public sector agencies must— a) conduct an annual review of their obligations under this Direction; and b) identify and rectify any failure or deficiency in complying with this Direction. Guideline Foreign exchange risks are quantified by identifying all currently held assets and liabilities denominated in foreign currency and identifying contractually committed future currency transactions or cashflows. The foreign exchange exposure will exist until settlement or until the exchange rate is fixed. The foreign exchange exposure is determined by aggregating these balances by currency and settlement date and converting to Australian dollars at current forward exchange rates. Hedging transactions may only be closed out if a change in foreign currency receipts and payments occurs and retaining the transaction results in a change in exposure levels. Any funding bids that contain currency exposure should address the proposed currency hedging strategy. Bids should price future foreign currency denominated payments at the relevant forward rate which can be obtained from TCV. The preferred instrument for hedging foreign currency risks is a forward foreign exchange rate contract. An option strategy may be considered in exceptional circumstances, however this strategy will need to be supported by a justifiable business case. In addition, the option premium costs will need to be included in the funding bid. Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 59 For those public sector agencies which do not have legislative powers to enter into financial arrangements, they should contact the Department of Treasury and Finance to arrange for approval. Transition arrangements There may be a number of public sector agencies that, prior to the issuance of this direction, have entered into foreign currency hedges with financial institutions other than TCV. These hedging arrangements are permitted to continue to maturity, after which hedging transactions involving foreign currency exposures that is in aggregate of AUD1 000 000 or more must be executed with TCV. Department of Treasury and Finance contact details: The Assistant Director, Financial Risk Management Department of Treasury and Finance Level 5, 1 Treasury Place Melbourne VIC 3002 4.5.8 Commodity risk management Background The objectives of this Direction are to ensure that commodity risks are effectively identified, assessed, monitored and managed by public sector agencies, and that the strategies adopted by public sector agencies are consistent with the overall objectives of Government. The State has a conservative approach to the management of commodity risks and accordingly, public sector agencies are encouraged to develop specific measures that best address the commodity risk of their business. Direction A public sector agency is responsible for developing appropriate policies and procedures for managing exposure to specific commodity risk where it is considered these risks could have a material impact on the business. A public sector agency must consider whether fully hedging the exposure is appropriate. The accountable officer must verify that this requirement has been complied with. This Direction does not apply to commodity exposures incurred by a public sector agency where the funds are managed by VFMC, or by VFMC acting as trustee on behalf of a public sector agency, nor does it apply to money held on trust for the private sector. Procedure Relevant public sector agencies must— a) conduct an annual review of their obligations under this Direction; and b) identify and rectify any failure or deficiency in complying with this Direction. Guideline Where a public sector agency has a material exposure to commodity risk, it should consider fully hedging the exposure where it is known with certainty (with respect to the timing and quantity) and there are hedging instruments available in financial markets to provide an effective hedge that is also cost effective. 60 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) In accordance with Standing Direction 4.5.6 a hedging transaction must be executed by TCV. Should TCV be unable to offer a suitable hedging product, Treasurer’s approval is required to transact with an alternative counterparty. For those public sector agencies which do not have legislative powers to enter into financial arrangements, they should contact the Department of Treasury and Finance to arrange for approval. Transition arrangements There may be a number of public sector agencies that, prior to the issuance of this direction, have entered into commodity hedges with financial institutions other than TCV. These hedging arrangements are permitted to continue to maturity, after which hedging transactions must be executed with TCV. Department of Treasury and Finance contact details: The Assistant Director, Financial Risk Management Department of Treasury and Finance Level 5, 1 Treasury Place Melbourne VIC 3002 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015) 61 www.dtf.vic.gov.au 2 Standing Directions of the Minister for Finance under the Financial Management Act 1994 (as part of the financial management package), June 2003 (updated May 2015)