MENA FCCG ANTI BRIBERY AND CORRUPTION (ABC) ASSESSMENT QUESTIONNAIRE

Integrity, transparency, and the fight against corruption have to be part of the culture
and taught as fundamental values – Ángel Gurría, OECD Secretary General

MENA FCCG ABC Assessment Questionnaire

2020
MENA FCCG ABC ASSESSMENT QUESTIONNAIRE - TABLE OF CONTENTS

Questionnaire Components
Introduction
Purpose
Scope & Structure
Frequency
Rating
ABC Assessment Areas
1. Tone at the top
2. Risk Assessment
3. Training and Awareness
4. Control Environment
5. Hiring Practices and Enforcement
6. Facilitation Payments
7. Gifts, Entertainment and Hospitality
8. Third Parties
9. Subsidiaries & Significant Investments
10. Political Contributions
11. Charitable Contributions
12. Sponsorships
13. External Communication
14. Driving Collective Impact

MENA FCCG ABC Assessment Questionnaire

2020
MENA FCCG ABC ASSESSMENT QUESTIONNAIRE - INTRODUCTION

PURPOSE
MENA FCCG has developed this ABC Assessment Questionnaire to provide a practical approach for organizations to self evaluate their level of compliance
with ABC best practice requirements and identify control enhancements as necessary to mitigate bribery risks across the organization. The document is based
on leading practices as well as the expertise of MENA FCCG’s Technical Working Committee.

SCOPE & STRUCTURE

The ABC assessment is segmented into 14 areas. The areas have been grouped to enable organizations to conduct the assessment of the perceived levels of
risk, as well as level of compliance and organizational effectiveness of each section or sub section to ensure the organization is conducting business in
conformity with the highest ethical standards and in accordance with anti-bribery and corruption best practice. The questionnaire requires a 1-5 rating
response (relevant columns to be ticked), and includes provision for written responses. Once each section is completed, the weighted score will be able to
identify the overall perceived level of risk, compliance, and effectiveness of the ABC program. The self assessment ratings are: Strong, Satisfactory, Marginally
Satisfactory, Needs Improvement, and Weak.

FREQUENCY
The Questionnaire should be reviewed and updated regularly as internal and external bribery and corruption risks evolve. Reviews can be triggered by the
approval of new products or businesses or new legal or regulatory developments. Periodic reviews can be undertaken on a semi-annual basis to assess the
overall effectiveness and efficiency of the ABC Program.

MANAGING THE SCORECARD

The initial rating is based on MENA FCCG’s Technical Working Committee feedback. However, the rating is flexible and customizable based on each
organization’s risk profile and activity type. When adding or deleting factors, you must ensure the scorecard equation is appropriately adjusted; factors within
each area and sub-factors within each factor should add up to 100.

MENA FCCG ABC Assessment Questionnaire

2020
MENA FCCG ABC ASSESSMENT QUESTIONNAIRE - RATING

Risk Rating Criteria

LEVEL OF CONTROL EFFECTIVENESS

No Controls - Weak Needs Improvement Marginally Satisfactory Satisfactory Strong

0-1 2 3 4 5

ABC Program Overall Assessment Ratings

Management is committed and is employing industry leading practices to proactively identify and mitigate risk. Compliance management processes can be characterized as fully
Strong effective, formal and well-supported, thereby minimizing the likelihood of material loss and/or adverse publicity due to risk exposure. 

Operating procedures and practices are fully satisfactory. Management oversight and systems are deemed responsive and capable of identifying and addressing gaps on a timely
Satisfactory basis thereby reducing exposure to material loss and/or adverse publicity. 

Marginally Operating procedures and practices are minimally acceptable. Opportunities exist to strengthen the compliance program and address identified gaps to minimize exposure to
Satisfactory material loss and/or adverse publicity. 

Shortcomings exist, with a large number of requirements not being met, increasing the likelihood of financial, legal, and reputational damage including fines and civil penalties.
Needs Improvement Management must take immediate corrective action and implement enhancements to address identified weaknesses.

Existing controls and practices are ineffective to mitigate risk, leading to high likelihood of financial, legal, and reputational damage including potential restrictions on the
Weak organization’s activities or loss of license and potential civil and criminal liabilities including against the organization’s Management. Management must address and fix these
vulnerabilities as high priority.

MENA FCCG ABC Assessment Questionnaire

2020
 Area Driver Weight Factor Factor Weight

Zero Tolerance 25%

Top Level Commitment 25%

1. Tone at the Top 7%

Definition and Scope 25%

Accountability 25%
 Accountability 25%

Driver Sco

Risk Assessment 50%

Elements

2. Risk Assessment 7%

Risk Assessment Design 50%

Driver Sco

New Hires 17%

 New Hires 17%

Ongoing Awareness and 17%

Training

3. Training and 7% Risk- Based Training 17%

Awareness

Access and Availability 17%

Record Keeping 17%

Disclosure 17%
 Driver Sco

Whistleblowing 14%
Framework

Record Keeping 14%

Monitoring 14%

4. Control 7%
Environment
Ongoing Enhancement 14%
 4. Control 7%
Environment
Ongoing Enhancement 14%

Independent Assurance 14%

Reporting 14%

External Assurance 14%

 External Assurance 14%

Driver Sco

Hiring guidelines 50%

5. Hiring Practices and 7%

Enforcement

Enforcement 50%

Driver Sco

Prohibition Policy 50%

6. Facilitation 7%
Payments

Policy Enforcement 50%

 Policy Enforcement 50%

Driver Sco

Gifts 33%

7. Gifts, Entertainment 7%
and Hospitality
Entertainment and 33%
Hospitality

Compliance Enforcement 33%

Driver Sco
 Policies and Procedures 20%

Contractual obligations 20%

8. Third Parties

7%

Due Diligence 20%

 Due Diligence 20%

Awareness and Training 20%

Monitoring 20%

Driver Sco

Subsidiaries 50%

9. Subsidiaries &
Significant 7%
Investments
9. Subsidiaries &
Significant 7%
Investments

Significant Investments 50%

Driver Sco

Policies and Procedures 33%

10. Political
Contributions
7% Control Mechanism 33%

Recording and Reporting 33%

Driver Sco

Control Mechanism 50%

11. Charitable 7%
Contributions
 Control Mechanism 50%

11. Charitable 7%
Contributions

Recording and Reporting 50%

Driver Sco

Policies and Procedures 50%

12. Sponsorships 7%

Recording and Reporting 50%

Driver Sco

13. External 7% Policy Transparency 100%

Communication

Driver Sco

14. Driving Collective 7% External Engagements 100%

Impact

Driver Sco
 Overall Assessment Sc
100%
 MENA FCCG
Sub Factor

There is a policy of zero tolerance to bribery that has been formally approved by the board or equivalent body
The bank has a Code of Conduct or equivalent policy document that includes an explicit statement of the no-bribes policy
The bank has a high level public statement such as a Corporate Values statement that includes a commitment to business integrity
Factor Score
Board members have received written guidance on their responsibilities related to the program including the expectations for their own integrity
The CEO is responsible to ensure that the program is carried out consistently with clear lines of authority
There is a procedure for dealing with breaches of the program by directors
The board of directors or equivalent body provides oversight to the program
The board and senior management are familiar with applicable laws and regulations and leading practices
The board of directors or equivalent body has formally approved the program
Anti-bribery is included on board meeting agendas
The board receives regular reports on the implementation of the program
Accurate and informative Management Information (MI) is provided to the Senior Management and the Board
Factor Score
The bank's definition of bribery is comprehensive and is consistent with applicable legislation and leading practices
There is a procedure to ensure bank policy is consistent with relevant anti-bribery laws in all the jurisdictions in which the bank maintains a presence
There is a procedure to ensure the program is consistent with all relevant anti-bribery laws in all the jurisdictions in which bank transacts its business
Factor Score
Clear responsibility and authority is assigned to managers for carrying out the program
A senior manager has responsibility for implementing the program
A project manager has responsibility for the detailed implementation of the program
The assigned manager/project manager are responsible for ensuring program clearly and in reasonable detail, articulates values, policies and procedures to be used to preven
under the bank’s effective control
The assigned manager/project manager maintain a register of anti-bribery laws and monitor changes to laws, regulations, and best practice
Factor Score

Driver Score
Responsibility for regular risk assessment for bribery is assigned

Risk assessment process takes into consideration the countries of operation corruption risk level (using CPI or other risk ranking system)
Risk assessment process takes into consideration the extensive use of third parties
Risk assessment process takes into consideration dealings with government officials
The risk assessment process identifies and prioritizes risks from bribery
Risk Assessment takes into account human rights violations such as forced labor and slavery
The risk assessment process is carried out on a continuous basis to assess and prioritize the risk of bribery
Factor Score
The procedure for regular risk assessment for bribery extends to all operations under the bank’s effective control
Detailed policies and procedures to counter bribery are developed and improved based on the assessed risks
The bank has a procedure to ensure that it is informed of all internal and external matters material to the effective development and implementation of the program, and in p
The bank reports publicly, as required, on the risks identified
Data analytics processes are in place to better identify bribery and corruption activity or data misuse
There is a procedure for recording and capturing all incidents / attempts of bribery and corruption
Factor Score

Driver Score
There are procedures to ensure appropriate induction/orientation training is given to recruits so that they clearly understand the bank’s program, know the bank’s expectatio
event of a violation
There are procedures governing new hires training including time-frame during which training must be completed (e.g. within 3 months of hiring)
There is appropriate tracking and reporting of new hires training to ensure it abides with set timeframe
End of probationary period is contingent upon completion of induction training
Factor Score
There are procedures for delivering refresher training on the program across the organization
There is a procedure to ensure ongoing circulations across the organization on anti-corruption developments such as new regulations, enforcement actions, and best practice

There is a procedure for ensuring the refresher training is updated to reflect changes in regulatory mandates, risks, and evolving best practice
The results of the training are reported to the Board / Committee of the Board
Factor Score
The bank tailors its training based on its overall risk assessment results
Staff in higher risk positions receive specific tailored training (e.g. employees involved in procurement, sponsorships, events management, offer employment opportunities…e
The bank provides training on the program to third parties using a risk based approach
Factor Score
The bank has procedures for communicating its program in an accessible way to all its employees
There is a procedure to provide written guidelines on the program to all employees
The bank publishes information on the number/percentage of employees that have signed that they have read the Bank’s anti-bribery guidelines
Factor Score
Training programs are followed by an assessment with a minimum passing score
Directors and employees’ records include documentation of anti-bribery training received whether induction or refresher training
Factor Score
The bank reports publicly on the extent and quality of its anti-bribery training
The bank reports publicly on measures of training provided to employees
The bank reports publicly on measures of training provided to third parties (i.e. suppliers and vendors)
Factor Score
 Driver Score
The bank provides secure and accessible channels through which employees can seek advice on the application of the program and raise concerns and report violations (‘whis
risk of reprisal
Employees are also required to report potential violations to human rights such as forced labor or slavery observed from customers or third parties
There are secure and accessible communication channels that encourage and allow business partners or other external parties to raise concerns and report violations (‘whistl
of reprisal
The bank circulates ongoing communication and awareness across the organization on the significance of whistleblowing as a means of encouraging reporting of any miscondu
The bank conducts proper analysis on whistleblowing incidents and undertakes actions to address root causes as applicable
The Board receives regular reporting on whistleblowing incidents including action taken and confirmation of appropriate resolution
Factor Score
The internal controls include financial and organizational checks over accounting and record keeping practices
There are procedures to examine contracting and purchasing procedures regularly where risks of bribery apply
There are procedures to maintain accurate books and records that properly and fairly document all financial transactions
There are procedures to ensure that there are no 'off-the-books' accounts, inadequately defined transactions or false entries
There is a procedure to ensure the accounting and recordkeeping practices, are subject to regular internal audits to ensure they are effective in countering bribery
Factor Score
There is a procedure to monitor the effective operation of the program covering all key aspects
There is a procedure to monitor employee accounts
There is a procedure to monitor pooled accounts
There is a procedure for dealing with incidents of bribery
Root cause analysis in relation to past incidents and near misses are conducted
High Risk Data sets are being Safeguarded from potential misuse by corrupt individuals
Factor Score
Continuing and/or discrete evaluations are performed supporting the continuous improvement of the program
The bank deploys specific KRIs/KPIs to encourage and measure progress in improvement of the program and its implementation
Discussions are held with stakeholders especially suppliers and contractors to obtain their views on the program
The bank benchmarks its program internally between business units
The bank benchmarks its program externally
The bank participates in anti-corruption initiatives and business sector groups to learn best practices to improve its program
Self-evaluations are carried out and the results applied to improve the program
Factor Score
There is a procedure for ensuring that there is an adequate audit trail to support all recorded transactions

The bank performs audit of financial records for third party payments
The bank performs audit of gifts logs and entertainment records
The bank performs audit of financial records for charitable and political contributions
The scope of audit specifically includes potential conflict of interest in key areas such as Procurement and Treasury
There is a procedure to discuss the results of internal audits of the program with relevant operational personnel
There is a procedure to ensure that the internal control systems, in particular the accounting and record keeping practices, are subject to regular internal audits to provide ass
countering bribery
There is a procedure for the Audit Committee, Compliance Committee, the board or equivalent body to make an independent assessment of the adequacy of the program
Factor Score
There is a procedure for senior management to monitor the program and periodically review its suitability, adequacy and effectiveness and implement improvements as appro
There is there a procedure for senior management to periodically report the results of program reviews to the audit committee, governance committee, board or equivalent b
There is a procedure for prompt reporting of any issues or concerns to senior management and the board

The bank has a procedure for self-reporting bribery incidents as appropriate to the authorities
Factor Score
External consultants are used to monitor and advise on the program
The board or equivalent body has considered whether to commission external verification or assurance of the program
An external verification or assurance has been conducted
The verification or assurance opinion has been published publicly
Factor Score

Driver Score
The recruitment process includes procedures to ensure that it is fair, transparent, and free from bribery and nepotism and preserves human rights
Appropriate due diligence is carried on prospect employees
The bank has procedures to communicate clearly to employees the sanctions that would be applied in the event of violation of its program
The bank delivers special communication to employees in higher risk functions (e.g. procurement, sponsorships)
Factor Score
There is a policy to make compliance with the program mandatory for employees
Employees are required to read and sign annually that they have read the Code of Conduct
Job descriptions of employees in sensitive positions (e.g. Procurement, Treasury, RMs) embed the requirement to apply the program
Employees’ annual performance assessment and promotion takes into consideration commitment to implement the program
There are procedures to apply appropriate sanctions to employees in the event of breach of the program up to and including termination in appropriate circumstances
Factor Score

Driver Score
There is a written policy prohibiting facilitation payments
The policy includes a clear definition of facilitation payments
There are detailed procedures and controls based on a risk assessment to implement the facilitation payments policy
Factor Score
A risk assessment has been carried out to confirm that no facilitation payments have been paid
Preparatory work has been carried out to deter demands for such payments
Training and guidance is provided to employees likely to encounter risks of facilitation payments on how to deal with them
The policy on facilitation payments is made clear to third parties, agents, and other intermediaries
Implementation of the policy on facilitation payments is monitored
Senior management reviews regular reports on implementation of the zero tolerance policy to facilitation payment
Factor Score

Driver Score
The bank has written policies covering Gifts
There are procedures and controls, including thresholds and reporting procedures, to ensure that the bank’s policies relating to Gifts are followed
The procedures on gifts include specified and clear monetary thresholds
There is a procedure to ensure that Gifts conform to the laws of the countries where they are made or received
There is a procedure to communicate to employees the guidelines for Gifts
There are appropriate and comprehensive logs maintained on gifts including amount, recurrence, justification, and approvals
The Bank’s gifts log is accessible to Compliance
Factor Score
The bank has written policies covering entertainment and hospitality
There are procedures and controls, including thresholds and reporting procedures, to ensure that the bank’s policies relating to entertainment and hospitality are followed
The procedures on entertainment and hospitality include specific and clear monetary thresholds
There is a procedure to ensure that entertainment and hospitality conform to the laws of the countries where they are made or received
There is a procedure to communicate to employees the guidelines for entertainment and hospitality
Factor Score
Tailored training is given to employees on the rules for gifts, hospitality and expenses
Gifts, hospitality and expenses given are recorded accurately in the books
Special Codes of Conduct / rules are circulated to staff in higher risk functions to enforce ongoing compliance (e.g. Procurement, Treasury)
Gifts, hospitality and expenses given or received are documented and reviewed by management to ensure compliance
Factor Score

Driver Score
The bank has defined and identified the forms of third party and the scope of the third's party involvement in its policy
The bank has a procedure to inform prospective third parties of its process for engaging and working with third parties, including its anti-corruption commitments and practice
The bank has a procedure to inform prospective third parties of its practices in relation to human rights issues including slavery and foced labor
There is a procedure to ensure that the third party has a program that is consistent with the bank’s program
There is a procedure to avoid dealing with contractors and suppliers known or reasonably suspected to be paying bribes
The bank has thresholds of authority for approving the business case prior to appointment of third parties
There are procedures to ensure the avoiding of nepotism and possible conflict of interest
There is a procedure to contractually require third parties to keep proper books and records available for inspection by the bank, auditors or investigating authorities
There is there is a procedure to monitor the conduct of third parties
There are policies to ensure compensation paid to third parties is paid legitimately & through bona fide channels (including prohibition on the use of off-shore accounts)
There is a procedure to fully document all material aspects of the bank relation with the third party
There is a procedure to communicate clearly to third parties the sanctions for violating any of the program elements
Factor Score
The Third Party is required to acknowledge through a Code of Conduct or another document that they will refrain from any unacceptable behavior or practice including briber

Contracts with third parties specifically prohibit the third party from engaging in corruption, human rights violations, or other illegal activity
Contracts with third parties grant the bank the “right to exit” if in its judgment the third party has engaged in corrupt practices, human rights violations, and other illegal activi

Contracts with third parties allow the bank to access the third party’s records and to perform audits on the third party to ensure commitment
Factor Score
There is a procedure for properly documenting risk-based due diligence reviews before appointing third parties
The bank implements a comprehensive methodology for risk rating third parties (e.g. geographic area, third party type/structure, services being acquired, spend level, contrac

The bank assigns Risk Rating for potential and existing third parties

The bank carries out due diligence that is proportionate to the risk rating assigned to the third parties, focusing on those of highest risks
The bank's due diligence includes obtaining a detailed business profile 
The bank's due diligence includes screening of key persons (i.e. General Manager, Members of the Management Body, Key Personnel, and Authorized Signatories ) against san

The bank's due diligence includes checking media, social media, open source information on the third party and key persons (i.e. General Manager, Members of the Managem
Authorized Signatories )

The bank's due diligence includes screening against Politically Exposed Persons (PEPs) lists for key persons (i.e. General Manager, Members of the Management Body, Key Per

The bank's due diligence includes conducting background checks on key persons (i.e. General Manager, Members of the Management Body, Key Personnel, and Authorized Sig
The bank's due diligence includes a procedure for assessing if the proposed fees and other contractual considerations are appropriate and justifiable for the services to be ren
If the due diligence exercise shows risks above normal, the employee involved in the assessment is required to notify the ABC Champion/ Control Committee
The frequency and depth of reviews on third party relationships matches their assessed risk rating.
Factor Score
The bank provides tailored training to employees who manage or interact with third parties
The bank provides regular training to third party employees using a risk based approach
The bank provides whistle blowing channels to be used by third parties
Factor Score
Changes to third party bank account details are monitored
There is a procedure for properly documenting procedural breaches
There is a procedure for properly documenting the investigations performed in case of a breach .
Factor Score

Driver Score
There is a policy to implement the bank's program in all business entities over which it has effective control
There are procedures for applying this policy
There is a procedure to carry out due diligence on 'legacy risks' for mergers and acquisitions
The bank reports publicly the extent to which the program is implemented in all the entities under the bank’s effective control
Factor Score
There is a policy to encourage the implementation of a program equivalent to its own in companies in which the bank has a significant investment
There is a procedure for applying this policy
The bank carries out due diligence on its significant investments before entering into them
The bank monitors its significant investments periodically to check that their anti-bribery programs are adequate and working

Driver Score
There are written policies and procedures that include a definition of political contributions and cover political contributions whether made directly or indirectly
The policy and procedures reflect the particular risks of political contributions being used as a subterfuge for bribery
If the policy is to allow and make political contributions, the policy specifies that political contributions shall be in accordance with applicable law
Factor Score
There are procedures and controls to ensure that political contributions are not used as a subterfuge for bribery
If the policy is not to make political contributions, the bank has procedures to prevent political contributions being made
If the policy is to allow and make political contributions, there is a review and approval procedure with designated levels of approval
The review and approval procedures include checks to ensure that political contributions are not made directly or indirectly to political parties, organizations or individuals en
advantage in business transactions
If the bank uses politicians as consultants, it has procedures for their appointment and checks that fees paid represent appropriate and justifiable remuneration for the service
There are procedures to ensure that those retained to advocate on the bank’s behalf know and observe the bank’s policy on contributions and responsible advocacy
Factor Score
There is a procedure to record any political contributions made accurately in the books
The bank publishes details of all political contributions made by the bank and its subsidiaries or a statement that it has made none
The bank publishes details of the top issues on which it makes advocacy
Factor Score

Driver Score
There is a written policy covering charitable contributions
There is a review and approval procedure for charitable contributions with designated levels of approval
There are procedures and controls to ensure that charitable contributions are not used as a subterfuge for bribery
There is a procedure to carry out due diligence on recipient bodies to ensure no Public Official is associated with the body that will gain an advantage in the conduct of busines
Factor Score
There is a procedure to record charitable contributions accurately in the books
The bank publishes details of all charitable contributions made by the bank
Factor Score

Driver Score
There is a written policy covering sponsorship
There are procedures and controls to ensure that sponsorships are not used as a subterfuge for bribery
There are procedures for approval and payment of sponsorships which are in line with the normal purchasing procedures
There is a procedure to carry out due diligence on recipient bodies that ensure no Public Official is associated with the body that will gain an advantage in the conduct of busin
Factor Score
There is a procedure to record sponsorships accurately in the books
A list of sponsorships made is published publicly
Factor Score

Driver Score
There is a policy to publicly disclose information about the program including the management systems employed to ensure its implementation
The bank reports on its anti-bribery program aligned to the Global Reporting Initiative Sustainability Reporting Framework
Factor Score

Driver Score
The bank is a member of a sector anti-bribery initiative or working group
The bank takes action in enhancing awareness and delivering training on anti-corruption and bribery
The bank takes part in local collective action to counter bribery
Factor Score

Driver Score
Overall Assessment Score & Rating
Corruption Assessment Questionnaire

Sub Factor Weight Control Effectiveness (0 – 5) Weighted Score Justification for rating and reference to supporting documentation

33% 1 0.01
33% 1 0.01
33% 1 0.01
100% 1.00 0.02
11% 1 0.00
11% 1 0.00
11% 1 0.00
11% 1 0.00
11% 1 0.00
11% 1 0.00
11% 1 0.00
11% 1 0.00
11% 1 0.00

100% 1.00 0.02

33% 1 0.01
33% 1 0.01
33% 1 0.01

100% 1.00 0.02

20% 1 0.00
20% 1 0.00
20% 1 0.00

20% 0.00
1
20% 1 0.00

100% 1.00 0.02

1.00 0.07
14% 1 0.01
14% 1 0.01
14% 1 0.01
14% 1 0.01
14% 1 0.01
14% 1 0.01
14% 1 0.01

100% 1.00 0.04

17% 1 0.01
17% 1 0.01
17% 1 0.01
17% 1 0.01
17% 1 0.01
17% 1 0.01

100% 1.00 0.04

1.00 0.07

25% 0.00
1
25% 1 0.00
25% 1 0.00
25% 1 0.00

100% 1.00 0.01

25% 1 0.00
25% 1 0.00
25% 1 0.00
25% 1 0.00
100% 1.00 0.01
33% 1 0.00
33% 1 0.00
33% 1 0.00
100% 1.00 0.01
33% 1 0.00
33% 1 0.00
33% 1 0.00
100% 1.00 0.01
50% 1 0.01
50% 1 0.01
100% 1.00 0.01
33% 1 0.00
33% 1 0.00
33% 1 0.00
100% 1.00 0.01
 1.00 0.07
17% 0.00
1
17% 1 0.00

17% 0.00
1
17% 1 0.00
17% 1 0.00
17% 1 0.00
100% 1.00 0.01
20% 1 0.00
20% 1 0.00
20% 1 0.00
20% 1 0.00
20% 1 0.00
100% 1.00 0.01
17% 1 0.00
17% 1 0.00
17% 1 0.00
17% 1 0.00
17% 1 0.00
17% 1 0.00
100% 0.01
1.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
100% 1.00 0.01
13% 1 0.00
13% 1 0.00
13% 1 0.00
13% 1 0.00
13% 1 0.00
13% 1 0.00

13% 0.00
1
13% 1 0.00
100% 1.00 0.01
25% 1 0.00
25% 1 0.00
25% 1 0.00
25% 1 0.00
100% 1.00 0.01
25% 1 0.00
25% 1 0.00
25% 1 0.00
25% 1 0.00
100% 1.00 0.01
1.00 0.07
25% 1 0.01
25% 1 0.01
25% 1 0.01
25% 1 0.01

100% 1.00 0.04

20% 1 0.01
20% 1 0.01
20% 1 0.01
20% 1 0.01
20% 1 0.01

100% 1.00 0.04

1.00 0.07
33% 1 0.01
33% 1 0.01
33% 1 0.01
100% 1.00 0.04
17% 1 0.01
17% 1 0.01
17% 1 0.01
17% 1 0.01
17% 1 0.01
17% 1 0.01
100% 1.00 0.04
1.00 0.07
14% 1 0.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
14% 1 0.00
100% 1.00 0.02
20% 1 0.00
20% 1 0.00
20% 1 0.00
20% 1 0.00
20% 1 0.00
100% 1.00 0.02
25% 1 0.01
25% 1 0.01
25% 1 0.01
25% 1 0.01
100% 1.00 0.02
1.00 0.07
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
8% 1 0.00
100% 1.00 0.01
25% 0.00
1
25% 1 0.00
25% 0.00
1
25% 1 0.00
100% 1.00 0.01
8% 1 0.00

8% 0.00
1
8% 0.00
1
8% 0.00
1
8% 1 0.00
8% 0.00
1

8% 0.00
1

8% 0.00
1
8% 0.00
1
8% 1 0.00
8% 1 0.00
8% 1 0.00
100% 1.00 0.01
33% 1 0.00
33% 1 0.00
33% 1 0.00
100% 1.00 0.01
33% 1 0.00
33% 1 0.00
33% 1 0.00
100% 1.00 0.01
1.00 0.07
25% 1 0.01
25% 1 0.01
25% 1 0.01
25% 1 0.01
100% 1.00 0.04
33% 1 0.01
33% 1 0.01
33% 1 0.01
100% 1.00 0.04
1.00 0.07
33% 1 0.01
33% 1 0.01
33% 1 0.01
100% 1.00 0.02
17% 1 0.00
17% 1 0.00
17% 1 0.00
17% 1 0.00
17% 1 0.00
17% 1 0.00
100% 1.00 0.02
33% 1 0.01
33% 1 0.01
33% 1 0.01
100% 1.00 0.02
1.00 0.07
25% 1 0.01
25% 1 0.01
25% 1 0.01
25% 1 0.01
100% 1.00 0.04
50% 1 0.02
50% 1 0.02
100% 1.00 0.04
1.00 0.07
25% 1 0.01
25% 1 0.01
25% 1 0.01
25% 1 0.01
100% 1.00 0.04
50% 1 0.02
50% 1 0.02
100% 1.00 0.04
1.00 0.07
50% 1 0.04
50% 1 0.04
100% 1.00 0.07
1.00 0.07
33% 1 0.02
33% 1 0.02
33% 1 0.02
100% 1.00 0.07
1.00 0.07
1.00 1.00
ABC Champion/ Control Committee Testing/Monitoring Performed Actions Needed to Strengthen Controls
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