Final 0 Fiduciar 0 N 0 Program 000 P174650

Fiduciary System Assessment Bangladesh Electricity Distribution Modernization Program(P174650)
ELECTRICITY DISTRIBUTION MODERNIZATION PROGRAM (P174650)
People’s Republic of Bangladesh
PROGRAM-FOR-RESULTS
FIDUCIARY SYSTEMS ASSESSMENT
November 29, 2021

ABBREVIATIONS AND ACRONYMS
ADMS Advanced Distribution Management System

ACG Anti-Corruption Guidelines
AMI Advanced Metering Infrastructure
BACS Budget and Accounts Classification System
BREB Bangladesh Rural Electrification Board
BERC Bangladesh Energy Regulatory Commission
BESS Battery Energy Storage System
CTF Clean Technology Fund
DLI Disbursement Linked Indicator
e-GP e-Government Procurement Portal
FSA Fiduciary Systems Assessment
FMIS Financial Management Information System
GOB Government of Bangladesh
HR Human Resource
iBAS Integrated Budget and Accounting System
IDA International Development Association
IPSASB International Public-Sector Accounting Standards Board
MPEMR Ministry of Power, Energy, and Mineral Resource
MIS Management Information System
MTBF Medium-Term Budget Framework
OC&AG Office of Comptroller and Auditor General
PAP Program Action Plan
PBS Palli Biyut Samiti
PDO Program Development Objective
PforR Program for Results
PMAP Project Management Accounting Portal
SCADA Supervisory Control and Data Acquisition
SOE State Owned Enterprise
Table of Contents
EXECUTIVE SUMMARY........................................................................................................................III
INTRODUCTION..................................................................................................................................IV
SECTION 1: CONCLUSIONS....................................................................................................................1
1.1 Reasonable assurance.............................................................................................................1
1.2 Risk assessment......................................................................................................................1
1.3 Procurement exclusions..........................................................................................................2
SECTION 2: SCOPE OF FSA....................................................................................................................2
SECTION 3: REVIEW OF COUNTRY PUBLIC FINANCIAL MANAGEMENT CYCLE........................................2
3.1 Planning and budgeting..........................................................................................................2
3.2 Budget execution....................................................................................................................6
3.3 Internal controls.....................................................................................................................8
3.4 Auditing................................................................................................................................10
3.5 Procurement and financial management capacity.................................................................10
SECTION 4: PROGRAM SYSTEMS AND CAPACITY IMPROVEMENTS......................................................11
SECTION 5: IMPLEMENTATION SUPPORT............................................................................................12
ANNEX 1: BUDGET AND ACCOUNT CLASSIFICATION SYSTEM (BACS)...................................................13
iii
EXECUTIVE SUMMARY
1. The objective of the Fiduciary System Assessment (FSA) is to assess the adequacy of Program
fiduciary systems. It assesses if these systems provide reasonable assurance that the financing proceeds
will be used for the intended purposes, with due attention to the principles of economy, efficiency, fit-
for-purpose, value for money, integrity, transparency, and fairness. The FSA comprises separate
assessments of the risks relating to the Program’s procurement, financial management, and fraud and
corruption aspects.
2. The FSA for this Program is based on review of existing assessments as well as consultations
with key stakeholders. Key documents reviewed include Country Public Expenditure and Financial
Accountability assessments, the Public Financial Management Reform Action Plan (2018-23), Rural
Bridge Maintenance Program, Value Added Tax Modernization Program, and the assessments for
Secondary Education Development Program. It also synthesizes consultations with the key stakeholders
on core fiduciary issues and challenges. The financial management systems were reviewed to assess the
extent to which the planning, budgeting, accounting, controls, funds flow, financial reporting and
auditing systems, and practices provide reasonable assurance on the appropriate use of funds and
safeguarding of assets within the existing financial management framework of the country. Similarly, the
procurement systems have also been assessed to establish the extent to which the arrangements and
practices provide a reasonable assurance in support of achievement of the Program results. In addition,
the assessment considered how the country governance systems manage the risks of fraud and
corruption and how such risks will be mitigated.
3. The five-year Program cost is estimated to be US$ 902 million. The planned contribution from
International Development Association (IDA) and Clean Technology Fund is US$ 500 million and US$15
million, respectively.
4. The FSA finds that Program fiduciary systems are sound and can be expected to enable the
government to implement the Program efficiently and provide reasonable assurance that the financing
proceeds will be used for intended purposes. However, there are areas for improvement that could
potentially affect Program implementation such as delays in preparing Program financial statements,
capacity constraint in auditing result based financing, delays in resolution of audit observations, lack of
professional resources in financial management and internal audit , delay in procurement process,
inappropriate bidding practices undertaken by the bidders, time over-run and cost over-run during
contract implementation, lack of strategic procurement planning and lack of systematic monitoring of
procurement performance and outcomes.
5. A Program Action Plan focusing both on risk mitigation as well capacity building was agreed
with implementing agencies and is included in this assessment. The implementation progress of the
Program Action Plan will be reviewed periodically during the implementation of the Program.
iv
SECTION 0: INTRODUCTION
1. BREB in the last decade successfully implemented one of the largest rural electrification
programs in the world, delivering access to more than 90 million people. With the access agenda
nearing completion, the Government is keen to focus on BREB’s modernization and network
transformation.
2. The Government has prepared program for Modernization and Capacity Enhancement of
BREB to respond to challenges in electricity distribution. The program aims to (i) upgrade and enhance
capacity of rural electrical distribution network; (ii) meet the projected increase in electricity demand;
(iii) provide access to reliable, affordable, and efficient power supply to consumers and (iv) reduce
system loss of the distribution system. The Government’s program will cover all 80 PBSs in BREB, which
together supply about half of the electricity in the country and cover the entire country except Dhaka
and some other urban areas. The program comprises of four geographical areas: Dhaka-Mymensingh
Division, Chittagong-Sylhet Division, Khulna-Barishal Division and Rajshahi-Rangpur Division, as well as
institutional and regulatory strengthening. The program will cover the period from 2021-2026 and will
require approximately US$3.2 billion of investments over the period.
3. The proposed Program-for-Results (PforR) operation will support a part of the overall
Government program—with a focus on network strengthening, expansion, and rehabilitation to ease
existing constraints and meet the rapidly growing demand in BREB’s Dhaka-Mymensingh Division. These
network investments will be paired with new and transformative elements such as Supervisory Control
and Data Acquisition (SCADA), Advanced Distribution Management System (ADMS), and Advanced
Metering Infrastructure (AMI) and distributed energy resources such as rooftop solar, and Battery
Energy Storage Systems (BESS) to improve reliability, efficiency, and sustainability of electricity supply.
Strengthening of institutional and regulatory activities will be undertaken at the national level.
4. The total value of the program is US$902 million, to be implemented in five years. The World
Bank intends to support part of this program through the PforR (also referred to as ‘Program’) financing
instrument, using predefined Disbursement-Linked Indicators (DLIs). These DLIs were finalized through
several consultation sessions involving a broad range of stakeholders (Table 1). This approach will also
use the Government’s own systems in financial management (FM), procurement, fiduciary, social, and
environmental areas. The Program will be executed by several self-accounting entities: (a) BREB, a state-
owned enterprise (SOE) governed by Rural Electrification Board Act 2013, which stipulates the provision
for transparency, financial disclosure, audit and accountability mechanism; and (b) Power Cell, created
by the Government under the Power Division of the Ministry of Power, Energy and Mineral Resources
(MPEMR).
Table 1. Disbursement-Linked Indicators

Results Area Financial Recipient
Summary of Disbursement-Linked Indicators Allocation (USD
Million)
RA1: Increased DLI 1. Electricity delivery to BREB customers 112 BREB
delivery, climate increased
resilience and DLI 2. Climate Resilient Electricity distribution 271 BREB
digitalization of network infrastructure developed
electricity supply. DLI 3. Advanced Metering Infrastructure 23 BREB
implemented
v
DLI 4. SCADA pilot completed 15 BREB

RA2: Increased DLI 5. Integration of renewable energy in BREB 30 BREB
readiness to distribution net increased
integrate DLI 6. BESS connected to BREB distribution 30 BREB
Distributed Energy network1
Resources
DLI 7. Sector institutional and regulatory capacity

and gender consideration increased
RA3: Strengthened DLI7.1 Annual institutional strengthening and 22 BREB
institutional and gender activities of BREB completed
regulatory capacity DLI7.2 Annual institutional strengthening and 13 Power Cell
technical assistance activities of Power Cell
completed
Total 515
5. BREB, under the oversight and coordination of MPEMR, is the lead implementing agency for
the Program. GoB’s rule, as prescribed in the Rural Electrification Board Act 2013 that shapes BREB’s
systems, will be used for Program implementation, oversight, FM, procurement, safeguards, monitoring
and evaluation, and reporting arrangements. The Program will be implemented over a period of five
years between 2021 and 2026. Activities under Results Area 1 and Results Area 2 will be implemented
by BREB while activities under Results Area 3 will be implemented by BREB and Power Cell. A Program
Steering Committee will be established by the GoB, consisting of relevant Government ministries to
ensure coordinated implementation of the Program.
6. BREB was established in 1977 and operates under a license issued by Bangladesh Energy
Regulatory Commission (BERC). BREB has established 80 PBSs, rural electricity cooperatives, for the
operation and management of the rural distribution network. BREB directs and assists PBSs in all
technical, financial, and management aspects through a system of annual performance target
agreements with each PBS. BREB has issued comprehensive policy instructions to PBSs covering these
areas. Rural electrification system development projects are undertaken by BREB, and the completed
systems are thereafter handed over to PBSs for operations.
7. BREB will be responsible for planning, financing, and installation of Program investments in
Results Area 1 and Results Area 2. Once the distribution system is constructed, responsibility for the
system will be transferred to rural electricity cooperatives (PBSs), which provide retail service, as well as
operate and maintain the system, and are overseen by BREB.
8. BREB will be the lead agency for the Program and the responsibility for providing reasonable
assurance for economic, efficient, effective, transparent, and accountable utilization of funds. The
assessment covers three interrelated fiduciary areas critical to assessing fiduciary risks to the program’s
development objectives, risk mitigation, and capacity development strategies: (a) FM, (b) procurement,
and (c) governance and anti-corruption.
1
US$15 million of the disbursements under DLI 6.2 will be Climate Investment Fund grants. See annex 2 for breakdown of DLI6.
vi
SECTION 1: CONCLUSIONS
1.1 Reasonable assurance
1. The FSA was undertaken to ascertain if the Program’s financial management (FM) and
procurement arrangements are adequate and if they provide reasonable assurance that the Program
funds will be used for the intended purposes with due attention to the principles of economy, efficiency,
effectiveness, transparency, and accountability
1.2 Risk assessment
2. The residual fiduciary risk for the Program is rated Substantial after mitigation. The following
key risks have been identified in the Program fiduciary systems. Program implementing agencies have
agreed to implement mitigation measures to address these risks, to be monitored during
implementation through Program Action Plans (PAPs).
Table 2. Summary of Risks and Mitigation Measures

Risk Area Mitigation Measures Risk Rating
Risk of weak/slow implementation of audit BREB to strengthen the role of the Board Audit Substantial
recommendations and observations. Committee and Management Audit
Bangladesh Rural Electrification Board (BREB) Committees and reenforce accountability to
currently lacks adequate expertise and staff resolve audit observations.
to address audit observations on time and On Internal Audit , BREB to develop and
this has resulted in slow progress in resolving implement an internal audit modernization
audit observation. plan that includes (a) issuance of a Model
Internal Audit Charter and risk based internal
audit manual following International Standards
for the Professional Practice in Internal Audit;
(b) training and capacity building of financial
management and audit staff iii)establishment
of a system for annual procurement planning
and, procurement post review and associated
training; (c) transformation of internal audit
unit with appropriate structure particularly ,
ensuring organizational independence
reporting to the audit committee; use of
professional audit methods, including risk
assessment techniques to provide assurance to
management on the performance of the
internal control systems
Risk of inefficient and ineffective BREB to add qualified and experienced Substantial
procurement. BREB currently lacks procurement staff and consultants to ensure
experienced and qualified staff to meet the efficient and effective procurement.
needs of its growing investment program.
Risk of inefficient allocation and management BREB to (a) fully implement Integrated Budget Substantial
of Program budget due to insufficient and Accounting System (iBAS), which adopts
coordination between BREB Program the system of budget classification up to field
Implementing Units and the fund flow from or pay point level, enables iBAS++ to
the treasury to the implementing unit incorporate Program budget and funding
allocations, and enables the automation of
budgeting accounting processes; (b) ensure
that on-lending/granting arrangements are in
1
Risk Area Mitigation Measures Risk Rating

place for counterpart’s downstream fund flow
and release to Program spending centers and
reporting arrangement of Program expenditure
in iBAS; (c) establish a system of procurement
planning together with budget planning; and
(d) train both technical and procurement
specialist in procurement planning.
Risks of inadequate oversight of Program BREB to prepare guidance notes to facilitate Substantial
processes and quality due to BREB’s weak the use of iBAS++ for IDA financing; develop
capacity in internal audit as well as material Information and Communication Technology -
management, inventory accounting, fixed based internal control systems at BREB linking
asset management, and financial reporting procurement, payments, and asset register in
the Financial Management Information System
(FMIS) of BREB; and update FM operations
manual.
1.3 Procurement exclusions
3. The Program is not expected to procure any large contracts valued at or above the OPRC
thresholds for a "Substantial" risk rating i.e. US$75 million for works, US$50 million for goods and non-
consulting services, and US$20 million for consultant services. The implementing agencies will report to
the World Bank if any large contracts appear during Program implementation. The World Bank will also
monitor fiduciary systems and contract management reports to identify any large value contracts
throughout the Program implementation.
SECTION 2: SCOPE OF FSA
4. The FSA2 covers BREB which is the main implementing agency as well as Power Cell. This
assessment reviews the adequacy of the systems, processes, and procedures underlying Program
activities in implementing agencies. The FSA is based on Program Expenditure Framework identified in
the Technical Assessment of US$902 million and World Bank financing will be US$515 million over the
period 2021–2026.
SECTION 3: REVIEW OF COUNTRY PUBLIC FINANCIAL MANAGEMENT CYCLE
3.1 Planning and budgeting
Adequacy of budgets
5. The Budget and Accounts Classification System (BACS) of the Government of Bangladesh
(GoB), as explained in annex 1, is robust and will enable reporting of Program expenditures. Budget
allocations to BREB fall under the oversight of the Power Division in the Ministry of Power, Energy and
Mineral Resources (MPEMR) and state-owned enterprise (SOE) Monitoring Cell under the Finance
Division. The overall budget for the Power Division can be clearly identified under Grant 53, code-156 of
the Medium-Term Budget Framework (MTBF) 2020–2021 to 2024–2025. Together with the new
integrated budget preparation and execution modules and functionalities, the planning and budget
preparation process promotes better links between policy formulation, planning, and budget allocation
to enhance service delivery in a transparent and accountable manner.
2
The approach and methodology for the FSA is based on the Program-for-Results Fiduciary Systems Assessment Guidance Note
issued and effective June 30, 2017, to assist task teams in conducting the FSA for PforR operations.
2
6. The Program budget will be reflected in the Government’s budget. The practice is that donor-
funded projects are included in the budget when the relevant Program Document is approved by the
Prime Minister and subsequently reflected through the supplementary budget which is normally done in
April. The Detailed Project Pro forma of BREB in under preparation while the Technical Assistance
Project Proposal of Power Cell has been approved by the Government. The counterpart financing from
BREB and the Government will also be included in the 9-digit Task/Scheme/Program, unique code for
the EDMP that will be used by all implementing entities. The inclusion of all Program activities
undertaken by BREB, and Power Cell in the unique program code will enable effective monitoring of
utilization of Program budget by each Program Implementing Agency. BREB’s budget is governed by
section -19 of BREB act 2013, which requires BREB to submit its budget to the Government for approval.
7. The Finance Unit of implementing agencies will consider implementing subordinate

office/organizational unit dimensions of BACS under the Program. Deepening the organizational
segment from the Power Division to the responsible implementing agencies (BREB and Power Cell) will
enhance managerial accountability of funds allocated to deliver on the specific allocation at the lowest
organizational unit level as shown in table 3, to minimize the risk of delay in distribution of Program
funds to the frontline units responsible for the DLIs.
Table 3. Finance Division Organizational Codes

Subordinate
Ministry/ Directorate/ Office/
Public Sector Organizational Unit
Division Department Organizational
Unit Group
L-1 L-2 L-3 L-4 L-5
Digit-1 Digit-2 Digit-2 Digit-2 Digit-6
1 1-09 1-09-XX 1-09-XX 1-09-01-01-XX
Budgetary Central Secretariat, Secretariat, Secretariat, Secretariat, Power
Government Power Division Power Division Power Division Division/BREB/Power Cell
8. The operating segment of BACS supports tracking of Program activities. This will facilitate
budget management and reporting arrangements and ensure external scrutiny of the PAP. The Program-
for-Results (PforR) will be included in the budget using the code ‘Electricity Distribution Modernization
Program: Continuation of Priority Ongoing Activities Programme’, as shown in table 4.
Table 4. Power Division Operational Code

Task/Scheme/ Task/Scheme/
Type Subtype
Project Group Project
Level 1 Level 2 Level 3 Level 4
1 Digit 1 Digit 5 Digit 2 Digit
2 2-XX 2-XXX 2-XXX
Electricity Distribution Modernization Electricity Distribution
Development Annual Development
Program: Ongoing Activities Modernization Program: Ongoing
Activities Program
Programme Activities Programme
9. The Power Division and BREB have a strong budget execution and implementation track
record. There has been only a minor deviation in the approved and expected expenditures in recent
years (table 5), indicating that the risk of Program funds not being utilized for intended purposes is low.
Nevertheless, if there is an underutilization of total Program budget that results in the total Program
expenditure, which is planned to be US$902 million, being less than IDA and CTF allocation of US$515
million, the counterpart will have to refund that shortfall amount after the end of the Program period.
BREB has a good track-record of utilizing funds as indicated in Table 6.
3
Table 5. Annual Development Program Utilization of Ongoing Development Programme under the Power
Division
Financial Year (FY) Approved Actual Variance Variance (%)
FY2019/20 2,920 2,730 190 6.5
FY2018/19 2,921 2,720 201 6.90
FY2017/18 2,935 3,036 (101) −3.44
Note: Variance: Approved budget less actual.
Table 6. Development Budget Utilization of Ongoing Development Programme by BREB
Budget vs Actual Development Budget - BREB (US$, millions)
Financial Year 2017–2018 2018–2019 2019–2020 2020–2021
Budget (amount allocated) 991.78 1,116.94 813.68 499.63
Utilization/actual expenditure 1,032.55 1,131.32 798.55 487.48
Total number of projects 16.00 17.00 14.00 11.00
Number of projects - GoB finance 16.00 17.00 14.00 11.00
Amount allocated - GoB and BREB finance projects 717.37 859.42 664.99 424.96
Utilization/actual expenditure - GoB finance project
717.04 858.96 649.15 415.67
and BREB
Number of projects - donor finance 5.00 6.00 8.00 7.00
Amount allocated - donor finance projects 274.40 257.52 148.69 74.67
Utilization/actual expenditure - donor finance project 315.51 272.36 148.69 71.81
10. The current budget of the PforR for 2021–2026 is US$902 million: GoB/BREB - US$250 million;
World Bank - US$500 million; Clean Technology Fund - US$15 million. Given the past utilization track
record of the Power Division, BREB and strengthening of fiduciary capacity proposed under the Program,
the risk associated with budget adequacy is moderate.
Program’s Expenditure Framework
1. The Program will be implemented over five years, at an estimated total cost of US$902
million, out of which IDA will finance US$515 million including CTF: US$15 million (that is, 57.1
percent). The Program is expected to mobilize at least US$124 million of private capital for distributed
energy resources, which is included in the financial envelope of the Program; however private capital
mobilized for distributed solar is not an eligible expenditure under the Program. The capital cost
(goods/works) of the Program is US$742 million, representing 81 percent of the total Program cost,
followed by consulting service of US$34 million, representing 3 percent of the total cost, and the
remaining 2 percent is operating costs and other costs. Implementing agency-wise allocation shows that
BREB will implement 98 percent of total allocation followed by Power Cell with 2 percent. The IDA funds
will be disbursed to the Government Single Treasury Account (Consolidated Fund) upon submission of
withdrawal applications for DLI advances and results on verification of achievement of disbursement-
linked results. The Government will reach on-lend/on-grant agreements with implementing agencies—
BREB and Power Cell—to ensure fund flow to Program spending centers and reporting arrangement of
Program expenditure.
Table 7. Program Cost Estimates
BREB
Cost Head BREB-SM Power Cell Total Percentage
Modernization
Economic Code
Operating Cost 5.6 3.8 9.3 1
32571 Consultancy 20.0 11.4 31.4 3
4
BREB
Cost Head BREB-SM Power Cell Total Percentage
Modernization
Capital Expenditure —
41121 Transport 0.4 0.4 0
Equipment
41122 Computer and 0.0 0.0 0.8 0.8 0
Accessories
41123 Electrical 712.2 20.0 732.2 81
Equipment
Private Capital 124 0 0 124 14
Mobilization for
distributed solar
Others 3.9 3.9 0
Total 866.0 20.0 16.0 902.0 100
Procurement planning
11. BREB has been systematically preparing annual procurement plans and updating them on a
regular basis. Majority of the procurement under the Program is done by BREB. Power Cell will also
procure small-value procurement which includes routine goods items and consulting services. The
Annual Procurement Plan is published on the notice board of the agencies and where applicable on their
websites and through e-Government Procurement Portal (e-GP) systems.
Procurement profile of the Program
12. The following goods and services will be procured under the Program.
Table 8. Procurement Profile

Range of Larger Expected
Total Value
Type of Expected Number of
Category of Items (US$,
Procurement Contract Size Large
millions)
(US$, millions) Contracts
Transformer 11.4 1.5–5.6 4
Conductor 135.0 1.5–40 6
Line hardware 9.3 1.8–5.9 3
Goods
Insulator 5.8 2.3–3.5 2
Guy and grounding wire 5.1 1.5–1.8 3
Pole 114.0 5-30 2
Substation 148.0 25-45 3
New line and upgradation 3.8 3.8 1
LT to HT conversion, insulated conductor line 29 29 1
System Control and Data Acquisition (SCADA)
2.5 2.5 1
establishment
Work
Energy storage system establishment 7.5 7.5 1
Fault locator installation 2.1 2.1 1
River crossing 6.1 6.1 1
Supervision and management consultant 7.0 7.0 1
PSI agent 0.4 0.4 1
Consultancy Electrical works design, implementation, and 9.4 9.4 1
Firm supervision consultant along with geographic
5
Range of Larger Expected

Total Value
Type of Expected Number of
Category of Items (US$,
Procurement Contract Size Large
millions)
(US$, millions) Contracts
information system data collection
Individual International procurement consultant 0.2 0.2 1
Consultants International technical consultant 0.5 0.5 1
Note: LT = Low transmission, HT = high transmission.
3.2 Budget execution
Treasury management and funds flow - The funds flow arrangements for Program implementation
13. Technical information on each DLI with time-wise activities and verification protocol of results
will be used to prepare funds allocation against each results area. Fund flow outlined in the Treasury
Rules and Supplementary Rules will apply. Generally, development fund release is sought by the
implementing agencies based on an Annual Operational Plan approved by the line ministry and funds
are released in four equal instalments. BREB and Power Cell would submit the withdrawal applications
separately for their respective parts of the Program upon achievement of DLI or prior result and
advance. An amount of up to US$30.8 million will be allocated for prior results from the IDA credit
against DLI-1. Disbursements for prior results will be made against the verification of the results
following the effectiveness of the credit. The starting date of incurring EEP for prior result is the approval
date CN review note. BREB will use a unique ledger code in the FMIS to identify the program
expenditure.
14. With the Power Division providing oversight to the Program implementing agencies and the
Secretary of the Power Division as the Principal Accounting Officer, the risk of unavailability of funds
for Program implementation is not envisaged. After releasing funds from the Treasury Single Account
to BREB, the financial delegation as per the financial rules of BREB will be followed for the expenses
incurred in BREB. Both Power Cell and BREB will submit payment requests to the Chief Accounts Officer
of the Power Division for processing payments through the Treasury Single Account directly to the
vendors for goods and services for the Program implementation.
Accounting and financial reporting
15. The financial reporting obligations are specified in the Public Money and Budget Management
Act 2009. All Principal Accounting Officers are required to maintain accounts of their agencies and
reconcile regularly with the accounts maintained by the concerned accounts office. The accounts offices
prepare monthly and quarterly statements with financial information and data and forward them to the
Power Division. The Power Division may publish analytical reports based on these statements. While
responsibility for Annual Appropriation Accounts for the Program rests with the Power Division PAO, the
responsibility for preparation of Annual Financial Accounts for the Program rests with the Office of
Comptroller and Auditor General.
16. The Chief Accounts Officer, Power Division currently uses the iBAS for payment processing,
accounting, and reporting. Budget reports show financial and nonfinancial information as required by
Public Money and Budget Management Act 2009. Budget execution reports at the aggregate
departmental level show comparison between approved budget, release, actual, and remaining balance.
Information on outstanding commitment and obligations are not yet reported. To improve budget
monitoring and management under the Program, budget execution reports should show spending
6
against approved and released budget disaggregated by department, scheme, sector/subsector, fund,
and other BACS elements supplemented with output data for release to decision-makers and service
delivery managers and published in user-friendly format. Program expenditure financed by IDA and GOB
will be channeled through TSA using iBAS for initial recording of expenditure under the unique program
code with separate organizational code for BREB and Power Cell. There will also be fund code for each
source of financing. In parallel, BREB will also record the program expenditure in its FMIS along with the
program activities funded by its own source. The program financial statements will be comprised of iBAS
generated expenditure report and the BREB’s expenditure statement financed by BREB’s own fund.
17. The iBAS++, together with the BACS, will be used to prepare the Annual Program Financial
Statements. Program expenditure financed by IDA and GoB will be channeled through TSA using iBAS
for initial recording of expenditure under the unique program code with separate organizational code
for BREB and Power Cell. There will also be fund code for each source of financing. In parallel, BREB will
also record the program expenditure in its FMIS along with the program activities funded by its own
source. The program financial statements will be comprised of iBAS generated expenditure report and
the BREB’s expenditure statement financed by BREB’s own fund. In addition, as a part of corporate
reporting requirement, BREB will include the Program expenditure of their respective part in the annual
financial statement of entity financial statement.
Procurement processes and procedures
18. The Public Procurement Act 2006 and the Public Procurement Rules 2008 provide the
framework for Program procurement. They provide procedures to be followed for ensuring
transparency and accountability in the procurement of goods, works, and services using public funds
and for ensuring equal treatment and a free and fair competition among all persons wishing to
participate in public procurements. Open competitive bidding is the default method under the Public
Procurement Act 2006 and Public Procurement Rules 2008.
19. The procurement systems and processes that are in place for the Program are adequate. BREB,
and Power Cell will form the tender or proposal evaluation committees, comprising officials from their
own agency and other Government agencies. Quality of tender and proposal evaluation is also found to
be generally acceptable. Public Procurement Rules 2008 provides comprehensive instructions about the
tender evaluation process and the formation and composition of the evaluation committee. The Tender
and Proposal Evaluation Committees should consult the World Bank’s Debarment List prior to finalizing
the contract award decision in order to avoid having a debarred firm or entity being awarded a contract
under the WB-financed Program.
Procurement Performance
20. The procurement performance of BREF has been found to be acceptable. The procurement
performance of BREB was reviewed in nine projects over the last two financing years FY2020 and
FY2021 (Contracts awarded between 01 July 2019 to 30 June 2021). For the large value and complex
contracts, the time taken to complete the procurement process was higher than expected. The
indicators of procurement performance are given below. Almost all of the goods and works contract
which are procured through open competition were process through eGP system.
7
Table 9. Procurement Performance
Time Taken Between

Number of Bids/EoIs Advertisement and
No of Contracts Contract Value (US$)
received Notification of Contract
Type of
Name of the Project Awards (Days)
Procurement
Tota National International
Average Min Max Total Average Min Max Average Min Max
l QCBS OTM Direct (OTM/QCBS)
1.5 Million Consumer $ $ $ $
Goods 37 0 36 1 0 3.86 1 7 160 21 334
Connection Through Rural 181,763,438 4,912,525 98,654 22,077,594
Electrification Expansion (1st $ $ $ $
Works 9 0 9 0 0 2.56 2 5 300 214 324
Revision With Provision of 18,362,945 2,040,327 787,032 3,048,680
1.95 Million Consumer
Connection) Consulting $ $ $ $
40 40 0 0 0 3.89 3 4 204 204 204
Bangladesh Rural Services 3,864,490 96,612 8,245 581,728
Electrification Board, Dhaka.
$ $ $ $
TAPP Goods 1 0 1 0 0 6 6 6 82 82 82
1,073,241 1,073,241 1,073,241 1,073,241
Up-gradation of Rural
Electricity Distribution
System (Dhaka, Chittagong $ $ $ $
Goods 12 0 0 0 12 4.75 1 10 258 107 552
and Sylhet Division) (2nd 39,231,091 3,269,258 23,855 13,268,430
revised) (UREDS; DCSD)
Project
Up-gradation, Rehabilitation
and Intensification of $ $ $ $
Goods 1 0 0 0 1 1 1 1 105 105 105
distribution system (Dhaka, 85,295 85,295 85,295 85,295
Mymensingh, Chittagong and
Sylhet Divisions) (2nd
Revised) $ $ $ $
Works 1 0 1 0 0 2 2 2 225 225 225
2,305,046 2,305,046 2,305,046 2,305,046
Up-gradation, Rehabilitation
$ $ $ $
and Intensification of Goods 1 0 0 0 1 1 1 1 89 89 89
85,800 85,800 85,800 85,800
distribution system (Rajshahi,
Rangpur, Khulna & Barishal
Divisions) (2nd Revised)
$ $ $ $
Works 2 0 2 0 0 4.5 4 5 218 219 219
11,914,901 5,957,450 5,800,760 6,114,141
Distribution Network
Expansion for 100% Rural $ $ $ $
Goods 28 0 28 0 0 3.57 1 5 253 53 649
Electrification (Rajshahi, 155,011,554 5,536,127 301,222 17,483,616
Rangpur, Khulna & Barisal
1
Time Taken Between

Number of Bids/EoIs Advertisement and
No of Contracts Contract Value (US$)
received Notification of Contract
Type of
Name of the Project Awards (Days)
Procurement
Tota National International
Average Min Max Total Average Min Max Average Min Max
l QCBS OTM Direct (OTM/QCBS)
Divisions)
$ $ $ $
DNE(DMCS) Goods 63 0 58 5 0 3.7 1 7 232 79 475
203,857,788 3,185,278 104,765 19,091,188
$ $ $ $
Goods 7 0 7 0 0 3.56 1 7 143 32 442
7,886,871 563,348 48,012 3,106,800
$ $ $ $
Works 4 0 4 0 0 5.5 3 9 54.25 35 58
SDP & ID 3,020,318 604,064 385,612 1,011,753
Consulting $ $ $ $
2 1 0 0 1 5 5 5 319 319 319
Services 137,647 68,824 68,824 68,824
$ $ $ $
Works 7 0 0 0 7 6.14 3 8 565 395 643
25,629,855 427,642 3,857,989 4,464,355
SPPAI
Consulting $ $ $ $
2 0 0 0 2 11 5 17 217 217 217
Services 939,215 469,607 191,729 747,487
2
Access to complaint handling mechanism
21. The complaint handling mechanism for procurement meets Program requirements. The
national procurement law and regulations have already established the process to handle complaints
related to procurement. According to the national procurement law, complaint handling takes place on
two levels: an administrative process and an independent process. The administrative process involves
the handling of complaints at various authority levels of the procuring entity. Complainants not satisfied
with the outcome of the administrative process may choose to settle the matter through the
independent process conducted by one of the three review panels located in the Central Procurement
Technical Unit of the Government. The decision of a review panel is binding upon the related parties.
However, although a comprehensive complaint handling mechanism is there in the national
procurement law and regulations, it is not systematically operationalized in practice in most procuring
agencies in Bangladesh.
22. It was agreed that BREB, and Power Cell would implement procurement complaint handling
procedures required by national procurement law and regulations. This will include, but not limited to,
designating the official(s) responsible for reviewing and responding to the procurement complaints and
appeals, deciding the time frame for responses, maintaining an electronic database for record-keeping
of the complaints and responses in accordance with Public Procurement Rules 2008, and ensuring public
disclosure of the number of complaints received and responded.
Contract administration
23. Program contract administration and management arrangements are acceptable. The staff of
BREB and Power Cell assigned in the project management unit are responsible for the contract
management. The engineers at the field offices where the contract is implemented are also involved in
the contract implementation and management. Based on the information provided by the BREB about
the projects implemented in the last two financial year (FY20 and FY21), on average, around 100
contracts were implemented and managed in each financial year. Recently in the Bank-financed project,
Bangladesh: Rural Electricity Transmission and Distribution Project (P129920), which was closed on June
30, 2021, BREB did not handle and resolve the claims raised by a contractor (which is high value and
important contract of the project). Because of the BREB’s delayed response and misunderstanding of
the contract management, the disbursement deadline had to be extended at the very last moment
before the current disbursement period closing date. However, given a large number of contracts under
the Program, BREB may consider increasing the number of personnel engaged in contract management,
either deputing personnel from within the organization or by hiring consultants.
3.3 Internal controls
24. The Secretary of the Power Division, as the PAO, will ensure that the total expenditure is kept
within the limits of the authorized appropriation and that the funds allotted to the Program are spent
for the intended purpose. The PAO will be responsible for observance and compliance of all relevant
financial rules and regulations of the Program through the Program Director as the DDO. To maintain
proper control, the PAO will receive regular Program Budget Execution Reports. The Finance
Department issues the delegation of financial powers for all public sector organizations and projects. It is
therefore expected that this delegation is meticulously followed by the Finance Department and its line
agencies. The Secretary of the Power Division is the Head of Procuring Entity of the Finance Department.
1
Internal audit
25. BREB will strengthen its capacity to undertake risk-based internal audit. BREB currently has a
traditional transaction-based internal audit wing in its FM Unit. BREB will prepare and implement an
internal audit modernization plan under the Program including by strengthening audit committees to
enhance effectiveness of internal audit and institute risk-based internal audit.
Program governance and anticorruption arrangements
26. Arrangements to deal with issues of fraud and corruption will follow the requirements of the
Anti-Corruption Guidelines (ACG) on Preventing and Combating Fraud and Corruption in PforR
lending. The ACG requires, among other things, that the borrower shall ensure that any person or entity
debarred or suspended by the World Bank is not awarded a contract under or otherwise allowed to
participate in the Program during the period of such debarment or suspension. Based on the
information provided by BREB and Power Cell it is apparent that the agencies generally follow the
Government’s requirement of ineligibility of firms to be debarred by the country system, which is
published on the CPTU’s website. However, the agencies are not systematically checking the World
Bank’s debarment and temporary suspension lists before awarding contracts. It is therefore critical that
BREB and Power Cell put in place a mechanism/procedure to systematically check the list of the World
Bank debarred/suspended firms to ensure compliance with the World Bank’s ACG applicable to the
Program.
27. The manner of operationalization of the ACG under the Program has been agreed with the
Finance Department. Key commitments under the Program in this area and how these commitments
would be implemented are as follows:
(a) All appropriate measures will be taken to ensure that the Program is carried out in
accordance with the PforR ACG.
(b) Given the Program design, there is no distinction between World Bank-financed activities
and Government-financed activities within the Program; thus, BREB agrees that the ACG
shall be applied in an unrestricted manner for all activities within the Program boundary
and all appropriate measures to prevent fraud and corruption in connection with the
Program, including (but not limited to) adopting and implementing appropriate fiduciary
and administrative practices and institutional arrangements.
(c) BREB will identify a focal office and key officials responsible for ensuring that the Program
activities are implemented in accordance with the provisions of the World Bank’s ACG and
agreed protocols. The officers and the focal office are charged with reporting any
allegations to the Task Team Leader of the Association and to relevant authorities in
Bangladesh as soon as they become aware of them. Reports should be addressed to the
Task Team Leader with a copy to (CMU?). The key officials and staff in the focal office must
be available to answer questions or provide further information on request and make
appropriate arrangements for any subsequent INT investigation (see below). .
(d) BREB will take timely and appropriate action to investigate fraud and corruption allegations
and indications; report to the World Bank on the actions taken in any such investigation,
every six months; and promptly update to the World Bank its findings upon the completion
of any such investigation.
2
28. Under the ACGs, and in line with the above, for the purposes of Section 6 of the ACG, BREB’s
focal office and officials who are responsible will collect, consolidate, and provide the World Bank, on a
semiannual basis, a report on (i) any material and credible allegations and other indications of fraud and
corruption under the Program that come to the attention of the implementing agency during the
reporting period; (ii) any investigations launched into such allegations, and (iii) the progress of and
outcomes from such investigations and any remedial or corrective actions taken or planned in response
to such allegations or the findings of such investigations. This report will be appended to the
semiannual progress report provided to the Association by BREB. Even if there have been no allegations
or other indications of fraud and corruption or any follow up actions taken, a report should nevertheless
be filed so indicating. A template for semiannual reporting is attached as an Annex to the FSA and to the
Negotiations package.
29. In addition to the formal reporting mechanisms above, the Association maintains a “hotline”
that any PMU staff may call to report fraud and corruption directly to the Association. Persons who
report fraud and corruption via the hotline may remain anonymous if they wish.
(e) BREB will take timely and appropriate action, satisfactory to the World Bank, to remedy or
otherwise address the situation and prevent its recurrence if the borrower or the World
Bank determines that fraud and corruption has occurred in connection with the Program.
(f) For the purposes of Sections 6(f) and 7(b) of the ACG, BREB confirms that in the event that
the World Bank decides to conduct its own inquiry into allegations or other indications of
fraud and corruption in connection with the Program, BREB and other entities
implementing the Program will cooperate fully with the World Bank’s representatives and
take all appropriate measures to ensure the full cooperation of relevant persons and
entities, including in each case, allowing the World Bank to access sites and facilities; meet
with relevant persons and/or entities; and inspect all of their relevant accounts, records,
and other documents and have them audited by, or on behalf of, the World Bank.
(g) BREB will ensure that any person or entity debarred or suspended by the World Bank is not
awarded a contract under or otherwise allowed to participate in the Program during the
period of such debarment or suspension.
(h) BREB will report to the World Bank on actions taken in any investigation into fraud and
corruption allegation or other indications and will use a template for reporting, which has
been agreed between the Economic Relations Division, Ministry of Finance, and World
Bank. The report template is annexed to this FSA.
(i) However, if there are reported allegations, which might constitute a serious risk to the
implementation of the Program, the reputation of the borrower or the World Bank, or to
the proper use of the proceeds of the IDA financing, BREB will immediately inform the
World Bank.
(j) It is imperative that persons who engage in fraud and corruption be held accountable for
their actions. The World Bank requires that any counterpart staff who have been found to
have engaged in fraud and corruption must be removed from any responsibilities in
connection with the PforR Program as soon as possible. In addition, Bangladeshi
3
authorities will determine whether any laws may have been broken and the appropriate
steps to be taken under local laws.
(k) Any other actions to be taken in response to any particular case will vary from case to case.
When a case of fraud and corruption has been substantiated, either by the Association or
by Bangladeshi authorities, the Bank and counterpart agencies will consult as soon as
possible to discuss and agree on a course of action. This agreed course of action should be
set out in a written action plan, including specific roles and responsibilities and timeframes
for each action included in the action plan. The key officials and focal office will include in
the semiannual reports mentioned above a report on the progress in carrying out the
action plan.
3.4 Auditing
Program audit
30. The Program audit will be carried out by the Office of the Comptroller and Auditor General
(OC&AG) based on the financial statement of implementing agencies. Program expenditures will be
tracked in the BACS for GoB and IDA financed part and the FMIS of BREB for BREB’s own source.
Program audit is expected to be completed within nine months of the end of Fiscal Year. There are 10
audit directorates under the OC&AG. Each of the Audit Directorates is headed by a Director General who
is responsible for conducting external audits in a specific functional area of the public sector. Of the 10
directorates, Foreign Aided Project Audit Directorate has been mandated to carry out the audit of all
development projects and programs funded by development partners including those having both
foreign aid as well as GoB funding. Moreover, Reimbursable Project Aids through GoB arrangements,
where expenditure is initially made from Government treasury against GoB budget provisions and then
actual expenditure is reimbursed by development partners in Government treasury, are also audited by
Foreign Aided Project Audit Directorate because both development partners and GoB funding are
involved. Currently, OC&AG is undergoing reform, whereby it is moving to an entity audit model by
combining revenue and development expenditure in a single financial statement and will be audited by
a single audit directorate. The independent auditor will pay special attention to the risks of material
misstatement of the financial statements due to fraud, in line with International Standards on Auditing
240: ‘The auditor’s responsibilities relating to fraud in an audit of financial statements. Currently, the
entity audit of BREB is conducted by a private sector audit firm of chartered accountants. Audited
Financial Statements are submitted within the time limit set by the government to the BREB
management and stakeholders. The audit is carried out in line with Bangladesh Standard of Auditing. In
addition to this, all foreign aided projects are also audited every year by the Foreign Aided Project Audit
Directorate and reports are submitted within 31 December each year. There is no pending audit report
by BREB under any on-going or closed Bank Financed operation.
3.5 Procurement and financial management capacity
31. Program implementing agencies are advised to strengthen their procurement and FM
capacity. There is a procurement unit in BREB that mainly does the procurement of BREB’s regular
procurement. The procurement unit of BREB is not involved in project procurement. For every project,
4
under the project director, there is a dedicated procurement team consisting of BREB’s staff who do the
project procurement. There are projects where BREB also hires a procurement consultant to assist the
procurement in the projects. A project like this program of complexity and value handles on average
around 40 to 50 contracts per year. The head of the agencies will need to assign staff in each agency
who will focus on processing and reporting the Program expenses. The project director is overall
responsible and accountable for project management and implementation. The head of the agency (the
chairman in the case of BREB and director-general in the case of Powercell) is the head of the
procurement agency (HOPE). According to the financial designation of the authority of the government
the contracts are approved, which can be at the level of project director, head of the agency, ministry
and the cabinet committee of government purchase (CCGP). This is the first PforR to be implemented by
the implementing agencies. It will also be important to ensure that staff dedicated to the Program
receive formal training on procurement and FM, including PforR instrument and requirements.
32. Procurement risk and mitigation measures. Several procurement risks were identified during
the assessment for procurement capacity and performance of BREB and Power Cell. The risks included
(a) lack of an established Procurement Unit; (b) lack of overall supervision and coordination; (c) weak
enforcement of procurement legislation and lack of oversight; (d) weak system of registration and
handling of complaints; (e) lack of consistency of some provisions of the country laws with basic public
procurement principles—for example, tenders invited and rejected based on the percentage above or
below the estimated cost and use of lottery; (f) lack of proficiency in procurement management; and (g)
selection of contractors under undue political influences. The fiduciary actions in the PAP will mitigate
these risks. In the government public procurement rules, there is a lottery/above-below price rejection
process in a limited tender method. This is not applicable in case of International Competitive Bidding
and National Competitive Bidding under GOB Public Procurement Act and Public Procurement Rules. It
can be said that these issues are not likely to impact the Program procurement which will be mostly
International Competitive Bidding and National Competitive Bidding. Preparing an Annual Procurement
Plan by the agencies as indicated in the PAP will help plan and conduct the procurement activities
systematically under the Program.
SECTION 4: PROGRAM SYSTEMS AND CAPACITY IMPROVEMENTS
Table 10. PAP and DLIs

Type of
Risk Mitigation Measures Timing Action
(PAP, DLI)
1. Planning and Budgeting
Risk of inefficient allocation of budget Institute arrangements in 2022 PAP
due to lack of timely budget allocation to implementing agencies to ensure
implementing agencies and inadequate coordination between budget
coordination between budgeting and procurement planning.
processes and procurement planning
2. Budget Execution
Risk of delayed implementation of Mainstream IBAS for recording 2021 PAP
Program due to inefficient budget and reporting Program
execution and duplicative institutional expenditure for all implementing
reporting arrangements where separate agencies.
financial accounts are being maintained
by DDO and Chief Accounts Officers Ensure on-lending/granting 2022 PAP
arrangement with BREB for the
5
Type of
(PAP, DLI)
downstream fund flow and
release to ensure funding is
available on time at the spending
center.
3. Internal Controls
Risk of weak oversight of processes and Develop and implement an 2023 PAP
quality due to weak Internal Audit internal audit modernization plan
capacity and practice in BREB for BREB that includes (a)
issuance of a Model Internal
Audit Charter and risk-based
internal audit manual and (b)
establishment of a system for
annual procurement planning
and procurement post review
and associated training.
4. Auditing
Risk of non-compliance with the financial Strengthen the audit committee 2024 PAP
covenants and inability to identify and and establish processes and
take remedial measures due to delays in mechanisms for completing
resolution of audit observation annual audit, including
procurement audit and resolving
audit observations.
5. Procurement and FM Capacity
Risk of inefficient and ineffective Certify training on FM and 2022
procurement due to the absence of procurement for staff in BREB,
experienced and qualified procurement and Power Cell.
PAP
and FM staff to meet the needs of its
growing investment program Prepare an updated FM 2022
operation manual and risk
management manual.
6. Inadequate public confidence in BREB and Power Cell to establish Within three PAP
procurement processes carried out by and maintain a separate publicly months of
the implementing agencies resulting accessible website dedicated for project
in low participation of bidders the overall program where all effectiveness
disclosable procurement data,
including annual procurement
plans, procurement notices,
complaints/resolution, contract
award information, quarterly
procurement performance
progress reports under the
overall program will be available
and regularly updated.
7. Inefficiencies in procurement process BREB and Power Cell will use the Within three PAP
due to e-GP system not being used e-GP system for at least one-third months of the
for International Competitive Bidding of their contracts procured e-GP system’s
method through the ICB method under ICB module
the overall program. being made
available by
6
Type of
(PAP, DLI)
Central
Procurement
Technical Unit
for use by
procuring
agencies
SECTION 5: IMPLEMENTATION SUPPORT
33. The World Bank’s fiduciary team will work with the borrower to monitor implementation
progress and address underperforming areas identified in the PAP. Fiduciary support includes the
following:
 Reviewing implementation progress and working with the task teams to examine the
achievement of Program results and DLIs that are of a fiduciary nature
 Helping the borrower resolve implementation issues and carry out institutional capacity building
 Monitoring the performance of fiduciary systems and audit reports, including the
implementation of the PAP
 Monitoring changes in fiduciary risks to the Program and, as relevant, compliance with the
fiduciary provisions of legal covenants.
7
ANNEX 1: BUDGET AND ACCOUNT CLASSIFICATION SYSTEM (BACS)
1. The new 56-digit BACS was approved by the President in February 2017. The new BACS which
has rollup tables can now meet the current and future demands of the public financial management
system of Bangladesh as it can derive financial statements that meet IPSASB format and International
Monetary Fund Government Finance Statistic Manual 2014. Core segments are assigned to all
transactions by users at the time that they are posted into computer-based iBAS++. Conversely, users do
not need to enter coding for derived segments since reports are produced automatically from the
posted core segments. Core segments comprise four posted segments of 37 digits. These segments are
Organization (13 digits), Operation (9 digits), Fund (8 digits), and Economic (7 digits). There are another
three non-posted segments: Authorisation (1 digit), Function (Classification of Functions of Government,
4 digits), and Budget Sector (4 digits) that are derived within the iBAS++ based on posted data.
2. Two new tables for additional information—Mode of Payment (1 digit) and Location (9 digits)—
are also available to facilitate budget preparation, control, and reporting. Unlike the core posted
segments, these will not be posted for all transactions; only limited data will be inserted as and when
required. Furthermore, each segment can be configured to provide for varying levels of detail, as
deemed appropriate, to expand on existing monitoring/control requirements or to introduce new
informational segments and related reporting elements.
Table 1.1. Overall Structure of the New BACS

Segment Digits Purpose
Posted segments (users to enter data in iBAS++)
1. Organization Identifies the organizational unit (ministry/division, department, and operating
13
(5 sublevels) unit) responsible for a transaction
Identifies whether a transaction is for development or non-development purposes
2. Operation 9
and, if part of an activity/project, to which activity/project it relates
Identifies the fund in which a transaction is recorded (consolidated fund, public
3. Fund 8 account), and for those transactions within the consolidated fund identifies whether
the Government, a foreign grant, or a foreign loan funds the transaction
4. Economic (6 Identifies the economic nature of the transaction (tax or non-tax receipts, salaries,
7
sublevels) goods and services, grants, and so on)
Derived segments (pre-defined in iBAS++)
5. Authorization 1 Identifies whether an expenditure transaction is charged or other expenditure
Identifies the purpose of a transaction according to Classification of Functions of
7. Function 4
Government.
8. Budget Sector 4 Identifies the budgetary sector to which a transaction should be attributed
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Fiduciary System Assessment Bangladesh Electricity Distribution Modernization Program(P174650)

ELECTRICITY DISTRIBUTION MODERNIZATION PROGRAM (P174650)

People’s Republic of Bangladesh

FIDUCIARY SYSTEMS ASSESSMENT

November 29, 2021

ABBREVIATIONS AND ACRONYMS

ADMS Advanced Distribution Management System

Table 1. Disbursement-Linked Indicators

DLI 4. SCADA pilot completed 15 BREB

DLI 7. Sector institutional and regulatory capacity

1.1 Reasonable assurance

1.2 Risk assessment

Table 2. Summary of Risks and Mitigation Measures

Risk Area Mitigation Measures Risk Rating

1.3 Procurement exclusions

SECTION 2: SCOPE OF FSA

SECTION 3: REVIEW OF COUNTRY PUBLIC FINANCIAL MANAGEMENT CYCLE

3.1 Planning and budgeting

7. The Finance Unit of implementing agencies will consider implementing subordinate

Table 3. Finance Division Organizational Codes

Table 4. Power Division Operational Code

Program’s Expenditure Framework

Table 7. Program Cost Estimates

Procurement profile of the Program

Table 8. Procurement Profile

Range of Larger Expected

3.2 Budget execution

Accounting and financial reporting

Procurement processes and procedures

Table 9. Procurement Performance

Time Taken Between

Time Taken Between

Access to complaint handling mechanism

3.3 Internal controls

Program governance and anticorruption arrangements

3.5 Procurement and financial management capacity

SECTION 4: PROGRAM SYSTEMS AND CAPACITY IMPROVEMENTS

Table 10. PAP and DLIs

SECTION 5: IMPLEMENTATION SUPPORT

ANNEX 1: BUDGET AND ACCOUNT CLASSIFICATION SYSTEM (BACS)

Table 1.1. Overall Structure of the New BACS

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