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Internal Audit Report - Audit of the Inspector General's Office

Table of Contents

1.0 Executive Summary

The Canadian Food Inspection Agency (the CFIA, or Agency) is dedicated to safeguarding food, animal, and plant health, which enhances the health and well-being of Canada's people, environment, and economy. Over half of the Agency's human resources are dedicated to food safety-related activities including front-line inspectors.

The Vice President (VP) of the Operations Branch is responsible for the delivery of the CFIA inspection programs. In fulfilling this responsibility and to strengthen the Agency's food safety regime, an Inspector General executive was appointed in 2014 to report to senior management via the VP, Operations, on the overall performance and quality delivery from Operations Branch activities. The Inspector General's Office (IGO) consists of three components, two focused on inspection programs carried out in Canada, and one focused on inspections of foreign facilities:

The objective of the audit was to assess the adequacy of the management control framework related to the functions of the Inspector General's Office. While the audit focussed on the IGO's oversight of domestic inspection delivery and processes, the Foreign Verification Office was examined insofar as how its work is planned. The audit covered the period from April 1, 2016 to September 30, 2017.

The audit concluded that the mandate of the IGO needs to be confirmed and consistently communicated and described in Agency documents. Clarifying the mandate will assist the Inspector General in developing an overall strategic plan and appropriate performance measures. The audit also concluded that improvement is required in the IGO's reporting practices and the way management action plans are tracked.

The audit contains six (6) recommendations, as follows:

2.0 Introduction

2.1 Background

The Canadian Food Inspection Agency (the CFIA, or Agency) is one of Canada's largest science-based regulatory agencies. The CFIA safeguards food, animals and plants to enhance the health and well-being of Canada's people, environment and economy. Over half of its human resources are dedicated to food safety-related activities including front-line inspectors. Inspectors verify compliance with regulatory outcomes.

The Vice President (VP) of the Operations Branch is responsible for the delivery of the CFIA inspection programs. In fulfilling this responsibility and in response to the Independent Expert Advisory Panel Review of XL Foods Inc Beef Recall 2012, the Operations Branch created the Inspection Verification Office to verify that inspection staff applies a consistent level of rigour at federally regulated establishments across the country. To further strengthen the Agency's food safety regime, the Agency appointed an Inspector General executive in 2014 to report to senior management via the VP of Operations on the overall performance and quality delivery from Operations Branch activities. Today, the Inspector General's Office consists of three components, two focused on inspection programs carried out in Canada, and one focused on verifications of foreign facilities:

The IVO uses risk-based criteria to select locations where its inspection verification activities will be carried out. IVO initially oversaw the Food Business Line only, but in the fall of 2016 expanded its scope to include the Animal Health Business Line. IVO's scope is expected to be further expanded to include the Plant Health Business Line.

ESO conducts technical assessments and process improvement projects relating to inspection delivery. The technical assessments use an ISO-based common framework allowing it to demonstrate that the operational process, delivered within established parameters, performs effectively and consistently. The process improvement projects seek to improve efficiency and quality.

FVO was established in 2016 to verify foreign food safety authorities' control activities in establishments under their authority. FVO employees assess the risk of foreign food establishments, conduct food safety verifications of those foreign food establishments that appear to be the highest risk, and recommend appropriate risk mitigation measures.

2.2 Objective

The objective of the audit was to assess the adequacy of the management control framework in place related to the functions of the Inspector General's Office.

2.3 Scope

The audit focused on the management of the IGO and the practices and procedures established by them to fulfil its mandate relating to verifying the performance of the CFIA's inspection system. This included an examination of systems, structures, tools and processes, related to IVO and ESO, in place to support the IGO.

The FVO was examined insofar as how its work is planned and did not include a review of verifications conducted by the FVO.

The audit scope covered the period from April 1, 2016 to September 30, 2017. Samples of Inspection Verification reports and Technical Assessment reports were selected from the period April 1, 2016 to June 30, 2017.

2.4 Approach

The audit was conducted in accordance with the requirements of the Treasury Board Policy on Internal Audit and the Directive on Internal Audit, which provide mandatory procedures for internal auditing in the Government of Canada.

The audit was planned and performed to obtain reasonable assurance that the audit objective was achieved. A risk assessment was conducted during the planning phase of the audit to establish the audit criteria, which were accepted by management. The audit findings are based on a comparison of the conditions in place at the time of the audit with the audit criteria.

The audit team undertook the following procedures:

2.5 Statement of Conformance

The audit conforms to the requirements of the Institute of Internal Auditors' International Professional Practices Framework, as supported by the results of the CFIA's internal audit quality assurance and improvement program. Sufficient and appropriate auditing procedures were performed and evidence gathered in accordance with the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing to provide a reasonable level of assurance over the findings and conclusion in this report. The findings and conclusions expressed in this report are based on conditions as they existed at the time of the audit, and apply only to the entity examined.

3.0 Findings and Recommendations

3.1 Governance and Mandate

The mandate of the Inspector General's Office is not clearly and consistently defined to support a common understanding and to ensure that it is supported with an appropriate organizational model and governance body.

We expected that there would be a clearly defined mandate for the Inspector General's Office (IGO) and its components, and that the established governance structure would support it in achieving its mandate. We further expected the IGO to be supported by an organizational structure to enable it to carry out its work.

Initially the IGO mandate was to observe and report issues relating to the quality and consistency of inspection delivery. In December 2015, the Agency's Senior Management Committee approved the expansion of the scope of the IGO mandate to include conducting root-cause analysis, making recommendations for improvements, tracking progress on implementation of improvements, and looking at the processes supporting inspection.

We noted that the IGO initiated steps to move to an evolved role. A mandate letter from the Vice President of Operations to the Inspector General requested that a plan be developed and communicated to implement the expanded mandate, and the Operations Branch Excellence System (OBES) Manual was written. While there was intent to evolve, there was uncertainty as to the desired outcome. This is reflected in a lack of consistency in the description of the mandate in various Agency documents reviewed during the audit. The descriptions range from an internal quality function to an independent audit-like function. The scope ranges from verifying that inspections are conducted as per operational guidance to reviewing the entire inspection system from program design to delivery.

Also, the work of the FVO, which was created in 2016, has not yet been incorporated into the overall mandate of the IGO.

We interviewed or surveyed key stakeholders including IGO management and staff and recipients of the work of the IGO regarding their understanding of the IGO mandate. Results indicated a lack of common understanding of the IGO's role. Changes in the management of the IGO and in the Operations Branch may have also contributed to different perspectives and interpretations.

A clearly defined mandate is important as it sets out the purpose of an organization. Currently, the mandate and role of the IGO and components are not formally articulated in a consistent and sufficiently plain language to support a common understanding. A clear mandate and set of objectives serve as the authority from which the function would establish itself including such things as: establishing clear authority, responsibility and accountability; establishing a clear and effective organizational structure including reporting relationships and oversight bodies; and resourcing considerations.

The Inspector General reports to the VP Operations, who is the executive responsible for the Agency's inspection activities. This reporting relationship provides sufficient independence to support an internal quality function. The results of the work of the IGO are also discussed at the Operations Executive Committee. However, the OBES Manual states that the IGO is to also provide assurance to the Agency's Senior Management Committee (SMC) composed of the CFIA President, Executive Vice President, and all Branch Vice Presidents. We noted that there is no reporting to SMC. In the case of FVO, results are reported to both the Operations Executive Committee and the International Coordination Committee. This latter committee includes executives from the Policy and Programs Branch in addition to the Operations Branch.

The Inspector General has the ability to contribute a uniquely informed perspective on the performance and quality delivery of Agency inspection programs. Without regular engagement between the Inspector General's Office and senior management, beyond the Operations Branch, there is a risk that senior management will not have important information to contribute to effective decision making.

Recommendation 1:

The Vice President of Operations Branch should clarify and confirm the IGO mandate and governance structure and ensure that they are consistently described, documented and communicated.

3.2 Planning and Resourcing

The IGO does not have an overall plan that demonstrates how the IVO and ESO plans integrate to provide risk-based oversight of the inspectorate and in consideration of resources.

The FVO has established a risk-based plan using a variety of data sources to prioritize countries and establishments.

We reviewed the processes used by the IGO and its components – Inspection Verification Office, Excellence Systems Office and Foreign Verification Office – to establish strategic and operational planning activities. We wanted to determine whether there were risk-based plans in place to lead and direct the work of the individual components, and in the case of the IVO and ESO, whether there was an overall strategic plan to demonstrate how the IGO intends to meet its mandate relating to domestic inspectorate oversight. We also considered whether the IVO and ESO had appropriate and sufficient resources to achieve their respective work plans.

We found that each of the components of the IGO is largely managed separately. We did not find an overall strategic plan relating to inspection oversight and how the combined work of the IVO and ESO achieves expected outcomes. We also found that while the scope of work carried out by the IVO is well defined, there is an opportunity to better define the scope of ESO activities. An overall strategic plan would ensure that the combined oversight is structured to meet the needs of management.

We reviewed the operational plans of each of the components:

Inspection Verification Office

The IVO used establishment risk-based information to select sites for verification. The IVO process consisted of:

The resulting 2016/2017 work plan identified 120 inspection verifications, divided equally between the East and West, to be completed in the year. The 2017/2018 work plan reflected the gradual evolution of IVO verifications from being exclusively focused on federally regulated food establishments to now including other business lines of the CFIA.

The IVO had sufficient resources to complete the planned verifications. The IVO recruits experienced CFIA inspectors on a two-year assignment basis to become verification officers. We reviewed the call letter detailing required qualifications for IVO assignment opportunities and we also reviewed the successful applications. Based on a sample, verification officers possessed or exceeded the required minimum level of inspection experience required by the IVO. We also noted that for the 20 sample files reviewed, each Inspection Verification Team included at least one verification officer with experience in the commodity being verified. Feedback received from Regional Chief Inspectors (RCI) as part of the audit indicated that the RCIs perceive IVO staff to have adequate knowledge of business processes and effective communication skills.

Excellence Systems Office

We noted that the ESO used a range of tools to identify potential projects. Based on our review and interviews, however, the scope of ESO's activities was not always clear and planning parameters often broad. For 2016/17, the majority of planned projects were not completed. The most recent ESO planning process consisted of:

The resulting 2016/17 work plan identified 11 ESO projects. Six projects were process improvement projects designed to identify ways to improve inspection processes and five projects were technical assessments designed to assess compliance with established CFIA requirements. We noted that the OBES Manual sets out a mandate for technical assessments but there is no reference to process improvement projects being within the mandate of ESO.

Three of the eleven planned projects were completed. Of the remaining eight, two were near completion, one had been postponed, and five were cancelled. While we were informed that briefings to the VP Operations and/or Operations Branch Executive Committee took place, we were not able to find evidence of approval of changes to the plan, nor were we able to determine how projects were prioritized.

The ESO has a core team of one manager and six officers that are responsible for planning projects, analyzing data, writing reports, and coordinating the technical assessments. The ESO also relies on experienced staff (specialists) from the Agency to perform technical assessments on a project basis. It relies on the Operations Branch Areas to select the appropriate specialists to be temporarily assigned to individual projects/assessments. The selection process and criteria are outlined in an ESO directive that describes the process of selection of technical assessment team members. Feedback received from former technical assessors indicated that they felt that ESO management provided them with the knowledge and skills necessary to perform their assigned technical assessments.

Lack of clarity around mandate, scope and universe definition may have contributed to developing a plan that was not fully delivered. We also noted that the ESO plan was silent on the resources required to accomplish the listed projects.

Without clear processes in place to support the development, approval and monitoring of plans, plans may not be delivered and deviations may not reflect the desired outcome.

Foreign Verification Office

The FVO has established a risk-based process to prioritize countries, food safety risks and commodities, and select establishments in which to conduct its verifications. The FVO uses a risk-based prioritization tool that is populated with information from a range of sources including internally generated food safety data as well as data from other departments and jurisdictions. The FVO first prioritizes the countries that should be subject to a foreign verification and then prioritizes establishments within these countries.

Recommendation 2:

The Vice President of Operations should ensure that an overall strategic plan for the Inspector General's Office is developed, approved and demonstrates how the IGO intends to provide oversight on the inspectorate through the work of the IVO and ESO, including the resources required.

3.3 Conduct of the Work

IVO and ESO have established adequate policies and procedures to guide their staff in the conduct of their work; however, there is no mechanism in place to ensure that inspection verification officers remain current while assigned to the IVO.

We expected that there would be adequate policies, procedures and guidance to support IVO and ESO staff in planning, conducting and reporting on the results of their verifications / assessments. We also expected that there would be mechanisms in place to ensure that work is conducted in an objective manner.

Standardized policies and procedures are important because they are designed to bring a systematic, disciplined approach to planning the work. This ensures there is sufficient and appropriate documentation to support the conclusions of the verifications / assessments and the reports issued. Such policies and procedures contribute to consistency in the conduct of the work across all assessments / verifications.

We reviewed and assessed the guidance developed by the IVO and ESO to direct and lead teams in the conduct of their work. We noted that the IVO has established a set of policies and procedures including the Inspection Verification Manual, TeamMate User Manual, a document management policy, and an extensive set of templates and examples of completed documents. The IVO also provides a three-day, in person training session to new verification officers. The ESO has also developed directives, tools and training materials to guide the work of the ESO.

Both IVO staff and those working on ESO technical assessments indicated that they had the tools required to carry out their work.

We found that mechanisms are in place to ensure that work is conducted in an objective manner. The IVO requires that verification officers review a code of ethics that includes information about the principle of objectivity and requires verification officers to sign a declaration. Also, verification officers are not permitted to perform verifications in their home regions. Audit tests confirmed that both of these procedures are being followed. The ESO has a Code of Conduct that is included in the training for technical assessors. The Code specifically defines the principle of objectivity and outlines actions that must be followed.

As part of our audit, we reviewed completed IVO verifications and ESO assessments to determine whether verification / assessment teams had adhered to established practices and procedures. Based on a sample of 20 IVO inspection verifications and 2 ESO technical assessments files adhered to established procedures, and were found to be evidence-based.

While assigned staff receive IVO related training, we noted that IVO personnel on two year assignments have limited access to inspection-related training required to keep up-to-date. This will become increasingly important as the Agency modernizes the work of the inspectorate. The inspection verification officers will need to be trained and experienced on new processes prior to carrying out verifications.

Recommendation 3:

The Vice President of Operations Branch should ensure that IVO staff has the necessary access to inspection-related training required to remain current.

3.4 Reporting Results and Follow-up

There is an opportunity to strengthen reporting practices to ensure that results are effectively communicated to senior management, and that Management Review Action Plans for systemic or significant issues are developed, monitored and acted upon.

We reviewed the practices and procedures established by the IVO and ESO to report on the results of individual verifications / assessments as well as any summary periodic reporting. We expected that the results would be communicated to appropriate parties and that corrective action would be taken on systemic or significant issues.

The IVO prepares inspection verification reports by federally regulated establishment. All reports (approximately 120 annually) are reviewed by the IVO inspection manager and the Inspection Verification Report Review Committee, and are then sent directly to the Operations Branch Regional Chief Inspector (RCI). The RCI is responsible for developing a Management Review Action Plan (MRAP) in response to the identified issues. In developing MRAPs, RCIs are expected to consider the broader application of issues to the regions in support of continuous improvement. The audit confirmed that this was generally done.

The RCI sends the completed MRAP to the IVO. The IVO Inspection Manager acknowledges receipt indicating whether or not there are any objections to its implementation as proposed.

The IVO has developed an automated tool to track the MRAPs. The RCIs report on the status of the MRAPs which are signed off by the Operations Branch Area Chief Inspector (ACI) once complete. Once signed off, the IVO closes the recommendation. We noted that the IVO sends quarterly status reports to ACIs and reports on the completion rates in the annual report. IVO does not validate their completion.

The ESO prepares Technical Assessment Reports that are presented to the Operations Executive Committee and approved by the Inspector General and the Vice President of Operations. We noted that both assessment reports completed during the audit period contained an MRAP; however, during the audit period, there was no tracking or monitoring of MRAPs.

The IVO also produces a semi-annual report that identifies systemic issues found in Inspection Verification Reports; however, there is no MRAP requirement. The report is presented to the Operations Executive Committee and posted on the Agency's intranet site.

While ESO reports and the IVO semi-annual reports are available on the Agency intranet, the results are not presented or discussed beyond the Operations Branch. In the absence of discussion beyond the Operations Branch, there is a risk that Senior Management will not have important information to enable strategic discussion to: inform the planning process; identify trends, concerns or opportunities for improvement; provide an early warning mechanism to manage risks before they materialize etc. While some action may have taken place to address systemic issues, there is no formal process in place to ensure that systemic or important issues identified in IVO semi-annual reports and ESO reports are being acted upon.

In our review of a sample of completed IVO verification and ESO technical assessment reports and supporting working papers, and IVO semi-annual reports, we noted the following opportunities for improvement:

It is important that reports effectively describe the nature and extent of the observations to allow the reader to understand their importance, help explain the impact the observed weaknesses may have on the Agency's ability to achieve its stated objectives and provide a basis for taking corrective action.

Actively monitoring progress against actions in response to systemic or significant issues provides important information to management on the degree to which corrective actions have been taken and the underlying cause of the observation addressed. We were informed that the Operations Branch is currently reviewing how best to monitor the disposition of MRAPs in response to IVO Semi-Annual Reports and ESO Reports, and that this may be overseen outside of the Inspector General's Office. It will be important that the role of the Inspector General with respect to follow-up is clear and aligned with its clarified mandate.

Recommendation 4:

The Vice President of Operations should review the Inspector General's Office reporting practices to ensure that the results of its work are communicated in a manner that meets the needs of management and maximizes the value of its work.

Recommendation 5:

The Vice President of Operations should establish a process to monitor the implementation of Management Review Action Plans in respect of IVO and ESO systemic or significant results.

3.5 Performance Measures

The IVO has defined performance measures and reports on them regularly. However, performance measures for the ESO and the IGO overall are under development.

We expected the IGO to have practices and procedures in place to monitor the quality of its work and to support continuous improvement. We further expected that the IGO would have measures or mechanisms in place to demonstrate its performance relative to its established purpose and objectives.

Performance measurement is important to allow the organization to demonstrate accomplishment of stated objectives or requirements, assess and enhance stakeholder satisfaction with outcomes achieved, and identify the need or opportunities for improvement.

Our audit found that the IGO had established some measures to monitor the quality of its work. These include:

The audit found that performance measures to report on the IGO's accomplishments and achievement of its stated objectives have been established for the IVO but have yet to be established for the ESO and the IGO overall.

The IVO performance measures are reported in its Semi-Annual and Annual Reports and include:

While the IVO reports statistics on the status of MRAPs based on recorded information against individual verifications, as stated in section 3.4, there is an opportunity for the IVO to report on progress made in addressing systemic or important issues identified in its semi-annual reports.

Recommendation 6:

The Vice President of Operations should ensure that the Inspector General's Office completes the development of performance measures for the IGO overall and its components to demonstrate what it has accomplished in delivering its established mandate.

Appendix A: Audit Criteria

Line of Enquiry 1: Mandate and Governance
1.1 The IGO and its components (IVO and ESO) have clearly documented mandates that set out their purposes, authorities and responsibilities.
1.2 The Inspector General's Office is independent and its work carried out in an objective manner.
1.3 There is a clearly defined governance structure that supports the IGO's and its components' (IVO and ESO) mandates.
Line of Enquiry 2: Planning and Resourcing
2.1 The IGO and its components (IVO, ESO, FVO) have risk-based plans that lead and direct the activities in achieving their mandates.
2.2 The IGO and its components (IVO and ESO) have resources that are knowledgeable, sufficient and effectively deployed to achieve their work plans.
Line of Enquiry 3: Conduct of the Work (IVO/ESO)
3.1 There are policies and procedures to guide the conduct of the IVO and ESO activities.
3.2 The work of the IGO and its components (IVO, ESO) is carried out in accordance with established policies and procedures and should include appropriate review and approval of the work conducted.
Line of Enquiry 4: Reporting Results of Assessments/Verifications (IVO/ESO)
4.1 The results of IVO verifications/ESO assessments are communicated to the appropriate parties.
4.2 The communication of the results of IVO verifications/ESO assessments is evidence-based, concise, constructive, complete and timely.
Line of Enquiry 5: Management Response and Action Plans (IVO/ESO)
5.1 The IGO and its components (IVO, ESO) have established and maintain a system to monitor the disposition of results communicated to management.
5.2 Management develops timely Management Response and Action Plans (MRAP) to address observations raised.
5.3 MRAPs take into consideration the broader application of the observations to the inspection process.
5.4 Management has a mechanism to monitor progress in implementing the MRAP.
Line of Enquiry 6: Performance Measures
6.1 The IGO and its components develop and maintain mechanisms to monitor the quality of their work to support their continual improvement.
6.2 The IGO and its components develop, monitor and report performance measures to demonstrate their performance relative to their purpose, and objectives.
6.3 IVO verifications and ESO assessments are carried out in accordance with annual work plans.

Appendix B: Management Response and Action Plan

Please note that objective of this audit was to assess the adequacy of the management control framework related to the two core components of the IGO; namely, the IVO and ESO. As a result, the following recommendations do not apply to the FVO.

Recommendation 1:

The Vice President of Operations Branch should clarify and confirm the IGO mandate and governance structure and ensure that they are consistently described, documented and communicated.

Management Response and Action Plan Completion Date Responsible Lead

Operations Branch agrees with this recommendation. It will accordingly:

  • Revise and update:
    • mandate for the Inspector General's Office; and
    • reporting processes for IGO activities (governance)
September 2018 Inspector General, Operations Branch

Operations Branch agrees with this recommendation. It will accordingly:

  • Reflect revised mandate in an authoritative document approved by the Vice President of Operations and endorsed by appropriate level of Senior Management
  • Post the approved authoritative document on the Agency's Intranet
December 2018 Inspector General, Operations Branch

Recommendation 2:

The Vice President of Operations should ensure that an overall strategic plan for the Inspector General's Office is developed, approved and demonstrates how the IGO intends to provide oversight on the inspectorate through the work of the IVO and ESO, including the resources required.

Management Response and Action Plan Completion Date Responsible Lead

(Building off of the revised IGO mandate described against recommendation 1)

Operations Branch agrees with this recommendation. It will accordingly:

  • Draft and approve a revised overall strategic plan for the IGO and its components. The plan will describe how the work done by IGO's components provides oversight of the inspectorate. It will also identify the process used by the Branch to ensure that IGO plans and resources remain aligned.
January 2019 Inspector General, Operations Branch

Recommendation 3:

The Vice President of Operations Branch should ensure that IVO staff has the necessary access to inspection-related training required to remain current.

Management Response and Action Plan Completion Date Responsible Lead

Operations Branch agrees with this recommendation. It will accordingly:

  • Review the existing Branch process for assessing and prioritizing employee training needs.
  • Update the process as necessary and/or apply it more appropriately, to ensure that core IGO training needs are suitably met, and that IGO staff have the necessary knowledge to conduct verification work.
September 2018 Inspector General, Operations Branch

Recommendation 4:

The Vice President of Operations should review the Inspector General's Office reporting practices to ensure that the results of its work are communicated in a manner that meets the needs of management and maximizes the value of its work.

Management Response and Action Plan Completion Date Responsible Lead

(Building off of the revised IGO mandate described against recommendation 1)

Operations Branch agrees with this recommendation. It will accordingly:

  • Revise reporting practices for IGO products to ensure scoring methodology and the reporting of deviations are reasonably reflected; and
  • Develop an IGO overall periodic reporting schema to ensure that:
    • Systemic and significant issues are identified, reported and monitored
    • Overall performance (refer to rec #6) is reported
    • Reporting is done against overall strategic plan (Rec #2)
January 2019 Inspector General, Operations Branch

Recommendation 5:

The Vice President of Operations should establish a process to monitor the implementation of Management Review Action Plans in respect of IVO and ESO systemic or significant results.

Management Response and Action Plan Completion Date Responsible Lead

(Building off of the revised IGO mandate described against recommendation 1)

Operations Branch agrees with this recommendation. It will:

  • Revise existing procedures for the monitoring of Management Review Action Plans generated as a result of IGO activities.
  • Ensure that revised procedures include sections on roles and responsibilities as well as accountabilities with respect to the fulfillment of MRAP recommendations.
January 2019 Inspector General, Operations Branch

Recommendation 6:

The Vice President of Operations should ensure that the Inspector General's Office completes the development of performance measures for the IGO overall and its components to demonstrate what it has accomplished in delivering its established mandate.

Management Response and Action Plan Completion Date Responsible Lead

(Building off of the revised IGO mandate described against recommendation 1)

Operations Branch agrees with this recommendation. It will:

  • Develop performance measurement principles for IGO activities that are consistent with Branch Best Practices.
  • Report annually on the results of IGO performance (refer to recommendation 4)
January 2019 Inspector General, Operations Branch
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