For further information, please contact:
Head Office The Chief Executive Officer/Secretary
Pest Control Products Board Off Waiyaki Way, Loresho
P. O. Box 13794 - 00800 Nairobi, Kenya. Tel.: 254-020-8021846/7/8
Mobile: 0720480904/0735778743 Email: [email protected]/
[email protected] Website: www.pcpb.or.ke
PEST CONTROL PRODUCTS BOARD [A Statutory Organization of the Kenya Government]
CORRUPTION PREVENTION PLAN
VISION
To be a world class regulatory agency for pest control products.
Revised 2016
PCPB CORRUPTION PREVENTION PLAN Page 2
MISSION To provide professional, efficient and effective regulatory service for trade, safe use and disposal of pest control products while ensuring safety to humans, animals and the environment.
PCPB CORRUPTION PREVENTION PLAN Page 43
REGIONAL OFFICES Coast Regional Office The Regional Manager
KARLO Mtwapa, P.O. Box 10636 - 80101
Bamburi, Kenya. Tel: 254-020-2375522.
Email: [email protected]
Western Regional Office The Regional Manager
MURBS Building P.O. Box 2757 - 40100
Kisumu, Kenya. Tel: 254-020-8068933
Email: [email protected]
Mt. Kenya Regional Office The Regional Manager
Embu Motors Plaza P.O. Box 2754 - 60100
Embu, Kenya. Tel: 254-068-31026
Email: [email protected]
South Rift Regional Office The Regional Manager
Industrial Area, General Mathenge Road
Within Pyrethrum Board Com-pound
P.O. Box 4507 - 20100 Nakuru, Kenya.
Tel: 254-051-2217544
PCPB CORRUPTION PREVENTION PLAN Page 42
Notes
PCPB CORRUPTION PREVENTION PLAN Page 3
TABLE OF CONTENTS
Foreword ………………………………………….... 4
Background ……..………………………………..... 5
Mandate ...……………………………………….…. 6
What is corruption ..…...……………..……………… 7
Corruption Risk Assessment and Corruption
Prevention Plan ...………………………………….. 8
Early Warning Signal of Corruption .………………. 9
Implementation of Corruption Prevention Plan ….. 10
Annex 1: Corruption Risk Assessment and
Corruption Prevention Plan ………………………... 12
PCPB CORRUPTION PREVENTION PLAN Page 4
FOREWORD The PCPB is continually implementing policies and programs to im-prove the social, political, economic, legal and institutional patterns and environment to create prosperity for Kenyans. It has committed itself to the realization of the principles of leadership and integrity as outlined in Chapter six of the Constitution of Kenya 2010. The Kenya government has also put in place legal and institutional structures e.g. the Anti-Corruption and Economic Crimes Act 2003, The Ethics and Anti Corruption Commission Act, 2011, Public Officers Ethics Act 2003, Public Procurement and Asset Disposal Act 2015 and Regulations 2006, Government Financial Management Act 2015, Leadership and Integrity Act 2012, United Nations Convention Against Corruption (UNCAC), African Union Convention on Preventing and Combating Corruption (AUCPCC), to address corruption. The government has been implementing the fight against corruption through the Public Service integrity program. Through this program, PCPB has trained seven integrity assurance officers who have been involved in the Corruption Risk Assessment, the preparation of the Corruption Prevention Plan, the Anti-Corruption Policy and the Code of Conduct and Ethics. In order for PCPB to play its role effectively, it must cleanse itself of corruption, wastefulness, negligence and inefficiency, and put in place strategies to mitigate against corruption. A corruption prevention com-mittee has been set-up with clear mandates on how to handle corrup-tion related cases or reports.
Chief Executive Officer/Secretary Pest Control Products Board
PCPB CORRUPTION PREVENTION PLAN Page 41
ACTIVITY
RESPONSI-BLE PER-
SON
BUDGET
TIME FRAM
E
MEANS OF MEASURE-MENT AND DELIVERY
Engage services of a qualified staff
Train/sensitize staff on proper stores records management.
Develop/Procure a computer-based stock control system
Adherence to estab-lished authorization procedures for stores
Enhance stores securi-ty.
Chief Execu-tive Officer
SCM Officer
Users
Annual Budgetary provision
Continu-ous
Regular sample stock takes
Annual stock take exercise
Stores docu-ments in place
Clean and se-cure store
Adherence to disposal guidelines
Members of the com-mittee be people of high integrity
Compliance with the provisions of the PPAD, 2015 and PPDR, 2006
Chief Execu-tive Officer
SCM Officer
Users
- Continu-ous
Disposal sub-missions by users
Use of disposal plan
Disposal com-mittee and minutes of its meetings
Disposals as per procedures
Implement Annual Audit plan.
Conduct regular audits and advice manage-ment on areas of weak-nesses identified.
Adherence to code of conduct for auditors.
Chief Execu-tive Officer
Internal Audi-tor
- Continu-ous
PCPB CORRUPTION PREVENTION PLAN Page 40
CORRUPTION PRONE AREA
CORRUPTION
RISKS
CORRUPTION PRE-VENTION STRATE-
GY
12 Stores Management Poorly maintained stock records.
Unqualified staff under-taking storekeeping tasks.
Lack of clear policy on stores management.
Failure to hold stores records securely.
Poor security of store items.
Establish a comprehen-sive stores records
Computerize stores rec-ords
Comply with guidelines on stores management
Comply with procedure for issues of stores
Have adequate security of stores.
13 Disposal of stores/assets
Conflict of interest.
Untimely or late disposal of stores.
Low valuation of stores.
Lack of objectivity in the determination of disposal criteria.
Leakage of information to potential bidders.
Comply with established guidelines on disposal of stores
Establish a Board of survey and disposal committee
Use PPAD, 2015 and PPDR, 2006
Confidentiality of delib-erations be maintained
(h) Internal Audit
1 Internal Audit func-tion
Failure to verify relevant records
Failure to conduct regu-lar checks on compliance to set rules and regula-tions
Failure to review proce-dures and policies.
Failure to report audit findings
Compliance with provi-sions of Public audit Act, Financial Management Act & International Au-dit standards.
Observance of Annual Audit Plans
Report true audit find-ings
PCPB CORRUPTION PREVENTION PLAN Page 5
BACKGROUND
The Pest Control Products Board (PCPB) is a Statutory Organization
of the Kenya Government established under the Pest Control Prod-
ucts Act, Cap 346, Laws of Kenya of 1982 to regulate the importation
and exportation, manufacture, distribution, disposal and use of pest
control products.
Presently, the Board operates under the following Subsidiary Legisla-tions (Regulations): The Pest Control Products (Registration) Regulations –
L.N.46/1984 & L.N.109/1984
The Pest Control Products (Licensing of Premises) Regula-
tions – L.N.145/1984
The Pest Control Products (Labeling, Advertising and Packag-
ing) Regulations – L.N.89/1984
The Pest Control Products (Importation and Exportations)
Regulations – L.N.146/1984
The Pest Control Products (Registration) (Amendment) Regu-
lations – L.N. 123/2006
The Pest Control Products (Licensing of Premises)
(Amendment) Regulations, 2006 - L.No. 124/2006
The Pest Control Products (Importation and Exportation)
(Amendment) Regulations – L.N. 125/2006
The Pest Control Products (Disposal) Regulations – L.N.
126/2006
The Pest Control Products (Labeling, Advertising and Packag-
ing) (Amendment) Regulations – L.No. 127/2006
The Pest Control Products (Licence Fees and Other Charges)
PCPB CORRUPTION PREVENTION PLAN Page 6
Regulations – L.No. 128/2006.
The Pest Control Products (Licence Fees and Other Charges) Reg-
ulations – L.No. 128/2006.
The Pest Control Products (Certificate of Registration) Regulation
2014. L.No. 7189/2014
The Pest Control Products (Registration) (Amendment) Registration
2014. L.No. 122/2014
The Pest Control Products (Registration) (Amendment) Regulations
2015. L.No.124/2015
MANDATE
The mandate of the Pest Control Products Board as prescribed in the Pest
Control Products Act and also in line with its vision and mission statement
includes the following activities:-
Investigating and prosecuting contravention of the Pest Control
Products Act.
Supervising the disposal of obsolete or undesired pest control prod-
ucts.
Advising the Minister on all matters relating to the Provisions of the
PCP Act and Regulations made there under.
Assessing the safety, efficacy, quality, merit and economic value of
pest control products with a view to registering them, if found suita-
ble.
Assessing suitability of premises used for manufacture/formulation,
re-packing, storage and distribution of pest control products for pur-
poses of licensing them for those functions.
Processing and issuing import/export permits to ensure that only
registered products are imported and in right quantities.
PCPB CORRUPTION PREVENTION PLAN Page 39
ACTIVITY
RESPONSI-BLE PER-
SON
BUDG-
ET
TIME FRAM
E
MEANS OF MEASURE-MENT AND DELIVERY
Evaluate as per the criteria set.
Facilitate training of Evaluation committee members.
Evaluate within the timeframe prescribed in the PPAD Act, 2015 & PPDR, 2006.
Interested parties to declare their interest and disqualify them-selves.
Chief Execu-tive Officer
SCM Officer
Evaluation Committees
Annual budgetary provisions.
Continu-ous
Evaluation criteria within tender docu-ments
Evaluation reports using set criteria
Timely evalua-tion
Discipline staff who divert goods or receive lower quality products or services
Intensify stock verifica-tion.
Intensify audit inspec-tions.
Maintain register of assets.
Chief Execu-tive Officer
SCM Officer
Inspection and Ac-ceptance Committee
User depart-ment/section
Finance de-partment
Annual budgetary provisions
Continu-ous
Acceptance and Inspection com-mittees
Acceptance forms duly signed
Register of assets
Authorization of pay-ments as per regula-tions.
Adhere to standard operating procedures for payments.
Chief Execu-tive Officer
SCM Officer
Accountant
Annual budgetary provisions
Continu-ous
PCPB CORRUPTION PREVENTION PLAN Page 38
CORRUPTION PRONE AREA
CORRUPTION
RISKS
CORRUPTION PRE-VENTION STRATE-
GY
9 Evaluation of quo-tations / tenders
Lack of an evaluation criteria.
Unqualified evaluation committee members.
Change of evaluation criteria.
Substitution of evaluation committee members.
Acceptance of unsolicited communications.
Delay in evaluation process.
Establish criteria for evaluation.
Train members of the evaluation committee.
Use evaluation commit-tees as per procurement guidelines.
Adhere to established evaluation criteria.
Involve experts in evalu-ation where necessary.
Comply with stipulated evaluation period.
10 Delivery and ac-ceptance of goods or service/ Perfor-mance of works
Receipt of substandard goods/services.
Substitution for lower quality goods or services.
Price variations and contract amendments.
Diversion of delivered goods for private use or resale.
Inspection and Ac-ceptance be undertaken as per threshold schedule.
Price variations and con-tract amendments be approved by the CEO.
Ensure complete delivery as per specifications.
11 Payment Payment for non-delivered goods/services.
Delayed payments.
Compliance with Gov-ernment Financial regula-tions.
PCPB CORRUPTION PREVENTION PLAN Page 7
Monitoring and ensuring adherence of quality standards of
pest control products from production to use.
Creating awareness of the general public on all aspects of
safety, storage, handling, disposal and use of pest control
products.
WHAT IS CORRUPTION? There is no single universal definition of the term corruption be-cause it is diverse with many manifestations. However, the Anti-corruption and Economic Crimes Act defines corruption as: -
An offence under any of the provisions of section 39 – 44, 46 and 47,
Bribery,
Fraud, Misappropriation of public funds, Abuse of office, Breach of trust, Dishonesty, Conduct of behavior where a person entrusted with public
or private responsibility or authority violates their duties for personal advantage or for the advantage of others, acts of omission or commission,
Omission resulting in personal advantage at personal ex-pense, abuse of office for gain to self or group to which one owes allegiance,
Dishonest use of ones legitimate power for personal gain, Extortion by those in position to offer free services to the
public for self-gain, Falsification, Soliciting or causing others to solicit rewards for otherwise
free service.
PCPB CORRUPTION PREVENTION PLAN Page 8
CORRUPTION RISK ASSESSMENT AND CORRUPTION PRE-VENTION PLAN Corruption Risk Assessment (CRA) is the systematic applica-tion of management policies, procedures and practices to the tasks of identifying, analyzing, evaluating, treating and monitoring corruption risk within the institution. It involves the identifica-tion of corruption loopholes in all functional areas of the organiza-tion and proposing mitigation measures, which when applied will seal the loopholes. This takes into account the real threats to cor-ruption as well as the perceived ones. Corruption Prevention Plan (CPP) can be defined as efforts and resources directed towards sealing loopholes that may allow corrupt practices. The plan outlines the strategies to be employed in sealing the corruption loopholes identified in the CRA. In addi-tion to the loopholes identified and the preferred strategy adopted for implementation in order to seal the loophole, the plan indicates the resources, actors and time frame. CRA and CPP are corruption prevention tools that enable man-agement in institutions to identify corruption prone functional are-as within the institution that may require special attention. It helps management to proactively avert the risk or threat of corruption occurring at the institution and makes it possible to stop corruption before it occurs. CRA and CPP also minimize exposure of staff to opportunities for corrupt practices. This will ultimately improve the image of the PCPB as well as enhancing transparency, efficiency and account-ability in its operations.
PCPB CORRUPTION PREVENTION PLAN Page 37
ACTIVITY
RESPONSI-
BLE PERSON
BUDGET
TIME FRAME
MEANS OF MEASURE-MENT AND DELIVERY
Publicize bids in ap-propriate media i.e. IFMIS ,newspapers, notice boards, PCPB website.
Have a fair quotation rotation method.
Ensure use of dispatch registers for quota-tions/tenders
Allow time as per the public procurement regulations
Let suppliers sign when collecting or receiving quotation or tenders
Discipline staff who leak information
Prompt response to request for clarifica-tions
Chief Execu-tive Officer
SCM Officer
Heads of De-partments/Sections
Annual Budgetary provision
Continu-ous
Dispatch regis-ter or email records
Rotation of bid invitation
Indication of response time and actual opening time
Have a quotation opening committee
Have quotation open-ing committee minutes
Have secure custody of bid documents be-fore and after evalua-tion
Discipline officers leaking information or substituting samples or brochures
Chief Execu-tive Officer
SCM Officer
- Continu-ous
Timely open-ing as per regu-lations
Tender/quotation box
Tender/quotation open-ing minutes
Opening com-mittees
PCPB CORRUPTION PREVENTION PLAN Page 36
CORRUPTION PRONE AREA
CORRUPTION RISKS
CORRUPTION PREVEN-
TION STRATEGY
7 Dispatch of tenders and quotation docu-ments
Insufficient notice for preparation of quotations / tenders
Leakage of information to preferred bidders.
Failure to answer requests for clarification sought by suppliers / contractors.
Comply with timelines pro-vided in the PPAD Act 2015 & PPD Regulations 2006.
Ensure uniformity of infor-mation released to prospective bidders.
Institutionalize procedures of dispatch of tender quotations.
8 Opening of bids, tenders / quotations
Delaying in opening.
Opening before time.
Leakage of bids infor-mation.
Substitution of docu-ments/ samples/brochures.
Different location for receiving bids and open-ing them.
Failure to provide secure storage of, and restricted access to, bids received.
Use tender/quotation boxes
Ensure centralized receiving of bids.
Open immediately after clos-ing
Have tender box keys kept by at least two senior officers
Invite users and suppliers/ contractors during opening
Have a quotation opening Committee
PCPB CORRUPTION PREVENTION PLAN Page 9
Annex 1 provides a detailed matrix of the CRA and CPP for the Pest Control Products Board showing:
Functional areas, Corruption prone areas, Corruption risks, Corruption prevention strategies, Activities, Responsible persons, Budgets, and Time lines.
EARLY WARNING SIGNALS OF CORRUPTION The Pest Control Products Board being a regulatory organi-zation offers services that are prone to corruption. The phe-nomena cited here below particularly when they exist simul-taneously indicate existence of corruption and other malprac-tices in the work systems. They indicate circumstances as to where the management should take a close look in order to identify loopholes for corrupt practices. The following corruption red flags may guide the manage-ment as indicators of corruption: -
Extravagant lifestyle Financial pressure Regularly staying late in the office for no apparent rea-
son Refusal or reluctance to accept a posting/transfer, even
with promotion Refusal or reluctance to take leave Inappropriate friendliness with juniors and clients Paying with cash – exceptionally fast or slow pay-
ments Frequent reports of loss of merchandise, or in the writ-
ing off of stock or bad debts.
PCPB CORRUPTION PREVENTION PLAN Page 10
Excessive purchase/heavy expenditure at discount or staff prices for items not required
Frequent and repeated purchases of small items from the same supplier
Irregular involvement in the affairs of other departments Over-willingness to work overtime during lunch time or take
on particular responsibilities Long inexplicable, hushed telephone calls Late reports and management information/documents pre-
sented for authorization in large, unrelated batches at busy times
Lost documents/documents presented in unusual format, photocopies instead of originals submitted
High staff turnover and low morale Excessive debts/liabilities (pecuniary embarrassment) Creating emergencies in order to buy Authorization or request for authorization late in the day or on
Friday or End of Financial Year. IMPLEMENTATION OF CORRUPTION PREVENTION PLAN (1) In order to implement the Corruption Prevention Plan, there is
hereby established a Pest Control Products Board Corruption Prevention Committee, hereinafter referred to as the committee’ with the following membership: -
Chairperson Chief Executive Officer/Secretary Members Heads of Departments Integrity Assurance Officers
(2) The committee shall have at least five (5) members and may
co-opt not more than three members. 3) The committee shall meet at least once every quarter.
PCPB CORRUPTION PREVENTION PLAN Page 35
ACTIVITY
RESPONSIBLE
PERSON
BUDGET
TIME
FRAME
MEANS OF MEASURE-MENT AND DELIVERY
Involve users.
Capacity building of users involved in specification prepa-rations.
Heads of Depart-ments/Sections
SCM Officer
Annual budget-ary provi-sion
Continu-ous
User requisitions with clear, con-cise and stand-ard technical specifications
Adhere to the thresh-olds and set guide-lines.
Chief Executive Officer
SCM Officer
Evaluation/Inspection & Acceptance Commitees
- Continu-ous
Use of methods within set thresholds
Issue standard pro-curement document to all bidders.
Discipline staff who release bid documen-tation.
Undertake local mar-ket survey.
Chief Executive Officer
SCM Officer
Heads of Depart-ments/Sections
Annual Budg-etary provi-sion
Continu-ous
Use of standard tender docu-ments as guided by PPRA
Timely release of tender docu-ments to pro-spective bidders
Market surveys guided by the PPRA Market Index manual
PCPB CORRUPTION PREVENTION PLAN Page 34
CORRUPTION PRONE AREA
CORRUPTION
RISKS
CORRUPTION PRE-VENTION STRATE-
GY
4 Identification of needs / specifications
Tailoring of specifications and/or Terms of reference.
Weak technical specifi-cations that lead to wrong procurement.
Conduct periodic market surveys.
5 Choice of procure-ment method
Use of inappropriate procurement method.
Use procurement methods thresholds schedules as spelt out in the Public Procurement and Asset Disposal Act(PPAD) Act, 2015 & Public Procure-ment and Disposal Regu-lations (PPDR), 2006
6 Preparation of bid documents
Unnecessary complexity of bid documents.
Advance release of bid documentation or relevant information to preferred bidders.
Under or over-specifications requirements
Use of standard procure-ment document.
Confidentiality in prepa-ration of bid documents.
Use of clear/concise spec-ifications.
PCPB CORRUPTION PREVENTION PLAN Page 11
4) The committee shall have the following terms of reference:
Set priorities of prevention of corruption within PCPB
Ensure that all corruption prevention initia-tives are integrated within PCPB
Receive and review reports on corruption initiatives and recommend appropriate ac-tion
Plan and coordinate corruption prevention strategies
Consider and review internal training on corruption
Ensure all decisions and policies on cor-ruption prevention are communicated ef-fectively to all levels of staff and all inter-ested parties
Receive complaints and information of cor-rupt activities within PCPB and evaluate, analyze and recommend appropriate ac-tion
Monitor the impact of corruption preven-tion initiatives
Spearhead anti-corruption campaigns within areas of jurisdiction
Prepare and submit regular progress re-ports on implementation of the program and recommended actions on reported corrupt activities to the Ethics and Anti-Corruption Commission .
PCPB CORRUPTION PREVENTION PLAN Page 12
CORRUPTION PRONE AREA
CORRUPTION
RISKS
CORRUPTION PREVEN-
TION STRATEGY
(a) REGISTRATION OF PEST CONTROL PRODUCTS1 Identification of prod-
ucts registration appli-cations for discussion by technical commit-tee
Selective/biased identifi-cation
Maintain an application register for complete applications
Use First In First Out (FIFO) method
2 Issuance/Extension of Imports/Exports per-mit
Delays in processing.
Selective approvals.
Failure and delay to communicate deficien-cies in application to the applicant.
Forged signature and stamp
Maintain an imports/export permits register.
Use First In First Out (FIFO) method to process permits.
Automate processing of im-ports/exports permits.
Incorporate permit extension in the Kentrade System.
3 Allocation of products applications for regis-tration
Selective allocation of applications.
Random allocation.
4 Issuance of efficacy trial permits for new products applications
Issuance of trial permits for deficient applications.
Trials being conducted without a permit
Maintain records of processing and approvals of trial permits.
Follow registration guidelines.
5 Evaluation of efficacy trials in the field, Physical chemical studies, toxicology and other studies
Unsafe products, or non efficacious products being passed.
Efficacious products being failed.
Comply with accreditation crite-ria.
Use an institutionalized evalua-tion criteria for monitoring and evaluation.
6 Evaluation of dossiers Biased reporting of an evaluation.
Lack of a comprehensive evaluation of dossier.
Team evaluation of dossier.
Peer review of evaluation re-ports.
Annex 1: CORRUPTION RISK ASSESSMENT AND CORRUPTION PREVENTION PLAN
PCPB CORRUPTION PREVENTION PLAN Page 33
ACTIVITY
RESPONSI-BLE PER-
SON
BUDGET
TIME
FRAME
MEANS OF
MEASUREMENT AND DELIVERY
(g) PROCUREMENT OF GOODS AND SERVICES
Facilitate staff to attend procurement-based trainings.
Finalize and ap-prove procurement polices and sensitize staff.
Adhere to guidelines on Records management.
Procure and implement computer-based procurement systems.
Chief Execu-tive Officer
Supply Chain Management (SCM) Of-ficer
Evaluation/Inspection & Acceptance Commitees
Annual Budgetary provision/Procure-
ment plan
Continu-ous
Training certificates
Budget and Initiatives to computerize
Use procurement plan.
Adhere to budget-ary provisions.
Chief Execu-tive Officer
SCM Officer
Heads of Departments/Sections
Annual Budgetary provision
Annual
Approved Annual Procurement plans
Annual disposal plan
Evaluate suppliers of goods and ser-vices as per set criteria.
Regular consulta-tion with the Na-tional Treasury on procurement issues.
Chief Execu-tive Officer
Heads of Departments/Sections
SCM Officer
Annual budgetary provision
Continu-ous
Prequalified list
Evaluation reports
PCPB CORRUPTION PREVENTION PLAN Page 32
CORRUPTION PRONE AREA
CORRUPTION
RISKS
CORRUPTION PRE-
VENTION STRATEGY
(g) PROCUREMENT OF GOODS AND SERVICES1 Administration of
procurement func-tion
Ignorance in pro-curement law and regulations.
Poor record keeping of procurement processes.
Retrospective Ratifications of approvals.
Manual procurement process.
Have approved internal pro-curement policies.
Sensitize staff on procure-ment laws and regulations.
Comply with PPRA record keeping manual.
Procurements be undertaken as per PPAD Act, 2015 & PPD Regulations, 2006.
Computerize procurement activities.
2 Procurement plan-ning
Failure to adhere to Procurement plan.
Procuring without a budget.
Adhere to annual procure-ment plans
Comply with PPRAguide-lines on procurement budg-ets.
3 Registration / prequalification for complex and spe-cialized goods, works and services contractors/suppliers
Disqualification of potential suppliers/ contractors.
Registration of un-qualified suppliers e.g. brief case sup-pliers.
Comply with criteria set for registration/pre-qualification.
Involve users and respective committee in the evaluation process.
Conduct due diligence of the suppliers/ contractors.
PCPB CORRUPTION PREVENTION PLAN Page 13
ACTIVITY
RESPONSI-BLE PER-
SON
BUDG
ET
TIME
FRAME
MEANS OF MEASUR-MENT AND DELIVERY
(a) REGISTRATION OF PEST CONTROL PRODUCTS For complete applica-
tions, process according to the order in the regis-ter
Head of Reg-istration & Analysis de-partment
Annual Budget-ary pro-vision
Continuous Number of dossiers re-ceived in FIFO register
Ensure updated imports/export permit register
Prompt communication of deficiencies to appli-cants
Maintain operational Kentrade System
Liaison with Kentrade
Registration Officers
Inspectors
Accountant
Chief Execu-tive Officer
ICT Officer
Clerical Of-ficers
- Continuous Number of imports/export in the register
Number of rejected import application
Electronic per-mits extension
Use systematic random allocation process.
Registration clerk
- Continuous Number of products allo-cated using the criteria
Strict adherence to regis-tration guidelines before issuance of permit.
Registration Officers
- Continuous Number of permits without deficiencies
Number of trials with per-mits
Impromptu visits to trial sites by registration of-ficers.
Follow trial protocols.
Accreditation of trial institutions.
Registration Officers
Incorpo-rate in Annual budgets
Continuous Number of non efficacious products
Number of efficacious products failed
Each dossier be evaluat-ed by a relevant expert.
Introduce peer review.
Registration Officers
- Continuous Number of dossiers evalu-ated
Annex 1: CORRUPTION RISK ASSESSMENT AND CORRUPTION PREVENTION PLAN
PCPB CORRUPTION PREVENTION PLAN Page 14
CORRUPTION PRONE AREA
CORRUPTION RISKS
CORRUPTION PREVEN-TION STRATEGY
7 Sampling of pesticides(Post Registration surveil-lance)
Selective/biased sampling of pesti-cides
Apply sampling protocols.
8 Analysis of product sam-ples
Biased reporting/Pre-determined results.
Delays in sample analysis.
Inter-changing sam-ples.
Maintain a register of samples sub-mitted.
Use the FIFO method.
Confirmatory analysis.
Proper custody of samples.
9 Communication of deci-sion of the Board on reg-istration of products
Selective communi-cation
Delays in communi-cation
Prompt communication
10 De-registration/ Revoca-tion of registration of products
Raising of false alarms
Follow de-registration regulations
Establish Revocation/de-registration procedures
11 Registration of products Adhoc requirements for registration
Conflict of interest
Follow products registration regu-lations
Establish procedures for introduc-tion of new requirements
Board/committee members/registration officers to declare in-terest
Secure dossiers and Confidential Business Information (CBI)
PCPB CORRUPTION PREVENTION PLAN Page 31
ACTIVITY
RESPONSIBLE
PERSON
BUDGET
TIME
FRAME
MEANS OF MEASURE-MENT AND DELIVERY
Maintain independence of auditing functions
Chief Executive Officer
Internal Auditor
- Annual budget pro-
vision
Continuous Audit reports
Adherence to the Fi-nancial Management Act.
Chief Executive Officer
Accountant
- Continuous Investments reports
Adherence to the rec-ommendations of the budgeting committee.
Chief Executive Officer
Heads of Depart-ments/sections
- Continuous Approved budgets
(f) INFORMATION COMMUNICATION TECHNOLOGY SERVICES
Adhere to established procedures.
Prompt update of rec-ords as authorized.
Maintain system logs and audit trails.
Implement information security measures.
Installation of physical security gadgets in computer rooms, lock-able cabinets, firewalls.
Heads of Depart-ments
Information Com-munication Tech-nology Officers
Annual budgetary provision
Continuous Issuing of user rights to em-ployees with different levels of access rights.
Scheduled maintenance of software and peripheral devices.
Constant mon-itoring of system logs
Regular update of anti-virus license.
Adhere to ICT mainte-nance schedules.
Establishing offsite back-ups.
Heads of Depart-ments
Information Com-munication Tech-nology Officers
Annual budgetary provision
Continuous Hardware and software maintenance.
Software up-grades and configurations.
PCPB CORRUPTION PREVENTION PLAN Page 30
CORRUPTION PRONE AREA
CORRUPTION RISKS
CORRUPTION PREVEN-
TION STRATEGY
4 Internal audit function
Non disclosure of true audit findings
Strengthen internal auditing unit
5 Financial invest-ments
Inappropriate investment. Comply with provisions of the Financial Management Act.
6 Budgeting process and funds re-allocation
Failure to involve user departments in the budget making process
Allocation of funds with vested interests.
Involvement of budget com-mittee in budgeting process.
(f) INFORMATION COMMUNICATION TECHNOLOGY SERVICES1 Information Secu-
rity Unauthorized access to
information.
Loss/misuse of data or information.
Unauthorized amend-ments (Addition/deletion/insertion) of information
Failure to update records as authorized
Issuance of access code to unauthorized users
Use access controls to systems e.g. usernames and passwords.
Monitoring system usage in the system logs and audit trail.
Utilize procedures for amend-ments of electronic records.
Adhere to ICT policy
Comply with approved user authorization/access privileges.
2 Hardware and Software manage-ment
Introduction of malicious program.
Disruption of office ac-tivities.
Delay of updating/upgrading management systems.
Virus protection.
Utilize ICT systems mainte-nance schedules.
Develop Business Continuity/Disaster Recovery Plans.
PCPB CORRUPTION PREVENTION PLAN Page 15
ACTIVITY RESPONSIBLE PERSON
BUDGET TIME FRAME
MEANS OF MEASUREMENT AND DELIVERY
Develop of sampling protocols by analysts
Sampling to be con-ducted by inspectors as per the PCP Act.
Adherence to sampling protocols by inspectors.
Pesticide analysts.
Inspectors.
- Continu-ous
Number of proto-cols
Update register of pes-ticide samples.
Submission of full analytical report.
Undertake confirmato-ry tests by a different officer.
Establish multi-lock access system for sam-ples.
Pesticide Analysts Incorporate in Annual budgets.
Continu-ous
Updated register
Number of confir-mation tests
Comply with provi-sions in the service delivery charter.
Chief Executive Officer
- Continu-ous
Compliance with service charter
Adhere to regulations on de-registration of products
Follow the laid down procedure
Chief Executive Officer
- Continu-ous
No of false alarms
Apply registration re-quirements uniformly.
Interested members to disqualify themselves from decision making process.
Store information in lockable cabinets or bulk filers
Board of Manage-ment.
Technical and Registration Com-mittee.
Chief Executive Officer.
Registration Offic-ers
- Continu-ous
Number of guide-lines
Use of SOPs
Use of lockable cabinets/bulk filers
PCPB CORRUPTION PREVENTION PLAN Page 16
(b) INSPECTION AND LICENSING OF PREMISES CORRUPTION
PRONE AREA CORRUPTION
RISKS CORRUPTION PREVEN-
TION STRATEGY
1 Issuance of premis-es/business licenses
Issuance of licenses to non-complying premises.
Delays in issuance of licenses.
Issuance of licenses to uninspected prem-ises
Compliance with established minimum requirements criteria.
Follow provisions in the service charter.
2 Inspection of prem-ises/businesses
Biased/selection of premises / regions to inspect
Develop an Annual work plan
Rotational program for officers
3 Inspection report Falsification of report Ensure inspectors are of high integrity
Random verification checks
4 Investigations Selective investiga-tion.
Inconclusive investi-gations.
False allegations.
Delays in investiga-tions.
Leakage of infor-mation leading to interference with evidence.
Abuse of discretion in disposal of cases of non-compliance.
Maintain an Occurrence Book (OB).
Train inspectors on investiga-tions.
Verify source of information
Restrict investigation infor-mation
Hold Inspector’s meeting to adjudicate in cases of non-compliance in accordance to the law
PCPB CORRUPTION PREVENTION PLAN Page 29
ACTIVITY
RESPONSIBLE
PERSON
BUDGET
TIME
FRAME
MEANS OF MEASURE-MENT AND DELIVERY
MANAGEMENT Keep track of all the
receipt books Accountant
Internal Auditor
Annual budg-et provision
Continuous Upadated register of receipt books issuance
Carry out regular reconciliation of cash book
Regular auditing to be undertaken
Accountant
Internal Auditor
- Continuous Monthly bank recon-ciliations
Audit reports
Ensure all collected revenue is banked by end of week
Accountant
Internal Auditor
Annual budg-et provision
Continuous Receipt vouchers
Observe checks and balances in the ap-proval process.
Adherence to govern-ment financial regula-tions.
Chief Executive Officer
Accountant
Internal Auditor
Inspectors
- Annual budget provi-
sion
Continuous Budgetary levels
Procurement plan
Regular auditing of accounting records
Accountant
Internal Auditor
Annual budg-et provision
-
Continuous Audit reports
Adherence to guide-lines on acquisition and disposal of assets
Chief Executive Officer
Accountant
Procurement of-ficer
Internal Audit
Annual budg-et provision
-
Continuous Up to date Asset register
PCPB CORRUPTION PREVENTION PLAN Page 28
CORRUPTION PRONE AREA
CORRUPTION RISKS
CORRUPTION PREVEN-
TION STRATEGY
(e) FINANCIAL 1 Revenue manage-
ment (receipting and deposits)
Failure to maintain an ac-countable receipt books reg-ister.
Failure to keep track of reve-nue collections and banking.
Teaming and lading.
Unreconciled cash records.
Maintain receipt books regis-ter.
Internal controls and supervi-sion.
Comply with requirements for banking of cash collec-tions.
2 Expenditure man-agement
Making unauthorized pay-ments from revenue collect-ed.
Unauthorized lending.
Non-compliance with limits for cash payments.
Unauthorized payments.
Failure to make authorized payments.
Apply internal controls.
Compliance with Expenditure guidelines.
3 Accounting rec-ords management
Falsification of expenditure documents.
Non-traceability of financial records.
Wrong posting of accounts
Observe internal controls
Periodic tracking of budget-ary allocation and expenditure
4 Assets Manage-ment
Inappropriate acquisition and disposal of assets.
Comply with guidelines on acquisition and disposal of assets
PCPB CORRUPTION PREVENTION PLAN Page 17
(b) INSPECTION AND LICENSING OF PREMISES ACTIVITY RESPONSIBLE
PERSON BUDGET TIME
FRAME MEANS OF MEAS-
UREMENT AND DE-LIVERY
Adhere to the estab-lished minimum cri-teria.
Prompt issuance of licenses upon inspec-tion and payment of relevant fees
HOD and Region-al Managers
- Continuous Inspection reports
Target 0- 2 weeks for license issu-ance upon inspec-tion and payment of licence fees
Adhere to the work plan
HOD and Region-al Managers
Annual budgetary provision
Continuous Work programmes and reports
Inspection be carried out by at least two officers
HOD and Region-al Managers
- Continuous All work programs and reports
Record outcome of every stage of inves-tigation in the OB.
Facilitate training of inspectors.
Inspectors to collect preliminary infor-mation prior to travel.
Disciplinary measures be taken against officers who leak information
Investigating officer to be involved at all stages in the disposal of cases.
HOD and Region-al Managers
Incorporate in the
Annual budget
Continuous Investigation file and report
Number of inspec-tors trained
Investigation pro-grams and reports
Number of case and action taken
Investigation report
PCPB CORRUPTION PREVENTION PLAN Page 18
CORRUPTION PRONE AREA
CORRUPTION RISKS
CORRUPTION PRE-VENTION STRATE-
GY
5 Categorization of Busi-nesses/premises and Col-lection of license fees
Failure to collect required fees as per category of busi-ness.
Computerization of prem-ises details.
Ensure inspectors are people of high integrity.
6 Impounding/seizure and release of products
Selective impounding/release of products.
Comply with minimum criteria for seizure/release of products.
7 Prosecutions Selective institution of legal action.
Failure to follow court pro-ceedings to conclusion.
Comply with PCP Act.
Follow-up cases to logical conclusion.
8 Training of stakeholders Biased selection of officers to undertake training of stake-holders.
Have a work plan on trainings.
9 Verification and release of pesticide imports/exports at ports of entry/exit
Allow importation/Exportation of products with-out import/export permit.
Release of illegally imported products.
Irregular release of products.
Apply procedures of re-lease.
Engagement in pesticides business
Conflict of interest Adherence to Cap 346
PCPB CORRUPTION PREVENTION PLAN Page 27
ACTIVITY
RESPONSIBLE
PERSON
BUDG-
ET
TIME
FRAME
MEANS OF MEASURE-MENT AND DELIVERY
(d) ADMINISTRATION SERVICES
Control of issuance of work tickets
Scrutinize details of journey before authoriz-ing use or fueling
Use of fuel cards.
Adherence to service schedules and repair guidelines
Carry out market survey to determine costs of repairs and maintenance
Use laid down procure-ment procedures to seek repairs and maintenance services
Prompt payments after ascertaining that the job has been done as re-quired.
Monthly fuel analysis reports.
Chief Executive Officer
Administrator
Accountant
Transport officer
Annual budget-ary pro-vision
Con-tinuou
s
Procurement of a fleet manage-ment system
Observe ethical commu-nication practices pre-scribed in the code of conduct and ethics
Adhere to the PCPB core values
Adherence to official language when com-municating official mat-ters
All PCPB offic-ers
- Con-tinuou
s
Work environ-ment surveys
PCPB CORRUPTION PREVENTION PLAN Page 26
CORRUP-
TION PRONE AREA
CORRUPTION RISKS
CORRUPTION PREVEN-
TION STRATEGY
(d) ADMINISTRATION SERVICES
Transport Misuse of motor vehicles.
Falsification of fueling records.
Exaggerated costs of re-pairs and maintenance.
Delays in carrying out repairs and maintenance of vehicles.
Repair and maintenance of vehicles being done by unauthorized garages.
Delayed payments after repairs have been done.
Maintenance of records for work tickets.
Authorization procedures for use and fueling of vehicles
Use of service schedules and repair guidelines.
Use of procurement committee to secure repair and mainte-nance services for vehicles.
Use of authorized garages for repairs and maintenance.
Expeditious processing of pay-ments.
2 Internal Commu-nication
Use of intimidating lan-guage.
Lack of feedback.
Use of unofficial language in communicating official matters
Implementation of the code of conduct and ethics for PCPB
Institutionalize PCPB core val-ues
Use of official language of communication
PCPB CORRUPTION PREVENTION PLAN Page 19
ACTIVITY
RESPONSIBLE
PERSON
BUDGET
TIM
E FRAME
MEANS OF MEASURE-MENT AND DELIVERY
Operationalize the PCPB computer-based database system..
Train officers on in-tegrity issues.
Chief Executive Officer
Inspectors
Accountant
ICT officer
Annual budgetary provisions
Con-tinuou
s
Data inputted into PCPB com-puter based sys-tem
Bank slips Number of officers trained; Discipli-nary cases report-ed and acted upon
Apply minimum crite-ria uniformly
Chief Executive Officer
Inspectors
- Con-tinuou
s
Inspection re-ports
Consistent adherence to the PCP Act.
Supervision be under-taken to ensure cases are taken to full com-pletion
Chief Executive Officer
Inspectors
Annual budgetary provision
Con-tinuou
s
All cases of non compliance in-vestigated
Cases followed to logical conclu-sion
Allocate officers on rotational basis
Adherence to work plan on trainings.
Chief Executive Officer
Inspectors
Registration Of-ficers
Annual budgetary provision
Con-tinuou
s
Training plan
Number of offic-ers trained
Verification to be done by one officer on a rotational basis.
Only authorized offic-ers to release prod-ucts.
Inspectors Annual budgetary provision
Con-tinuou
s
Work plans for port activities
Monthly reports
Signing the code of conduct and ethics for PCPB officers
Signed Code of conduct and ethics by all inspectors
CEO
HR
Head of compli-ance and enforce-ment.
- Con-tinuou
s
PCPB CORRUPTION PREVENTION PLAN Page 20
CORRUP-TION
PRONE AR-EA
CORRUPTION RISKS
CORRUPTION PRE-VENTION STRATE-
GY
(c) HUMAN RESOURCE MANAGEMENT
1 Human re-source planning
Adhoc employment due to non-adherence to em-ployment guidelines.
Incorporate Human Re-source Planning within PCPB plans.
2 Recruitment / Selection
Favouritism
Tribalism
Nepotism
Cronism
Interested parties being involved at the selection stage
Failure to advertise or limiting circulation of advert
Job analysis
Advertisement
Interview panels
Development of succes-sion plan
PCPB CORRUPTION PREVENTION PLAN Page 25
ACTIVITY
RESPONSIBLE PERSON
BUDG-ET
TIME FRAME
MEANS OF MEASURE-MENT AND DELIVERY
Manage discipline cases through a disci-plinary committee
Chief Executive Officer
Human Resource Officer Chief Executive Of-ficer -
Continu-ous
Minutes of Staff Advisory Com-mittee
Adherence to the code of conduct and ethics
Reference to code of conduct
Adhere to disciplinary procedures
Allow for appeal/redress
Number of appeal cases
Adhere to the provi-sions of Career Guide-lines and Human Re-source Manual
Chief Executive Officer
Human Resource Officer
- Continu-ous
Compliance to pay structures
Rewards to be based purely on fairness and merit
Adoption of public service reward and sanction policies
Use of a Com-mittee to handle reward
Adhere to Retirements Benefits rules and reg-ulations.
Implement a human resource management system.
Prompt processing of exit benefits.
Chief Executive Officer
Human Resource Officer
- Continu-ous
Prompt pro-cessing of exit benefits
Conduct appraisals Objectively.
Consultation between appraiser and appraise on agreed targets.
Provide feedback on staff appraisals.
Chief Executive Officer
Human Resource Officer
Heads of Depart-ments/Sections
- Continu-ous
List of apprais-al reports every end of year
PCPB CORRUPTION PREVENTION PLAN Page 24
CORRUP-TION PRONE AREA
CORRUPTION RISKS
CORRUPTION PREVEN-TION STRATEGY
6
Discipline Violation of laid down procedures in handling cases.
Deliberate delays in con-cluding cases.
Set up disciplinary committees
Comply with code of conduct and ethics
Comply with disciplinary proce-dures
7 Reward manage-ment and staff motivation
Disparities in pay struc-tures and benefits.
Discrimination and injus-tices in rewarding of bene-fits.
Compliance with Career Guide-lines and Human Resource Man-ual
Establish an adhoc reward com-mittee
8 Management of Separation (Exit)
Delays in payment of bene-fits.
Compliance with Retirements Benefits rules and regulations.
Computerize employee records.
9 Performance management
Using appraisals to settle scores.
Rewarding and promoting non-performers
Subjective appraisal due to failure to set or agree on standards and targets .
Compliance to set appraisal Guidelines.
Use of negotiation in setting individual performance targets.
PCPB CORRUPTION PREVENTION PLAN Page 21
ACTIVITY
RESPONSI-BLE PERSON
BUDGET
(Kshs)
TIME
FRAME
MEANS OF MEASURE-MENT AND DELIVERY
(c) HUMAN RESOURCE MANAGEMENT
Carry out job evaluation to determine staff require-ments.
Adhere to employment guidelines
Chief Executive Officer
Human Re-source Officer
2.5M Once every four years
Con-tinuo
us
Job evaluation carried out
Job description to be as stipulated in the Career Guidelines
Chief Executive Officer
Human Re-source Officer
- Con-tinuo
us
Job Descriptions issued to all employees
Place job advertisement for a period of at least 21 days in widely circulated media and PCPB website
Chief Executive Officer
Human Re-source Officer
Incor-porate in an-nual
budget
Con-tinuo
us
Number of ad-vertisements placed in print media and web-site
Manage recruitment and selection through commit-tees
Members of the commit-tee be people of high in-tegrity and from relevant functional areas
Adherence to selection requirements
Have pre-determined criteria for short listing
Conduct interview using objective methods
Chief Executive Officer
Human Re-source Officer
- Con-tinuo
us
Constituted shortlisting and interview panels and interview criteria as per requirements
Timely replacement of exiting staff subject to budgetary provisions.
Integrate succession plans within PCPB staff devel-opment plans
Chief Executive Officer
Human Re-source Officer
Head of Depart-ment’s
- Con-tinuo
us
Human resource plan
PCPB CORRUPTION PREVENTION PLAN Page 22
CORRUP-TION PRONE AREA
CORRUPTION RISKS
CORRUPTION PREVEN-TION STRATEGY
3 Managing career progression
Arbitrary/Selective promotions due to non-adherence to Career Guidelines
Failure to facilitate staff to acquire requi-site requirements for career progression leading to low morale.
Decision Making through Staff Advisory Committee
Use Career Guidelines in De-cision Making.
Adherence to human resource Manual
4 Placement, de-ployment and transfers
Placing employees in areas they are not qual-ified for.
Transferring/deploying employees for personal interest or punitive measures.
Compliance to staff rules and regulations on transfers and deployment.
Placement of employees be based on Career Guidelines.
Compliance to set guidelines on length of stay in stations.
5 Training and de-velopment
Favouritism.
Tribalism.
Nepotism.
Cronism.
Adhoc identification of persons to attend train-ing.
Denying opportunities to deserving employ-ees.
Undertake Training Needs Assessment (TNA).
Develop Training Guidelines/Policy.
PCPB CORRUPTION PREVENTION PLAN Page 23
ACTIVITY
RESPONSI-BLE PERSON
BUDGET
TIME FRAME
MEANS OF MEASURE-MENT AND DELIVERY
Adherence to rec-ommendations of Staff Advisory Committee
Chief Executive Officer
Human Re-source Officer Chief Executive Officer
Annual budgetary provision
Con-tinuous
Minutes of Staff Advisory Com-mittee meetings
Adherence to estab-lished schemes of service
Periodic review of career guidelines
Reference made to career guide-lines in every decision
Integrate and adhere to the established human resource manual
Reference made to HR Manual .
Adherence to the set guidelines on trans-fers and deploy-ments
Placement to be done based on area of expertise
Chief Executive Officer
Human Re-source Officer
Heads of De-partments
- Con-
tinuous
Transfers and deployment of staff done as per guidelines
Managing training selection processes through committees.
Preparation and adherence to train-ing projections.
Training on need basis upon under-taking TNAs.
Adherence to rec-ommendations of Staff Advisory committee.
Chief Executive Officer
Human Re-source Officer
- Con-
tinuous
Training pro-gramme as per Staff Advisory Committee ap-proval.