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Manual of Fiancial & Internal Control Procedures - Diocese of ...

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MANUAL OF FINANCIAL AND INTERNAL<br />

CONTROL PROCEDURES OF THE<br />

DIOCESE OF NOTTINGHAM<br />

The Finance Office is always happy to receive helpful comments about this and other<br />

manuals.<br />

<strong>Diocese</strong> <strong>of</strong> Nottingham <strong>Manual</strong>s:<br />

The complete set <strong>of</strong> <strong>Manual</strong>s for use in the <strong>Diocese</strong> are downloadable from the<br />

diocesan website, www.nottingham-diocese.org.uk.<br />

Parishes:<br />

Parish Administration <strong>Manual</strong><br />

Curia:<br />

Financial and <strong>Internal</strong> <strong>Control</strong> <strong>Procedures</strong><br />

<strong>Diocese</strong> (both Parish and Curia):<br />

Personnel<br />

Insurance (see also CCIA website User name: Nottingham Password: Anicetus)<br />

Health and Safety<br />

Priests:<br />

Vade Mecum (password protected)


FINANCIAL AND INTERNAL CONTROL<br />

Generally the Charity is a large one. However the number <strong>of</strong> people employed at any<br />

one <strong>of</strong>fice is not usually large, making internal control more difficult. In this case<br />

there is a particular duty on department heads to ensure that special care is taken over<br />

financial matters in particular when authorising and approving expenditure.<br />

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THE BOARD OF DIRECTORS<br />

1. The running <strong>of</strong> the Charity is the legal responsibility <strong>of</strong> the Board <strong>of</strong> Directors<br />

<strong>of</strong> the Company. (Until 31 st March 2010 it was the responsibility <strong>of</strong> the<br />

Trustees). This Company is referred to as the charity or the <strong>Diocese</strong> in this<br />

manual.<br />

2. The Board delegates the responsibility <strong>of</strong> keeping proper books and records to<br />

the Finance Office. The Annual Report & Accounts and the budgets are<br />

prepared by the Finance Office and are formally approved by the <strong>Diocese</strong>.<br />

3. The Company has the power <strong>of</strong> appointing new Directors and the Bishop has<br />

an effective veto over the decisions <strong>of</strong> the Board. A new Director indicates<br />

the formal taking up <strong>of</strong> responsibilities by signing the notification to<br />

Companies House.<br />

4. The Board meets formally at least four times per annum.<br />

5. Each <strong>of</strong>fice, department or service, or by whatever name it is known, is under<br />

the formal control <strong>of</strong> the Board.<br />

6. Independent pr<strong>of</strong>essional advice is available to the Directors.<br />

7. The Directors’ liabilities are insured.<br />

Segregation <strong>of</strong> Duties<br />

8. Where possible key duties are segregated. A person having access to cash or a<br />

cheque signatory should not also be responsible for accounting records.<br />

9. Unless otherwise authorised by the department head incoming post should be<br />

opened by two people.<br />

10. A separate record will be maintained <strong>of</strong> money due into the charity, for<br />

example when legacies have been notified, or for Gift Aid and other<br />

donations. Follow up checks are then made to ensure that it has been received.<br />

Cash and Bank Balances.<br />

11. A list <strong>of</strong> bank accounts, their signatories (which will always include the<br />

Bishop, the Moderator <strong>of</strong> the Curia, the Chancellor, both Vicars General and<br />

the Financial Secretary) and their purpose will be recorded in the Finance<br />

Office. Accounts may be opened and closed only on the authority <strong>of</strong> the<br />

Finance Office.<br />

12. It is the policy <strong>of</strong> the Board that, where possible, new accounts are not opened<br />

and that all transactions take place through the main Diocesan account.<br />

13. The policy <strong>of</strong> the <strong>Diocese</strong> is that all cheques for payments above £5 thousand<br />

require two signatures, one <strong>of</strong> which will be one <strong>of</strong> those mentioned in the<br />

previous paragraph. No signatory may sign a cheque payable to him or<br />

herself. It is obviously not permitted to avoid the second signature on cheques<br />

above £5,000 by making out a series <strong>of</strong> cheques for under £5,000.<br />

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14. Incoming cheques should be banked daily. If this is not possible they should<br />

be kept in a safe and banked as soon as possible and in any case at least<br />

weekly. Where they are banked by post full details should be kept (eg by<br />

photocopying) so that if mislaid replacement cheques can be obtained.<br />

Banking <strong>of</strong> cash should be gross and cash not held back for petty cash<br />

15. The charity’s money must be kept quite separately from personal money.<br />

(However this does not prevent expenditure being incurred originally in a<br />

personal name with a view to reimbursement at a later stage by the charity).<br />

16. Checks <strong>of</strong> cash books and the paying-in slips and cheque payments should be<br />

made from time to time by someone separate from the person originally<br />

recording the transaction. Bank reconciliations should be carried out each<br />

month, then independently checked and reviewed.<br />

17. Accounts may not go overdrawn without prior approval.<br />

18. When making payments, expenditure must be properly authorised and<br />

presented with the supporting documentation to the cheque signatories.<br />

19. Means <strong>of</strong> payments such as cheque books, building society passbooks and<br />

bank mandate forms must be kept in a safe with access limited.<br />

20. If possible the preparation <strong>of</strong> documentation for authorisation should be<br />

undertaken by someone other than the person authorising the payment. The<br />

person authorising should ensure that the goods or service being paid for have<br />

been ordered. The authorisation should be <strong>of</strong> original invoices only, if<br />

possible, (in order to ensure that an invoice is not paid twice). It should be<br />

stamped PAID with the date (or marked in some way in order to prevent its<br />

being paid twice) which should be in red. The authorisation is <strong>of</strong> the invoice<br />

and not the statement, again to avoid payments being made twice. Be<br />

particularly careful to avoid double payments where invoices have been<br />

emailed and can be downloaded and authorised twice in error.<br />

21. An order shall only be placed with the approval <strong>of</strong> the department head. If<br />

over £300 this will need to be written. Continuation <strong>of</strong> the following authority<br />

limits were determined by the Board at its meeting on 28 th September 2011.<br />

£300- £1000 Head <strong>of</strong> Department<br />

£1,000 - £5,000 Financial Secretary/ Moderator <strong>of</strong> the Curia<br />

£5,000 - £50,000 (£100 thousand having consulted the Board) Management<br />

and Finance Committee<br />

£5,000 - £250,000 (£650 thousand having consulted the Board) Building and<br />

Sites Committee – property transactions only.<br />

Above these limits Board <strong>of</strong> Directors.<br />

22. The record placed <strong>of</strong> orders should allow for the amount <strong>of</strong> outstanding orders<br />

to be ascertained.<br />

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23. Under no circumstances whatsoever are blank cheques to be signed in<br />

advance. In the words <strong>of</strong> the Charity Commission guide, “It is a<br />

dangerous breach <strong>of</strong> financial controls” and “the practice <strong>of</strong> signing<br />

blank cheques would be regarded as neglecting the duty <strong>of</strong> care owed by<br />

the charity”.<br />

24. Cheque expenditure is to be recorded in the cash book with details <strong>of</strong> the date,<br />

payee, cheque number and amount. Cheque book stubs are to be completed at<br />

the time <strong>of</strong> payment (as they form part <strong>of</strong> the charity’s accounting records).<br />

Where, exceptionally, a card has been provided for use for charity expenditure<br />

a separate account will be associated with it to assist with control <strong>of</strong> that<br />

expenditure.<br />

25. Cash payments are to be kept to a minimum because <strong>of</strong> the difficulties <strong>of</strong><br />

internal control over them.<br />

26. Proper supporting independent documentation for all payments and remittance<br />

advices for receipts must be retained and kept in the designated files and be<br />

available for internal check or external audit however the payment or receipt is<br />

made.<br />

27. Payment for expenses to be reimbursed should be submitted in a reasonable<br />

time, normally monthly, authorised independently (normally by a department<br />

head) and properly supported in the usual way as noted above.<br />

Accounting Records<br />

28. There will be proper records kept, enabling an audit trail from the original<br />

documents to the final accounts.<br />

29. Allocation <strong>of</strong> expenses to the right account is important, particularly where a<br />

restricted fund is to be charged.<br />

30. Budgets will be set in discussion with each department and agreed by the<br />

Trustees. Underspending against budget in a year cannot be carried forward<br />

or transferred to another account without approval <strong>of</strong> the Finance Office.<br />

31. It is intended that a fixed asset register will be prepared. Nothing is<br />

capitalised in the accounts unless its value is greater than £5,000. This does<br />

not prevent a fixed asset register record <strong>of</strong> details <strong>of</strong> items with lower values<br />

but they will not be treated as capital expenditure in the accounts and<br />

depreciated.<br />

32. Each person for whom a computer is provided is responsible for their own<br />

computer housekeeping routines, including back up, remote back up and other<br />

housekeeping routines such and also for ensuring that back up media are<br />

physically destroyed when no longer required. A department head is<br />

responsible for ensuring the same for the department’s network server and also<br />

for ensuring that hard drives <strong>of</strong> computers are destroyed when no longer<br />

required. A remote back up should be taken at least monthly.<br />

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Guardianship <strong>of</strong> Assets<br />

33. Assets are generally held in the name <strong>of</strong> the Company. Where the strict<br />

requirements <strong>of</strong> legislation are followed, whereby the beneficial ownership <strong>of</strong><br />

the assets is beyond doubt, they may held in other names.<br />

34. The Board is responsible for the Investment Policy, a copy <strong>of</strong> which is<br />

available from the Finance Office.<br />

35. Investment performance is the responsibility <strong>of</strong> the Management and Finance<br />

Committee <strong>of</strong> the Board and is to be brought to its attention.<br />

36. The opening and closing <strong>of</strong> bank accounts are to be authorised by the charity.<br />

Dormant accounts should be reviewed from time to time and closed if<br />

necessary.<br />

37. The fixed asset register needs to be checked to the fixed assets themselves<br />

from time to time. The condition <strong>of</strong> the fixed asset should be noted at that<br />

time.<br />

38. A proper register is maintained <strong>of</strong> land and buildings. This should be<br />

expanded to include data relevant to their maintenance and insurance. It<br />

should also include, for leased property, details <strong>of</strong> the terms <strong>of</strong> the lease. A<br />

proper diary system is to ensure that the relevant notices are given at the<br />

correct time for leased property.<br />

39. Generally, where a property is let, the <strong>Diocese</strong> as landlord should insure and<br />

then pass the cost on to the tenant through the lease.<br />

40. The disposition (including selling or leasing) or charging <strong>of</strong> land is subject to<br />

the special requirements for them under the Charities Acts.<br />

41. Protection <strong>of</strong> the documents <strong>of</strong> title are the responsibility <strong>of</strong> the property<br />

department. That department will also have responsibility for other legal<br />

documents. It is essential that a receipt is always obtained for legal<br />

documents which leave the building.<br />

Special Computer <strong>Procedures</strong><br />

43. All Curia departments must:<br />

a) ensure that personal data held is secure.<br />

b) this includes physical security – doors which protect rooms which provide<br />

access to personal data should be kept locked.<br />

c) password protection should be used to control access to information and<br />

encryption if appropriate for very secure data.<br />

d) ensure proper arrangements for back up.<br />

5


e) train its staff on procedures including not using the personal data other than<br />

for use for the Parish.<br />

f) provide records as necessary so it is clear who has had access to personal data.<br />

44. Use <strong>of</strong> antivirus s<strong>of</strong>tware is compulsory.<br />

45. Physical controls are important and a server with sensitive data on it should be<br />

locked physically as should the back- up media.<br />

46. Installation <strong>of</strong> new s<strong>of</strong>tware will require the approval <strong>of</strong> the head <strong>of</strong><br />

department. All s<strong>of</strong>tware must, <strong>of</strong> course, be properly licensed.<br />

Miscellaneous<br />

47. Meeting notes should be circulated within 7 days <strong>of</strong> a meeting. It takes no<br />

longer to prepare them in good time as at a later date and preferable to have<br />

them while the meeting is fresh in the minds <strong>of</strong> those attending.<br />

48. While the <strong>Diocese</strong> is in principle happy to support those who wish to take part<br />

in national activities connected with the Church, this requires the prior<br />

approval <strong>of</strong> the Board. There are two aspects to this. The first is that the<br />

priority over an employee’s duties is the responsibility <strong>of</strong> the <strong>Diocese</strong>. The<br />

second is that there can be cost implications, for example for additional<br />

support. The approach should give details and the approval <strong>of</strong> the head <strong>of</strong> the<br />

relevant department will also be required.<br />

49. The <strong>Diocese</strong> is under a duty under certain circumstances to make a report to<br />

the Charity Commission if a serious incident takes place. In practice such a<br />

matter will be associated with a possible insurance claim and the advice <strong>of</strong> the<br />

<strong>Diocese</strong>’s insurers will be sought before a report is made.<br />

50. The Management and Finance Committee will consider requests for mobile<br />

phones to be provided to Curia employees who travel on Diocesan business<br />

widely.<br />

51. Loans may not be made to members <strong>of</strong> staff for cars or otherwise (policy<br />

confirmed by the Board 28 th September 2011).<br />

Adopted October 2011.<br />

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