Internal Audit Report on Human Resources Performance ...

1 Office of the Superintendent of Financial Institutions Internal Audit Report on Human Resources Performance management November 2010 Table of Contents 1. Background .. 3 2. Audit Objectives, Scope, Approach, and Criteria .. 3 3. Audit 4. management 6 5. Observations and Recommendations .. 7 Appendix A Performance management Control Criteria .. 13 Office of the Superintendent of Financial Institutions Canada A&CS Audit & Consulting Services A&CS Audit Report on HR Performance management 3 of 14 1. Background HR Performance management Process The Audit Committee and the Superintendent approved an Audit of OSFI s Human Resources Performance management for inclusion in Audit and Consulting Services Audit plan.

2 The HR division, who is the key guardian of the Performance management (PM) process, is responsible to provide guidance/support to OSFI management in managing and overseeing the process to ensure its quality, fairness, transparency, and consistency. As stated in the PM Guide, the Performance management (PM) process is a continuous cycle that helps managers and employees work together to establish work and Performance goals as well as monitor their progress towards achieving them, recognizing the need to identify corrective action, where necessary.

3 It is an opportunity for an employee to receive and provide feedback regarding his/her actual Performance and contributions relative to OSFI s Performance expectations as set out in the employee s Goal Commitment Document (GCD). At the same time, it should offer the employee and his/her manager an opportunity to discuss and plan for the employee s career development. There are four key steps in OSFI s Performance management cycle: o Setting Performance expectations. o Monitoring Performance throughout the year. o Reviewing Performance (including the mid-year review and the year-end appraisal).

4 O Rewarding Performance . The PM process is a very significant contributor to OSFI s mandate due to the importance, complexity, and difficulty to acquire, develop, and maintain the skills, experience, and knowledge required to conduct OSFI s activities, resulting in people risk being rated high on an inherent basis in many areas of OSFI. It supports OSFI s mandate by requiring management and staff to work in partnership to deliver solutions related to Performance and career development. 2. Audit Objectives, Scope, Approach, and Criteria Audit Objectives The purpose of this Audit was to provide assurance on the adequacy of design and operation of the management framework, practices and controls in place to manage and oversee OSFI s Performance management process to ensure its quality, fairness, transparency, and consistency.

5 Continued on next page Office of the Superintendent of Financial Institutions Canada A&CS Audit & Consulting Services A&CS Audit Report on HR Performance management 4 of 14 2. 2. Audit Objectives, Scope, Approach, and Criteria, Continued Audit Objectives (Cont) The objectives were to determine: o Whether policies and procedures addressing activities of the PM process were developed and formally documented. o Whether policies and procedures were adequate and were properly communicated to all OSFI managers and employees.

6 O Whether policies and procedures were applied as designed and consistently across the office. o Potential areas for improvement, as appropriate. Audit Approach The scope of the Audit included OSFI s Performance management process, including Performance planning, monitoring, and reviewing as well as management oversight controls around the Performance process. Excluded from the scope of this Audit : o Rewarding Performance In order to review a completed Performance cycle, our Audit work focused primarily on the Performance management activities carried out during the fiscal year 2008-2009.

7 However, recognizing that the process is evolving, A&CS found it necessary to review and understand information relating to events before and after the chosen Performance cycle, as appropriate. Audit Criteria The Audit Criteria listed in Appendix A was derived from the COSO Framework. The criteria was used to help us ascertain the extent to which existing management controls ensure that Performance management key inherent risks in the areas of Governance, Process, and People are properly mitigated and monitored. The Audit was conducted in accordance with The Institute of Internal Auditors International Standards for the Professional Practice of Internal Auditing, consistent with the Treasury Board Policy on Internal Audit .

8 Office of the Superintendent of Financial Institutions Canada A&CS Audit & Consulting Services A&CS Audit Report on HR Performance management 5 of 14 3. Audit Conclusion The Internal control framework over the Performance management process needs to be improved to ensure its quality, fairness, transparency, and consistency across the office. The main document governing Performance management (PM) at OSFI is the Performance management Guide ( Guide ). We noted that there is lack of clarity with regard to the force of this document ( is it mandatory or not) and with regard to its true nature ( is it a policy or just a guide).

9 The degree of complexity in the process and ambiguity in this Guide, outdated related documentation, as well as a lack of awareness of the Guide s content, all have led to variation in staff interpretation and inconsistencies in its application. Consequently, employee morale and the staff retention could be significantly impacted if PM-specific risks are not effectively managed. The recent employee survey indicated that while Performance management scored the second lowest on percent favourable (out of 6 survey categories), the overall survey results were positive with 92% of respondents agreeing they would recommend OSFI to others as a good place to work.

10 The PM process is a significant contributor to OSFI s mandate due to the importance, complexity, and difficulty to acquire, develop, and maintain the skills, experience, and knowledge required to conduct OSFI s activities. In recognition of the need to improve the HR- Performance management process and enhance its contribution to the organization, change initiatives were recently introduced at HR. These initiatives have positive aspects, notably enhancements to the Performance management form, including the addition of learning plans to the form and the process. While these changes are positive and directionally appropriate, there are several other areas that need to be addressed to ensure that HR PM meets its mandate more effectively.