Office of the Commissioner of Lobbying of Canada

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Audit and Evaluation Committee Annual Report 2024-25

Table of contents

Introduction

The Office of the Commissioner of Lobbying (OCL) is an independent Agent of Parliament. The Commissioner of Lobbying (Commissioner) is the deputy head of the organization. 

The Financial Administration Act requires that deputy heads establish an audit committee for their departments. The Treasury Board (TB) Policy on Internal Audit and Directive on Internal Audit expand on the legislation, requiring the establishment of a Departmental Audit Committee (DAC) that includes a majority of members from outside the federal public service (external members). 

Audit and evaluation are the subjects of separate policies in the federal government. However, the management of these functions is closely linked, particularly in small agencies. In the interest of efficiency, the Commissioner has established an Audit and Evaluation Committee (AEC) that in addition to responsibilities mandated for a DAC, has responsibilities related to evaluations that are carried out under the TB Policy on Results.

The Terms of Reference (TOR) for the AEC requires that the Committee prepare a report on its activities annually and submit it to the Commissioner. This document fulfils that requirement. 

Relevant legislation and related policies

The AEC TOR supports the application of the Financial Administration Act as well as related Treasury Board policies and Directives. Details, including application to OCL as an Agent of Parliament, are set out in the TOR. 

Accountability of the AEC

The sole accountability of the AEC is to the Commissioner. In this regard, members are accountable for the objectivity, quality and timeliness of their advice and for the performance of their contractual responsibilities.

Responsibilities of the AEC

The AEC is responsible for the following:

  • Providing objective advice and recommendations to the Commissioner regarding the sufficiency, quality and results of internal audit engagements that are related to the adequacy and functioning of the Office's frameworks and processes for risk management, control and governance.
  • Using a risk-based approach, reviewing all areas of management set out in the AEC TOR for committee review. These areas are listed in the next section of this document.
  • Providing advice and recommendations on matters for which the Commissioner, as accounting officer, is responsible, and on other related matters as needed or requested by the Commissioner.
  • To provide advice and recommendations to the Commissioner on the selection of areas for evaluation and on the scope, conduct and results of those evaluations. 

Areas of management for AEC review

The areas of management that fall within the scope of the AEC are:

  • Audits, Evaluations, and Advisory projects
  • Values and Ethics
  • Risk Management 
  • Management Control Framework, including ICFM/ICFR Assessments
  • Internal Audit Function 
  • Follow-up on Management Action Plans, including those made in response to audits by the Office of the Auditor General or the Public Service Commission
  • Financial Statements and Public Accounts Reporting 
  • Accountability Reporting

Membership

The Chair and other external members are selected by the Commissioner. The FY 2024-25 AEC consisted of:

Chair:

Michael Nelson, External member

Members:

Nancy Bélanger, Commissioner, Ex-Officio member

Basia Ruta, External member

Regular Non-member attendees

Carl St-Armand, Director of Finance and Chief Financial Officer (from October 2024 onward)

Catherine Blanchard, Consultant and between August 2024 and October 2024, Interim CFO

Meetings

Regular Meetings

During FY 2024-25 regular meetings of the Committee took place on:  

June 20, 2024

September 10, 2024

December 19, 2024

February 13, 2025

Ad Hoc Meetings

Ad hoc meetings and discussions between the Commissioner and AEC members are held throughout the FY as required. During FY 2024-25 an ad hoc meeting was held August 22, 2024 to discuss draft Financial Statements, Q1 QFR, the ICFM/ICFR 5-Year Plan, the assessment of internal control annex and an RBAEP update.

Other Meetings

External members held discussions between meetings, usually via Zoom or Microsoft Teams, with each other, the Commissioner, and/or the CAE/CFO as required. The external members felt that communications with the Commissioner and other staff as appropriate were timely and open. 

Summary of FY 2024-25 AEC meeting items

AEC Annual Plan

A draft Annual Plan for the AEC was prepared by the Chair and was discussed and approved by the AEC early in the FY. Items were included in the Plan for either a decision, advice to the Commissioner or for the information of external members. A version of this plan with a “Results” column forms part of this Report. That version of the plan was reviewed by the AEC at the June 2025 AEC Meeting in order to inform the AEC 2025-26 Annual Plan. 

Agendas for AEC meetings were planned by the Chair and the CAE/CFO in accordance with the Plan and were approved or amended at the start of each AEC meeting. Items discussed at regular and ad hoc meetings of the AEC in FY 2024-25 included the following:

Internal Audits, Evaluations, and related engagements

One audit (Procurement Process), which took place in FY 2023-24 was finalized.

Three ICFR assessments were carried out in FY 2024-25:

  • Entity Level Controls
  • OCL Delegation Instrument
  • Phase 1 of the Financial Planning, Budgeting and Forecasting Process

In addition, a consultant was engaged to carry out a gap analysis of OCL’s compliance with revised IIA Standards. 

Audit of the Procurement Process The objectives of this audit were:

  • To determine whether management practices, systems and controls result in goods and services being acquired in accordance with stated requirements; 
  • To verify appropriate delegated financial signing authorities were applied; 
  • To validate adherence to policies and guidelines; and 
  • To confirm that value for money was obtained.

This audit took place in FY 2023-24. The final results and the Management Response and Action Plan (MRAP) were presented to the Commissioner and to the AEC in FY 2024-25. One administrative error was noted during the audit and corrective action was taken. As of the date of this AEC Annual Report, all MRAP actions were complete.

ICFM/ICFR Assessment: Entity Level Controls (ELC)

This assessment was carried out by a consultant under the supervision of the CFO. Preliminary work to document the ELC had been done in 2023-24 by Samson. The results and MRAP for the 2024-25 work were presented to the Commissioner, EMC and the AEC in June, 2025. Overall, ELC were found to be working in a satisfactory manner. 

ICFM/ICFR Assessment: OCL Delegation Instrument

This assessment was carried out by a consultant under the supervision of the CFO. The Office of the Comptroller General (OCG) Self-Audit instrument was used to guide the work. The results and MRAP were presented to the AEC in June 2025 and will be reported in the 2025-26 AEC Annual Report.

ICFM/ICFR Assessment: Phase 1 of the Financial Planning, Budgeting and Forecasting Process

The purpose of this assessment was to review the new and (then) recently implemented changes to the OCL forecasting process and system functionality. The engagement was carried out by a consultant under the supervision of the CFO. The results were reported to the AEC in December 2024. Results indicated that benefits of the new approach were already being seen in terms of effort required, integrity and availability of forecast information. For example, the CFO could now quickly provide a snapshot of the current financial situation by pulling a report from the GX system.

Gap Analysis of OCL’s Compliance with IIA Standards

AEC members were briefed at the February 2025 meeting on the new IIA Global Internal Audit Standards. A consultant was engaged to carry out a gap analysis between the new standards and OCL’s current documentation and practices. The work was carried out in FY 2025-26 and will be reported in the 2025-26 AEC Annual Report.

OCL Fraud Report

A Report on Fraud and Fraud prevention practices at OCL was prepared in early 2025 and the results were presented to the AEC in June 2025. No fraud was found to have occurred in FY 2024-25 and OCL’s fraud prevention practices were deemed by the AEC to be effective and comprehensive. The Fraud report for FY 2025-26 will be presented to the AEC before the end of the FY.

Office of the Auditor General (OAG) Audit of 2023-24 Financial Statements

OCL Financial Statements are audited each year by the OAG. In August 2024, the AEC reviewed the draft Financial Statements with OCL and provided comments on the statements and the ICFR Annex.  On September 10, 2024, the OAG Audit Principal responsible for audit of the FY 2023-24 OCL Financial Statements presented the results of the audit to the Committee. He advised that the audit resulted in an unmodified opinion on the financial statements. A management letter was not issued. OAG officials confirmed that the audit had gone well and thanked officials of OCL and the financial services provider, CHRC, for their full cooperation. On the recommendation of the AEC, the Commissioner and the CFO signed the audited financial statements.

OCL Financial Situation/Quarterly Financial Reporting

The AEC reviewed and provided comments on Quarterly Financial Reports for Q1, Q2 and Q3. At every meeting or by email if between meetings, members were presented with a report and analysis by the CFO and Interim CFO on OCL’s financial situation. 

Departmental Plan (DP) and Departmental Results Report (DRR)

The AEC was provided with drafts of the 2024-25 DP and 2023-24 DRR for review in advance of their finalization. Comments were made and where required, discussions with the Commissioner and Interim CFO took place. 

Corporate Risk Profile (CRP) and Risk-Based Audit and Evaluation Plan (RBAEP)

OCL undertook a comprehensive review of the CRP in FY 2021-22. In FY 2024-25 an annual review of the CRP that was produced in 2022 was carried out by EMC. No changes to that CRP were found to be required. Adjustments to the RBAEP were made at the August ad hoc meeting.

Human Resources

At each meeting the Commissioner briefed the AEC on OCL HR matters. These included:

  • Values and Ethics The AEC was kept informed of activities by OCL management to promote adherence to Public Service and OCL values and ethics codes and practices and to ensure mental health wellness of staff. 
  • Staffing of vacant positions The AEC was briefed at every meeting on progress to fill vacant positions. Of particular interest to the AEC, a CFO/CAE was employed in October 2024.

Legal Issues

During the reporting period, there were no legal cases. Accordingly, there were no potential financial risks to OCL.

Ongoing Operational Matters

At regular meetings and when appropriate at ad hoc meetings, the AEC was informed of the status of operational matters that had arisen. Members appreciated this information, as it provided context for their advice to the Commissioner. Items included the following:

  • IT security and physical security
  • Performance of organizations that provide services to OCL through MOUs.
  • Central agency reporting burden and its impact on staff workload and budgets

Orientation and learning activities

In-Camera with Directors

In August 2024, members of the AEC held in-camera meetings separately with each of the Directors. The agenda of each meeting was left to the Directors. The purpose of the meetings was to inform AEC members about the activities of each Directorate. Members found these meetings to be very helpful and recommended to the Commissioner that they be held annually.

Departmental Audit Committee (DAC) Symposium

Members of the Committee attended the virtual DAC symposium that was hosted by the Office of the Comptroller General in November 2024. Sessions included useful information on cybersecurity, key risks that should be considered by DACs, the new IIA Internal Audit Standards. As well there were insightful remarks from the Comptroller General and other senior officials.

Assessment of OCL’s system of internal controls, risk management and governance processes

As described earlier in this report, the AEC met as a full committee with the Commissioner and OCL staff (primarily the CAE/CFO) during the year, including ad-hoc meetings and discussions as required. At these meetings, the functioning of internal controls, risk management and governance processes were discussed. In addition, the following steps were taken:

  • At each regular AEC meeting the Commissioner and CAE/CFO were asked whether there were any irregularities, including fraud or management override to disclose. There were none. In addition, all participants at each AEC meeting were asked to declare any conflicts of interest with agenda items.
  • During the reporting period, the Chair was in regular contact with the Commissioner and the CAE/CFO
  • As noted earlier in this Report, OCL’s Quarterly Financial Reports were reviewed by external members before they were published. Questions were asked to the CFO – and satisfactory answers were provided – at each of these reviews.
  • External members met in-camera with the OAG Principal responsible for the audit of OCL’s FY 2023-24 financial statements. It was noted that the audit did not identify any material misstatements or concerns that needed to be brought to the attention of the AEC. 

Assessment of the capacity and performance of the OCL’s internal audit and evaluation function

Given its small staff size and budget, the OCL does not have an in-house audit or evaluation team. Audits, evaluations, and related reviews are carried out by external consultants under the direction of the CAE and in consultation with the AEC.

To support this arrangement of carrying out the OCL’s audit and evaluation responsibilities: 

  • A multi-year risk-based audit and evaluation plan is prepared and amended as required.
  • The AEC meets on a regular and ad hoc basis and at these meetings. reviews current audit and evaluation findings and the progress of management action plans.
  • OAG undertakes an external audit of OCL Financial Statements every year.
  • OCL has always made sufficient funds available to carry out planned audits, evaluations and related engagements.

Support to the committee

The AEC received information and support from management to enable it to carry out its duties. In particular:

  • Meeting agendas were discussed with the Chair in advance of each regular meeting
  • Minutes were taken at regular meetings and were provided to AEC members for review in a timely manner
  • Arrangements for virtual meetings, when required, worked well, allowing for efficient and effective discussions despite the inability to meet in person

AEC forward agenda

Certain AEC activities take place each year, including the following:

  • Reviewing audit and evaluation reports, advisory projects and ICM/ICFR assessments  
  • Follow up of Management Responses and Action Plans 
  • Review of Quarterly Financial Reports and provision of comments where appropriate on the Departmental Plan and the Departmental Results Report
  • Review and recommendation of approval to the Commissioner of the Financial Statements, including the Statement of Management Responsibility and ICFM/ICFR Annex
  • Review of OCL’s financial situation updates and compliance results
  • Participating where appropriate in DAC community learning events 
  • Updates on OCG policy changes and other TBS and Government-wide tools 
  • Other activities, as set out in the AEC Annual Plan

In addition to these regular activities, the external members of the AEC will have a special interest in the following during FY 2025-26:

  • Planning and Implementation of a new CRP and RBAEP – A comprehensive review of the CRP will take place in FY 2025-26, followed by drafting and approval by the Commissioner of a new RBAEP. These instruments are at the core of the AEC mandate and we look forward to participating in their development and implementation.
  • The first full FY of work with the CFO/CAE – Under the leadership of Carl St-Amand, the CFO and CAE functions have been revitalized with a welcome rigour and discipline. We congratulate Mr. St-Amand and look forward to assisting him in all the areas set out in our mandate.
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