Monday, December 30, 2019

Working Women the Pros and Cons - 1283 Words

Stereotypes and histrionics do not last for long. With changing times, even Gender Stereotypes and Gender Based Histrionics are being forced to undergo a change. For centuries together, man has been the breadwinner of the family, sweating it out in the sun, dealing with unknown people and risking his life at times while the woman used to take care of the family and dealing mostly with known people in a closed and safe environment. Slowly the woman started moving out and started to work, however, the primary financial responsibility lay on the man and it was considered highly demeaning for the man if the woman earned money and the man had to depend on her. Poor woman was viewed as victim, being forced to work by the non-working man. Such†¦show more content†¦It has to be borne in mind that it’s a result oriented argument and not process oriented. The arguments in favor of shifting the primary financial responsibility from men to women reflect a major attitude shift which will not happen overnight and also the existing perverted social setups and decades old social and mental hardwiring will be a further impediment to the said attitude shift. Also, in order to empower men to break marriages (the way women are empowered currently with a volley of easily misusable laws at their disposal like arsenal in warfare), men will need laws in their favor which also won’t be a reality for some years. And this exercise of attitude shift would have already stabilized the institution of marriage rendering multiple, gender obsessed, and biased marital laws quintessentially ineffective, redundant, irrelevant and uncalled for. 5. Liberation of Men: Allowing women to work wherein they assume the role of the primary financial backbone of the family would liberate men from a role they have donned for millions of years and would allow them to live the kind of life they want to. A life that does not force the man to compromise his interests and hobbies just in order to enable himself as the primary breadwinner of the family. Men can concentrate on other areas and improve their emotional and psychological health which will ultimately move them closer to their experiential domain. 6.Show MoreRelatedProstitution: Should A Change Be Made? Essay775 Words   |  4 Pagescontroversial topics in todays modern society. There is a wide variety of different pros and cons related to this subject. With these pros and cons come supporters and critics of the concept of legalized prostitution. Those who are pro-prostitution believe legalization would do more bad than good, that it would solve more problems than it would create. Those who are against prostitution argue that it is immoral and degrading for women to sell themselves in the sex industry, and that it would be wrong to condoneRead MorePro Con Universal Health Care Essay602 Words   |  3 PagesI didn’t bulk this into a PRO and CON section per say. I felt like it would flow better and make more sense if I could play pro/con on each system. Should the US have some form of universal health care? I must say prior to watching this video I was very uneducated yet very judgmental on the issue of universal health care President Obama is trying to push right now. I remember reading not too long ago in the paper that by 2016 if a US citizen doesn’t carry insurance they will be penalized on theirRead MoreWhat is Prostitution?1838 Words   |  7 PagesSumerian empire was at its peak, roughly 1780 B.C.E., the oldest known written laws were created. Of the 282 laws etched in stone, six specific laws declared the rights of both women and children as prostitutes (Head). These heavily enforced laws gave protection to prostitutes, commonly referring to them as â€Å"devoted women† and â€Å"sisters of God†. Sex clients were named â€Å"brothers†, and were bound by law to protect and care for the prostitutes by â€Å"hold[ing] her field and garden, and giv[ing] her cornRead MoreStay At Home Mothers Or Work ing Mothers920 Words   |  4 PagesSTAY AT HOME MOTHERS OR WORKING MOTHERS 1. Introduction When a child is born into a family and one also have to look for the household expenses such as a mortgage, one needs to choose between either continuing working full time or staying at home. Statistics show that the number of working mothers is declining and trends are shifting to stay-at-home mothers. Employment figures for married mothers with children under the age of 6 have declined about 7% to 10% since the peak yearsRead MoreThere Are 25 Different Types Of Prostitution1553 Words   |  7 PagesProstitution. Street Prostitution is what we see every day and night in the USA. I see nothing wrong with prostitution cause it is a job. I see women out there trying to make a living for themselves and their kids. As long as the prostitution , clients are not hurting or causing any problems for others than let them be. I don’t think clients or the female working should be doing any kind of solicted on the streets, parks, or other public places. I feel that our USA government is never going to stop prostitutionRead MoreU.s. Federal Minimum Wage Essay1162 Words   |  5 Pageseconomic downturn so the impact of minimum wage was masked by other activities. Federal Minimum Wage is pressing topic and it is important to consider the pros and cons to raising it, to ask what people and how people are affected, and to look further into the microeconomic theoretical framework of wages surrounding the topic. An argument on the pro raising the minimum wage side is by raising the pay for low income household employees, they will be able to spend more. This situation helps the individualRead MoreInformative Speech : Plastic Surgery819 Words   |  4 PagesINFORMATIVE SPEECH OUTLINE Topic: Plastic Surgery Specific purpose: Allowing people to know the pros and cons of plastic surgery. Thesis: The cosmetic, issues, and beauty. We need to understand every possible outcome while considering plastic surgery. Introduction I. Attention-getter: Modern plastic surgeons can alter almost any aspect of physical appearance, from facial features to body shape. II. Credibility statement: According to the American Society of Plastic Surgeons, 14.6 million plasticRead MoreFree Weights vs Machines Essay660 Words   |  3 PagesFree weights and machines both have their pros and cons, the key is to figure out which one is right for you. I will explain some of the pros and cons for both types of equipment. I hope you make a wise decision, because not knowing the difference can cause serious injuries and setbacks in your training. Free weights and machines both have their pros and cons, the key is to figure out which one is right for you. When you enter most gyms today, the first things you usually see are weight stationsRead MoreAffirmative Action in the Workplace997 Words   |  4 PagesNegative and Positive Rebecca Mikell Human Resources BUS362 Affirmative action in this time and place is a very hard area to keep in place when it comes to keeping jobs even at work for the employees. Sometimes this type of equality in the working world can be good and sometimes it can be bad, but it depends on how it is used that really makes how a person can feel when it comes to this type of treatment of employees no matter what color or sex a person is during this time period. If youRead MoreThe Pros And Cons Of Cohabitation Before Marriage1563 Words   |  7 PagesThe Pros and Cons of Cohabitation before Marriage Introduction Social scientists have defined cohabitation as a situation where two adults, male and female live together in a relationship that is intimate and non-marital. The two make living arrangements without legal bounds to stay together before getting married. In most of the countries and in this case in the United States, cohabitation is a common feature among the American family life (Stokes Raley, n.d). It has become a typical pathway to

Saturday, December 21, 2019

Nike Cost of Capital - 711 Words

NIKE, INC. COST OF CAPITAL Context: Estimating Cost of Equity with different methods. Compute WACC Nike’s current price per share= $ 42.09 Question: Is it undervalued or overvalued to make buy /sell decision? Forecasts for Cash flows, Dividend growth, EPS estimates for NIKE are given. Interest rate #’s, Betas, Book values on debt and equity are given. Also historical performance #s are given. At 12% WACC Nike is overvalued and hence sell decision; At 11.17% correct valuation; WACC below 11.17% , undervaluation and hence buy decision. Exhibit 2 : The bottom table shows the sensitivity of share price to discount rate. The issue is which discount rate (WACC) to use to make the decision. Lower the discount rate, higher the†¦show more content†¦Tax Rate = 38% Hence After Tax Cost of Debt= 4.45% Methods for estimating Cost of Equity: (a) Dividend Discount Model (DDM) K= (D in year1/ Current P) + g g= 5.5% according to Moody’s; [What is the actual during 1997-2000. Very Low] Current Dividend = 0.48 P= $42.09 g= 5.5% K= 12.03% Assumptions of DDM--- Stable growth in revenues, and Dividend; Has Nike experienced stable growth? (b) Earnings Multiplier: Estimate next year’s earnings (Forecast of EPS) divided by price per share. Following this procedure K= 6.6% [ Forecast of EPS= (755.4/271.5); Price per share= 42.09 from Exhibit 2] This method does not consider the growth rate . If you follow Consensus Forecast ( Exhibit 4), K= 5.5%-- 6.34% This method ignores rate of growth in the future. If you add growth rate of revenue projected by the case writer g= 6.5%- 6% K= 13.1% ---12.6%. If you follow Moody’s g, then K= 12.1% The range is 12-13% with growth rate added.  © Yield plus Method for estimating K Cost of Debt for Nike= 7.17% on 25-yr. note. Add premium for equity of Nike. 5% Approx. Hence K = 12+% approx. (d) CAPM method. Risk-free rate= 5.74% Beta= 0.80 MRP= 5.90% K for Nike= 10.46%Show MoreRelatednike cost of capital1980 Words   |  8 PagesUV0010 NIKE, INC.: COST OF CAPITAL On July 5, 2001, Kimi Ford, a portfolio manager at NorthPoint Group, a mutual-fund management firm, pored over analysts’ write-ups of Nike, Inc., the athletic-shoe manufacturer. Nike’s share price had declined significantly from the beginning of the year. Ford was considering buying some shares for the fund she managed, the NorthPoint Large-Cap Fund, which invested mostly in Fortune 500 companies, with an emphasis on value investing. Its top holdings included ExxonMobilRead MoreNike Cost Of Capital1791 Words   |  8 PagesGraduate School of Business Administration University Version 2.0 of Virginia UVA-F-1353 Version 2.0 Nike, Inc.: Cost of Capital On July 5, 2001, Kimi Ford, a portfolio manager at NorthPoint Group, a mutual fund management firm, pored over analyst write-ups of Nike, Inc., the athletic shoe manufacturer. Nike’s share price had declined significantly from the start of the year. Kimi was considering buying some shares for the fund she managed, the NorthPoint Large-Cap Fund, which invested mostly inRead MoreNike Inc. - Cost of Capital1368 Words   |  6 Pagesit so important to estimate a firms cost of capital? The WACC (weighted average cost of capital) is a percentage figure resulting from a calculation method by which the adequate cost of capital of a firm is expressed. It considers the composition of a company’s funding, be it debt or equity. A corporation whose source of funding is equity by 100 percent will have a WACC equal to the cost of equity. By contrast, a levered company will have to reflect the cost of debt as well. The WACC takes theirRead MoreNike Cost of Capital Case2415 Words   |  10 Pagesmanagement firm. In July 2001, Ford considered buying shares of Nike, Inc., the well-known athletic shoe manufacturer. It would be prudent of Ford to base her assessment on Nike’s financial reports for 2001. Around the same time, Nike held an analysts’ meeting to disclose those financial results. They also addressed ways to revitalize the company, since share price was beginning to decline and revenues had plateaued at around $9 billion. Although Nike projected a rosy future, many analysts had mixed reactionsRead MoreNike Inc Cost of Capital2974 Words   |  12 PagesIntroduction Kimi Ford is a portfolio manager at NorthPoint Group, a mutual-fund management firm. She is evaluating Nike, Inc. (â€Å"Nike†) to potentially buy shares of their stock for the fund she manages, the NorthPoint Large-Cap Fund. This fund mostly invests in Fortune 500 companies, with an emphasis on value investing. This Fund has performed well over the last 18 months despite the decline in the stock market. Ford has done a significant amount of research through analysts’ reportsRead MoreEssay on Nike Cost of Capital Case1615 Words   |  7 PagesNIKE, INC.: COST OF CAPITAL On July 5, 2001, Kimi Ford, a portfolio manager at NorthPoint Group, a mutual-fund management firm, pored over analysts write-ups of Nike, Inc., the athletic-shoe manufacturer. Nikes share price had declined significantly from the beginning of the year. Ford was considering buying some shares for the fund she managed, the NorthPoint Large-Cap Fund, which invested mostly in Fortune 500 companies, with an emphasis on value investing. Its top holdings Read MoreEssay about Cost of Capital Nike974 Words   |  4 Pagesï » ¿Case Analysis of Nike, Inc.: Cost of Capital Apparently, the issue of Nike’s case is to control and check the calculation cost of capital done by Joanna Cohen who is the assistant of a portfolio manager at NorthPoint Group. But I am willing to tell you that it can be a complex case in which we can doubt about sensitivity analysis done by Kimi Ford (portfolio manager) because her assumptions such as Revenue Growth Rate, COGS / Sales,  S A / Sales, Current Assets / Sales, and Current LiabilityRead MoreCase 14 Nike: Cost of Capital Essay1143 Words   |  5 PagesNike, Inc.: Cost of Capital Case 14 A Case Brief Submitted to Submitted by In Partial Fulfillment of the Requirements for Date Submitted September 28, 2011 Summary This case highlights Kimi Ford, a portfolio manager with NorthPoint Group, a mutual-fund management firm. She managed the NorthPoint Large-Cap Fund, and in July of 2001, was looking at the possibility of taking a position in Nike for her fund. Nike stock had declined significantly over the previous year, and it appearedRead MoreNike Inc Cost of Capital Case Study917 Words   |  4 PagesNike Inc. Case Number 2 Nike Incorporated’s cost of capital is a vital element when addressing opportunities regarding top-line growth and operating performance. Weighted Average Costs of Capital (WACC) is an essential estimation that is needed in order to determine the amount of interest that will be paid for each additional dollar financed. This translates to be the minimum overall required rate of return that the firm will keep. We disagree with Johanna Cohen’s assessment of Nike due to twoRead MoreCase Analysis of Nike, Inc.: Cost of Capital731 Words   |  3 PagesApparently, the issue of Nike’s case is to control and check the calculation cost of capital done by Joanna Cohen who is the assistant of a portfolio manager at NorthPoint Group. But I am willing to tell you that it can be a complex case in which we can doubt about sensitivity analysis done by Kimi Ford (portfolio manager) too. Because her assumptions such as Revenue Growth Rate, COGS / Sales, S A / Sales, Current Assets / Sales, and Current Liability / Sales have been adopted from previous income

Friday, December 13, 2019

Term Paper on Controlling Proceess Free Essays

string(25) " and visits by the team\." Govt. Titumir College Term Paper On â€Å"Application of Controlling Process in Banking Sector in Bd. † Prepared By Supervised by Name: Md. We will write a custom essay sample on Term Paper on Controlling Proceess or any similar topic only for you Order Now Golap Mia Rita Khandoker Roll:181 Year: BBA (2nd year) Lecturer Session: 2011-12 Department of Management NU Roll No: 9613648 Govt. Titumir College Department of Management Dhaka. Govt. Titumir College, Dhaka. Date of Preparation: 26. 01. 2012 Letter of Transmittal To Lecturer Department of Management Govt. Titumir College, Dhaka. Sub: Letter of transmittal. Dear Sir. I would like to draw your kind attention that we are submitting our report about the topic of â€Å"Application of Controlling Process in Banking Sector in Bd. † We have tried our best to prepare this report which will fulfill our requirement. We believe all these new ideas from this â€Å"Term Paper† will help us in our future practical life. We will be highly grateful to your honor if you would kindly accept our â€Å"Term Paper† and obliged thereby. Thanking you Name: Golap Mia Year: BBA (2nd year) Session: 2011-12 NU Roll No: 9613648 Department of Management Govt. Titumir College,Dhaka. Table of contents and counts: ChapterTopic namePage count 1 Introduction4 2Conceptual issues5-6 3Database7 4Findings of study8-24 5Conclusion recommendations25-27 1. Internal Control Policy 1. 1) Overview Banking has a diversified and complex financial activity which is no longer limited within the geographic boundary of a country. Since its activity involves high risk, the issue of effective internal controls system, corporate governance, transparency, Accountability has become significant issues to ensure smooth performance of the banking industry throughout the world. In many banks internal control is identified With in ternal audit; the scope of internal control is not limited to audit work. It is an Integral part of the daily activity of a bank, which on its own merit identifies the risks associated with the process and adopts a measure to mitigate the same. Internal Audit on the other hand is a part of Internal Control system which reinforces the control system through regular review. According to an IMF publication Internal Control refers to the mechanism in place on a permanent basis to control the activities in an organization, both at a central and at a departmental divisional level. A key component of effective internal control is the operation of a solid accounting and information system. In Bangladesh analysis on the performances of the banks has pointed out that an effective internal control system could have contributed significantly in improving the performance of the Commercial banks if the control culture is brought in through policy guidelines and structural changes at these banks and procedural controls. (1. 2) Objective of Internal Control The primary objective of internal control system in a bank is to help the bank perform better through the use of its resources. Through internal control system bank identifies its weaknesses and takes appropriate measures to overcome the same. The main objectives of internal control are as follows: †¢ Efficiency and effectiveness of activities (performance objectives). †¢ Reliability, completeness and timelines of financial and management information (information objectives) †¢ Compliance with applicable laws and regulations (compliance objectives) . Accountability to the Board. (2) STANDARDS OF INTERNAL CONTROL Internal control policies set forth some standards that departments must establish and incorporate in an internal control structure: (I)Cover all activities: All financial institutions should develop internal controls which have coverage over all their functions, in general, and the key risk areas (KRA) in particular. Key Risk Areas include those core activities, the break down of which may render a financial institutions unable to meet its obligations; to its customers, regulators and the sponsors. Further, the risk originating from such activities is of the type that it may cause in systemic failure of other financial institutions. Examples of key risk areas are Liquidity Risk, Interest Rate Risk, Foreign Exchange Risk, Credit Risk, Operational Risk, etc. (II) Regular Feature: Control activities should be an integral part of the daily activities of a financial institutions / DFI in such a manner that it becomes ingrained in their ongoing processes rather than a year-end â€Å"fire drill† to satisfy documentation requests from auditors and supervisors. III) Separation of Duties: Duties should be divided so that no one person has complete control over a key function or activity. (IV) Authorization and Approval: All transactions should be authorized before recording and execution. (V) Custodial and Security Arrangements: Responsibility for custody of assets needs to be separated from the related record keeping. (VI) Review and Reconciliation: Records should be examined and reconciled to regularly determine that transactions are properly processed, approved and booked. VII) Physical Controls: Equipment, inventories, cash and other assets should be secured physically, counted periodically and compared with amounts shown on control records. (VIII) Training and Supervision: Qualified, well-trained and supervised employees always help ensure that control processes function properly. (IX) Documentation: Documented policies and procedures promote employee understanding of duties and help ensure continuity during employee absences or turnover. Therefore, policies and procedures (in the form of operations manuals and desk instructions) should exist in all financial institutions / DFI. X) Communication of importance of Internal Controls: Setting standards of professional integrity and work ethics and ensuring that all levels of personnel in their organization know the importance of internal controls and understand their role in the internal controls process an d be fully engaged in the process. (XI) Cost/Benefit: It is for the financial institutions to assess the costs associated with control processes commensurate with the expected benefits. The controlling process data are collected in a standardized way. To start, the controlling process team, with academic advisers, designs a questionnaire. The questionnaire uses a simple control case to ensure comparability across economies and over time—with assumptions about the legal form of the control, its size, its location and the nature of its operations. Questionnaires are administered through more than 28 local experts, including lawyers, banker, business consultants, accountants, freight forwarders, government officials and other professionals routinely administering or advising on legal and regulatory requirements. These experts have several rounds of interaction with the controlling process team, involving conference calls, written correspondence and visits by the team. You read "Term Paper on Controlling Proceess" in category "Essay examples" For Controlling process 2012 team members visited 4 economies to verify data and recruit respondents. The data from questionnaires are subjected to numerous rounds of verification, leading to revisions or expansions of the information collected. It is not a statistical survey, and the texts of the relevant laws and regulations are collected and answers checked for accuracy. The methodology is inexpensive and easily replicable, so data can be collected in a large sample of economies. Because standard assumptions are used in the data collection, comparisons and benchmarks are valid across economies. Finally, the data not only highlight the extent of specific regulatory obstacles to business but also identify their source and point to what might be reformed. Limits to what is measured The Controlling process methodology has 5 limitations that should be considered when interpreting the data. First, the collected data refer to businesses in the economy’s largest business city and may not be representative of regulation in other parts of the economy. To address this limitation, sub national Controlling process indicators were created (see the section on sub national controlling process indicators). Second, the data often focus on a specific business form—generally a commercial bank (or its legal equivalent) of a specified size—and may not be representative of the regulation on other businesses, for example, Islami Bank Third, transactions described in a standardized case scenario refer to a specific set of issues and may not represent the full set of issues a banking encounters. Fourth, the measures of time involve an element of judgment by the expert respondents. When sources indicate different estimates, the time indicators reported in Controlling process represent the median values of several responses given under the assumptions of the standardized case. Finally, the methodology assumes that a business has full information on what is required and does not waste time when completing procedures. In practice, completing a procedure may take longer if the business lacks information or is unable to follow up promptly. ELEMENTS OF A SOUND SYSTEM OF INTERNAL CONTROLS AND THE PRINCIPLES FOR ASSESSING THE SYSTEM (A)Elements of Internal Controls An effective internal control system consists of following interrelated components: 4. 1. Management oversight Control environment; 4. 2. Risk assessment management ; 4. 3. Control activities segregation of duties; 4. 4. Accounting, information communication; and 4. 5. Self assessment monitoring 4. 1 Control Environment: The environment in which internal control operates has an impact on the effectiveness of the control procedures. In fact it is institution’s control environment which embodies the principles of strong internal control. Besides giving structure to the internal control system, it provides iscipline and protocol. The success of control environment is judged according to the integrity, ethics, and competence of personnel; the organizational structure of the institution; oversight by the board of directors and senior management; management’s philosophy and operating style; attention and direction provided by the board of directors and its committees, es pecially the audit and risk management committees; personnel policies and practices and; external influences affecting operations and practices. In order for internal controls to be effective, an appropriate control environment should demonstrate following behaviors: Board of directors reviews policies and procedures periodically and ensures their compliance; Board of directors determines whether there is an audit and control system in place to periodically test and monitor compliance with internal control policies/procedures and to report to the board instances of noncompliance; Board of directors ensure independence of internal and external auditors such that internal audit directly reports to the audit committee of the board which is responsible to the board and that external auditor interacts with the said committee and presents management letter to the board directly; Board ensures that appropriate remedial action has been taken when instance of noncompliance are reported and that system has been improved to avoid recurring errors/mistakes; Management information systems provides adequate information to the board and that the board can have access to financial institutions records, if need arises; Board and management ensure communication of conduct or ethics policies and compliance thereof down the line within the organization; In short, a strong control environment and an effective internal audit function, can significantly complement specific control procedures. However, constitution of internal control environment at a point-of-time does not, by itself, ensure the effectiveness of the overall system of internal control but it is the continuous supervision by management to ensure if it is functioning as prescribed and is modified as appropriate. Many internal control failures that resulted in significant losses for financial institutions could have been substantially lessened or even avoided if the board and senior management of the organizations had established strong control cultures. Weak control cultures often had two common elements: First, senior management failed to emphasis the importance of a strong system of internal control through their words and actions, and most importantly, through the criteria used to determine compensation and promotion. Second, senior management failed to ensure that the organizational structure and managerial accountabilities were well-defined. For example, senior management failed to require adequate supervision of key decision makers and reporting of the nature and conduct of business activities in a timely manner. Senior management may weaken the control culture by promoting and rewarding managers who are successful in generating profits but fail to implement internal control policies or address problems identified by internal audit. Such actions send a message to others in the organization that internal control is considered secondary to other goals in the organization, and thus diminish the commitment to and quality of the control culture. 4. 2 Risk assessment and management: Every financial institutions activity involves some kind of risk and this creates a compulsion for the financial institutions that, as part of an internal control system, these risks are being identified, assessed and mitigated. From an internal control perspective, risk assessment involves; identification and evaluation of factors, both internal and external, that could adversely affect performance, information and compliance objectives of a financial institutions. Internal factors include: complexity, nature and size of operations; quality of personnel and employee turnover; objectives and goals, etc. External factors include: fluctuating economic conditions, changes in the industry and technological advances, degree of aggressiveness of the market and competition faced by the market participants, etc. It may be noted that it differs from the risk management process, which typically focuses more on the review of business strategies and plans developed to maximize the risk/reward trade-off within the different areas of the financial institutions. This risk identification should be done across the full spectrum of activities addressing both measurable and non-measurable aspects of risks. Second part of risk assessment – evaluation is done to determine which risks are controllable by the financial institutions and which are not. For those risks that are controllable, the financial institutions must assess whether to accept those risks or the extent to which it wishes to mitigate the risks through control procedures. For those risks that cannot be controlled, the financial institutions must decide, for the present, whether to these risks or to withdraw from or reduce the level of business activity concerned. But for the future, internal controls may need to be revised to appropriately address any new or previously uncontrolled risks. An effective risk assessment system allows the board and the management to plan for and respond to existing and emerging risks in the financial institutions activities. For that matter, such a system needs to demonstrate following: Board and management involve audit personnel or other internal control experts in the risk assessment and risk evaluation process. Those experts should be competent, knowledgeable, and provided with adequate resources. As the risks mutate with time and with changing circumstances, the board and the management, with due involvement of audit personnel, should appropriately evaluate the risks and consider control issues related to existing products and those relevant to new products and activities. Risk coverage in the form of insurance (that is risk transfer) or provisioning (contingency fund) in relation to the financial institutions risk profile is adequate. In the recent past, inadequate risk assessment has contributed to some organizations’ internal control problems and related losses. In some cases, the potential high yields associated with certain loans, investments, and derivative instruments distracted management from the need to thoroughly assess the risks associated with the transactions and devote sufficient resources to the continual monitoring and review of risk exposures. Losses have also been caused when management has failed to update the risk assessment process as the organization’s operating environment changed. For example, as more complex or sophisticated products within a business line are developed, internal controls may not be enhanced to address the more complex products. A second example involves entry into a new business activity without a full, objective assessment of the risks involved. Without this reassessment of risks, the system of internal control may not appropriately address the risks in the new business. 4. 3 Instituting Controls: Control activities are designed and implemented to address the risk that the financial institutions identified through the risk assessment process as described above. Control activities involve: (a) establishment of control policies and procedures, (b) verification that the control policies and procedures are being complied with. It is desired that control activities should involve all levels of personnel in the financial institutions, including senior management as well as front line personnel. Instituting an appropriate controls structure ensures the efficacy of an internal control system. This process involves: Existence and compliance of policies and procedures ensuring that decisions are made with appropriate approvals and authorizations for transactions and activities while assuring that exceptions to the policies are minimal and reported to the board and the top management; Timely reconciliation of accounts so that outstanding items, both on-and of balance-sheet, are resolved and cleared; Segregation of duties, existence of cross-checks, more-than-one-person authorization, dual controls, joint custody of keys, safeguards for access to and use of sensitive assets and records and forced leave policies, employees rotation systems are functioning in sensitive positions or risk-taking activities so that concerned employees do not have absolute control over areas; Building of such reporting lines within a business or functional area that independence of the control function is ensured; Accountability mechanism for the actions taken by the personnel as per their responsibilities and uthorities ; Structure and functioning of compliance framework through which the board and senior management establishes that compliance with applicable laws and regulations is ensured. In short, top level reviews; appropriate activity controls for different departments or divisions; physical controls; checking for compliance with exposure limits and follow-up on noncompliance; a system of approvals and authorizations; and, a system of verification and reconciliation are major constituents of the control activities. 4. 4 Accounting Information and Communication Systems An institution’s accounting, information, and communication systems ensure that risk-taking activities are within policy guidelines and that the systems are adequately tested and reviewed. For this the following is important to note; Effective internal control system requires that there is an effective reporting system of information that is relevant to decision making. The information should be reliable, timely accessible and provided in a consistent format. Information would have to include external market information about events and conditions that are relevant to decision making. Internal information include financial, operational and compliance data. There, should be appropriate committees within the organization which would evaluate data received through various information systems. This will ensure supply of correct and accurate information to the management. Internal information must cover all significant activities of the financial institutions. These systems including those that hold and use data in electronic form must be secure, monitored independently and supported by contingency arrangements. Most importantly the channels of communication must ensure that all s fully understand and adhere to policies and procedures effecting their duties and responsibilities and that other relevant information is reaching the appropriate personnel. An accounting system is adequate if it properly identifies, assembles, analyzes, classifies, records, and reports the institution’s transactions in accordance with prescribed formats and international best practices. The adequacy of information systems is determined by the type, number, and depth of reports it generates for operational, financial, managerial, and compliance-related activities and the access and authorization to information systems. An ideal information system covers the full range of its activities in such a manner that information remains understandable and useful for audit trail. Adequate information and effective communication are essential to the proper functioning of a system of internal control. From the financial institutions perspective, in order for information to be useful, it must be relevant, reliable, timely, accessible, and provided in a consistent format. Information includes internal financial, operational and compliance data, as well as external market information about events and conditions that are relevant to decision making. Internal information is part of a record-keeping process that should include established procedures for record retention. On the one hand, the adequacy of communication systems is established by the fact that it imparts significant information throughout the institution (from the top down and from the bottom up, and laterally), ensuring that personnel understand whatever has been communicated and on the other hand, communication system should ensure that significant information is imparted to external parties such as regulators, shareholders, and customers. Without effective communication, information is useless. Senior management of financial institutions needs to establish effective paths of communication in order to ensure that the necessary information is reaching the appropriate people. This information relates both to the operational policies and procedures of the financial institutions as well as information regarding the actual operational performance of the organization. The organizational structure of the financial institutions should facilitate a complete flow of information – upward, downward and across the organization. A structure that facilitates this flow ensures that information flows upward so that the board of directors and senior management are aware of the business risks and the operating performance of the financial institutions. Information flowing down through an organization ensures that the financial institutions objectives, strategies, and expectations, as well as its established policies and procedures, are communicated to lower level management and operations personnel. This communication is essential to achieve a unified effort by all financial institutions employees to meet the financial institutions objectives. Finally, communication across the organization is necessary to ensure that information that one division or department knows can be shared with other affected divisions or departments. 4. 5 Self-Assessment and Monitoring: An integral component of internal control system is self-assessment and monitoring which includes: Board and senior management oversight of the internal control, control reviews, and audit findings. Before starting full scale control review, the board and senior management should give their approval of the overall scope of the control review activities (e. g. , audit, loan review, etc. ). Frequent and comprehensive reporting of deviations to the board or board committee and senior management regarding sufficiency of details and timely presentation to allow for resolution and appropriate action. Adequate documentation of management responses to audit or other control review findings so that it can be tracked for adequate follow-up. Board or board committee or senior management review of the qualifications and independence of the personnel evaluating controls (e. g. , external auditors, internal auditors, or line managers). Financial institutions is a dynamic, rapidly evolving industry. Financial institutions must continually monitor and evaluate their internal control systems in light of changing internal and external conditions, and must enhance these systems as necessary to maintain their effectiveness. Monitoring the effectiveness of internal controls should be part of the daily operations of the financial institutions but also include separate periodic evaluations of the overall internal control process. The frequency of monitoring different activities of a financial institution should be determined by considering the risks involved and the frequency and nature of changes occurring in the operating environment. Ongoing monitoring activities can offer the advantage of quickly detecting and correcting deficiencies in the system of internal control. Such monitoring is most effective when the system of internal control is integrated into the operating environment and produces regular reports for review. Examples of ongoing monitoring include the review and approval of journal entries, and management review and approval of exception reports. (B) CONTROL PRINCIPLES So far we have discussed about the elements of a sound internal control. Now the question is how to assess the internal controls of a particular organization The following principles related to the basic elements of control should be borne in mind while assessing internal control: A. Management Oversight and Control Environment Principle 1: The board of directors should have responsibility for approving and periodically reviewing the overall business strategies and significant policies of the financial institutions; understanding the major risks run by the financial institutions, setting acceptable levels for these risks and ensuring that senior management takes the steps necessary to identify, measure, monitor and control these risks; approving the organizational structure; and ensuring that senior management is monitoring the effectiveness of the internal control system. The board of directors is ultimately responsible for ensuring that an adequate and effective system of internal controls is established and maintained. Principle 2: Senior management should have responsibility for implementing strategies and policies approved by the board; developing processes that identify, measure, monitor and control risks incurred by the financial institutions; maintaining an organizational Structured that clearly assigns responsibility, authority and reporting relationships; ensuring that delegated responsibilities are effectively carried out; setting appropriate internal control policies; and monitoring the adequacy and effectiveness of the internal control system. Principle 3: The board of directors and senior management are responsible for promoting high ethical and integrity standards, and for establishing a culture within the organization that emphasizes and demonstrates to all levels of personnel the importance of internal controls. All personnel at a financial institution sing organization need to understand their role in the internal controls process and be fully engaged in the process. B) Risk Recognition and Asses sment Principle 4: An effective internal control system requires that the material risks that could adversely affect the achievement of the financial institutions goals are being recognized and continually assessed. This assessment should cover all risks facing the financial institutions (that is, credit risk, country and transfer risk, market risk, interest rate risk, liquidity risk, operational risk, legal risk and reputation risk). Internal controls may need to be revised to appropriately address any new or previously uncontrolled risks. C) Control Activities and Segregation of Duties Principle 5: Control activities should be an integral part of the daily activities of a financial institution. An effective internal control system requires that an appropriate control structure be set up, with control activities defined at every business level. These should include: top level reviews; appropriate activity controls for different departments or divisions; physical controls; checking for compliance with exposure limits and follow-up on non-compliance; a system of approvals and authorizations; and, a system of verification and reconciliation. BIS Framework for Internal Control Systems in Financial institutions. Principle 6: An effective internal control system requires that there is appropriate segregation of duties and that personnel are not assigned conflicting responsibilities. Areas of potential conflicts of interest should be identified, minimized, and subject to careful, independent monitoring. D) Information and communication Principle: 7 An effective internal control system requires that there are adequate and comprehensive internal financial, operational and compliance data, as well as external market information about events and conditions that are relevant to decision making. Information should be reliable, timely, accessible, and provided in a consistent format. Principle 8: An effective internal control system requires that there are reliable information systems in place that cover all significant activities of the financial institutions. These systems, including those that hold and use data in an electronic form, must be secure, monitored independently and supported by adequate contingency arrangements. Principle 9: An effective internal control system requires effective channels of communication to ensure that all staff fully understand and adhere to policies and procedures affecting their duties and responsibilities and that other relevant information is reaching the appropriate personnel. (E) Monitoring Activities and Correcting Deficiencies Principle 10: The overall effectiveness of the financial institutions internal controls should be monitored on an ongoing basis. Monitoring of key risks should be part of the daily activities of the financial institutions as well as periodic evaluations by the business lines and internal audit. Principle 11: There should be an effective and comprehensive internal audit of the internal control system carried out by operationally independent, appropriately trained and competent staff. The internal audit function, as part of the monitoring of the system of internal controls, should report directly to the board of directors or its audit committee, and to senior management. Principle 12: Internal control deficiencies, whether identified by business line, internal audit, or other control personnel, should be reported in a timely manner to the appropriate management level and addressed promptly. Material internal control deficiencies should be reported to senior management and the board of directors. RESPONSIBILITIES OF THE PARTIES TO INTERNAL CONTROL The board of directors, senior management and other personnel of financial institutions are responsible for establishing, maintaining, and operating an appropriate internal control system on an ongoing basis. Board of Directors: The Board of Directors of all financial institutions is responsible for ensuring that an adequate and effective internal control system exists in their organization and that the senior management is maintaining and monitoring the performance of that system. Moreover, Board should periodically review the internal control systems and the significant findings. From the above it can be said that: The overall responsibility of setting acceptable level of risk, ensuring that the senior management committee take necessary steps to identify , measure , monitor and control these risks, establishing broad business strategy, significant policies and understanding significant risks of the company rests with the Board of Directors. Through the establishment of an ‘Audit Committee’ of the Board and ‘Internal Control Department’ the Board of Directors can monitor the effectiveness of internal control system. The internal as well as external audit reports will be sent to the board without any intervention of the management and ensure that the management takes timely and necessary actions as per the recommendations. The Board should have periodic review meetings with the senior management to discuss the effectiveness of the internal control system of the company and ensure that the management has taken appropriate actions as per the recommendations of the auditors and internal control. Management: Senior management of financial institutions have the responsibility for implementing strategies and policies as approved by the board in work place ; developing processes that identify, measure, monitor and control risks incurred by the financial institutions; maintaining an organizational structure that clearly assigns responsibility, authority and reporting relationships; ensuring that delegated responsibilities are effectively carried out; setting appropriate internal control policies; and monitoring the adequacy and effectiveness of the internal control system. Audit Committee of the Board: This Committee shall be formed by the Board of a company. The members of the Audit Committee shall be the selected Directors and the Managing Director. The Committee shall seat at least quarterly in a year. The Committee shall perform its work through an Internal Control Unit comprising of the Audit Inspection wing and Compliance wing. The Committee shall monitor the adequacy and effectiveness of the Internal Control System based on established policies and procedure. The Committee vide its two wing shall produce, on quarterly basis, a report on internal control system and significant findings and present it to the Board. The terms of reference of the Audit Committee, frequency of meeting , name of the members of the Committee shall be decided by the Board. External Auditor: The external auditors are not part of a financial institution and, therefore, are not part of its internal control system, yet they have an important impact on the quality of internal controls through their audit activities, including discussions with management and recommendations for improvement of internal controls. The external auditors provide important feedback on the effectiveness of the internal control system. The concept of external reporting on internal controls is well established and supported in the accounting literature. It is expected that external / statutory auditors shall review control systems for the impact they have on financial reporting and compliance with relevant policies, procedures, regulations and laws. The extent of attention given to the internal control system may vary by auditor and by financial institutions; however, it is generally expected that the auditor would identify significant weaknesses that exist at a financial institutions and report material weaknesses to management and the board in the form of an audit report/ management letter. As regards internal control and the role of external auditors the following things should be borne in mind by the auditors: External Auditors by dint of their independence from the management of the financial institutions can provide unbiased recommendation on the strength and weakness of the internal control system of the financial institutions. They can examine the records, transactions of the financial institutions and evaluate its accounting policy, disclosure policy and methods of financial estimation made by the financial institutions; this will allow the board and the management to have an independent overview on the overall control system of the financial institutions. It should be made obligatory on the part of the auditor to report to the Bangladesh Bank immediately if during the course of audit the auditor come across any facts which (1) might warrant qualification (2) endanger the entity audited and (3) indicate that the organization has severely infringed the regulatory provisions/guidelines. Regulator: The Financial Institutions Department(FID) of Bangladesh Bank is the direct supervisor of the financial institutions of Bangladesh. FID has many responsibilities to the Financial Institutions to protect interest of the public and to maintain financial discipline. The responsibilities of FID should be regulatory as well as advisory. In order to achieve the regulatory and supervisory objectives the Bangladesh Bank may introduce a comprehensive supervisory framework. Supervision can be of two types: a. On Site Supervision and b. Off Site Supervision Off site supervision would structurally be an in-house review and analysis based on various statutory returns and other statements. On site supervision includes physical visit and inspection by Bangladesh Bank Official ensuring regulatory compliance, evaluation of financial soundness, appraisal of management and identification of areas requiring corrections, review of asset quality , analysis of key financial indicators etc. As a regulator the Bangladesh Bank may introduce a system whereby the name of the Financial Institute which had not complied with the regulatory directions could be published in the newspapers. The Bank may make it compulsory for the NBFIs to do credit rating periodically. The Bank may introduce an on-line corporate memory/profile building process based on the observations generated from off-site surveillance system, , market intelligence, complaints, supervisory rating, record of compliance with directions and inspection findings. Bangladesh Bank may think of devising a suitable system for co-coordinating the Onsite inspection in tandem with the other regulatory authorities so that these NBFIs are subject to one shot examination by different regulatory authorities. The Bank may think of introducing a supervisory rating system for the NBFIs. Such a rating system should be designed on the basis of different levels of regulatory compliance, capital adequacy and rating assigned by the credit rating agencies. Based on the rating the NBFIs may be placed in three different supervisory â€Å"watch list† with low, medium and high risks. The rating assigned may primarily be the tool for triggering on-site inspection at various intervals. It shall play its role as a watch dog, review the compliances of the regulations and Circulars issued from time to time through periodic inspections and visits, issue new directives for the betterment of macro economy, take corrective actions, if necessary, provide necessary advises and clarifications to the NBFIS. During the course of regular inspection of financial institutions or when required, Financial institutions Department (FID)of Bangladesh Bank shall review the internal control system of any financial institutions in order to ensure compliance with these guidelines and all other relevant regulations and laws, circulars issued and enforced from time to time. In addition to that, the FID may review the report of the internal auditor of the financial institutions, assessment report of the management regarding effectiveness of the internal control and Boards’ endorsement thereof and the external/statutory auditors’ evaluation of the management regarding effectiveness of the internal control. In addition to the above the following points shall also apply to the regulators: For the financial institutions Bangladesh Bank is the primary regulator, who governs the activities of financial institutions. In addition Tax Authority, Registrar of Joint Stock Company Finance Ministry, Securities and Exchange Commission etc. are different types of Govt. bodies whose directives have significant impact of financial institutions business. The internal control system should always take into account the financial institutions internal processes to meet the regulatory requirement before conducting any operation. The internal control system of the financial institutions must be designed in a manner that the compliance with regulatory requirements is recognized in each activity of the financial institutions. The financial institutions must obtain regular information on regulatory changes and distribute among the concerned department, so that they can take necessary, action to adapt to such changes. The financial institutions must develop an effective communication process which will allow smooth distribution of relevant regulations among different departments and, personnel. IMPLEMENTATION OF INTERNAL CONTROLS: Various models/methodologies are used for the design and implementation of internal controls. However, it is the decision of the organizations to decide what model / strategy suit the size, nature, complexity, scope, risk exposure, etc. of their activities. Nevertheless, following is a brief summary of the key points that should be kept in mind while implementing the internal controls: Compare current practices to the internal control system and identify gaps. For an internal control expert, the most important consideration should be to evaluate the existing system of internal control in comparison to one defined by these guidelines and other international best practices. In this regard the first step is to identify what is and what is not covered by existing practices. Involve senior management, the audit committee, audit staff, other key players. The thought process and implementation of change should not be considered as â€Å"just other audit things. † Senior management and the audit committee must be perceived as driving the change and developing the control culture. Assess business environment, organization culture and key players. Before the process of change is set in, it would be necessary to understand: (1) what is changing in the culture (2) What is changing in the organization’s businesses and systems (3) Are there organizational initiatives which internal control system implementation could link to (4) What is the perception about the internal auditing function within the organization . Decide on implementation strategy. If the new practices can be designed to align with other organizational initiatives, or if senior management has taken ownership, this step is relatively easy. In any case, having a realistic implementation strategy is critical to success. Most implementers introduce the new ideas slowly and informally, building on personal relationships within the organization, listening as much as talking, and gradually building a consensus for change. Provide training to everyone involved. The most critical factor to the successful implementation of a control model is that everyone involved must understand internal control. Effective training depends heavily on how concepts are phrased and the concrete examples and exercises which make the concepts real to participants. Rectification Improvement: The findings of the internal audit department and that of other experts should be reported back to the relevant staff/office for rectification and improvement of the internal control system. Instituting an appropriate organization structure: Organization structure plays a vital role in establishing effective internal control system. It is the sometimes called the pictorial representation of the chain of command and the authority and supervision chain of an organization. The essence of the ideal organizational structure that will facilitate effectiveness of the internal control system is the segregation of duties. The financial institutions should, depending on the nature of business, structure, size, location of its branches and strength of its manpower try to establish an organizational structure which allow segregation of duties among its key functions such as marketing, operations, credit, financial administration etc. Up to which level this segregation will take place will depend on an individual financial institution. For instance a financial institution which has small branch operations at remote places of the country may not find it feasible to have such functional segregation of duties at that branch level. However at the higher level such segregation should exist and where possible this should be extended to the branch levels. In cases where such segregation is not possible, there must be certain monitoring mechanism which should be independently reviewed to ensure all policies and procedures are followed at the branch level. A detail guideline in this respect is given in the following section. Structure of the Internal Control Unit For an effective control system a separate organizational structure is also provided for this unit. The audit committee of the board shall be the contact point for the internal control unit. The unit should be adequately staffed so that it can perform its duty properly. In order to ensure that availability of efficient people with internal control the financial institutions will make it mandatory for all middle to senior management staff to spend at least two years with internal control on second meant. The head of internal control will report directly to the Audit Committee of the Board He will be responsible for the both compliance and control related tasks which include compliance with laws and regulation, audits and inspection, monitoring activities and risk assessment. The audit team of the internal control unit will perform periodic and special audit and inspection. The compliance unit will be responsible to ensure that financial institution complies with all regulatory requirement while conducting its business. They will maintain liaison with the regulators at all level and notify the other units regarding regulatory changes. Audit Committee of Board Audit Inspection Wing Inspector Compliance Wing Internal Control Unit Preparing various guidelines/manuals Each Financial institution should have a policy guideline in line with relevancy laws and internal documents in order to ensure an effective control over its process in various fields e. g. credit, human resources, finance accounts, treasury, audit, customer service etc. There should be a written policy guideline for each Department’s function which may be as follows. (a) Standard Operating Procedures -Credit Operations The main objective of lending money is to ensure maximum return of lend able fund. This manual should highlight the process starting from review of credit proposals, obligor risk rating, approving credit limit, disbursement of loans, monitoring of credit risk etc. Various types of MIS should be provided in order to have better control over assets of the financial institutions which can be generated if the system is in place. This manual should also contain role of Credit Admin. , Trade Finance, Reconciliations, Cash, Client’s service, Treasury, Back office etc. It should also reflect a clear guideline regarding Anti-Money Laundering activity in order to protect Financial institution’s interest. Credit Admin will be responsible for monitoring of limits and outstanding as per credit approval. This manual should cover the following areas inter alias: Risk classes, lending limits and credit authorities Investment policies Policies on financial other product services Lending guidelines Approval processes Documentations Securities and collaterals etc. Account Opening and closing Payment monitoring procedures Loan Administration Treasury Operations Anti-money Laundering procedures etc. (b) Finance Accounting Manual This manual should provide guidelines on financial activities regarding income and expenditure of a financial institution. They will look after if there is any exaggeration of expenditure where it is necessary to get control. This manual must incorporate a clause which shall make it mandatory to prepare and present an annual budget which shall contain target business, revenue, expenses, capital expenditures etc. This budget should be placed to the Board before starting of a new year and a periodic review of the actual achievement. Through this process it can also ensure the profitability of the financial institutions. The basic content of Finance Manuals are: Financial Accounting Policies Financial Accounting Financial Management Administration Fixed Assets Control Procurement of Goods and Services Audit and Internal Control General Clause Capital structure policies Treatment of Land, Building Equipment Capital Adequacy and Shareholders Equity Treatment of revenue and expenditures Income tax procedures Write-off procedures etc. (c) Treasury Manual This manual should include activities of fund transfer. Inter financial institutions fund management is one by them. The manual should include the guideline so that they may manage the financial institutions fund properly and profitably. There may be some idle fund in the financial institutions which is to be taken into account so as to make them invested in optimum profit seeking area. They should also ensure the security of the fund. If possible, they may look into international money market subject to the available opportunity in the money market arena. While framing a treasury manual the following things should be considered inter alias : Internal Items Liquidity Cost of fund Vs. yield from assets Policies Procedure Skill of staff etc. External Items Market Liquidity Risks including changes in Exchange Rates Changes in regulations etc. Investments Capital management etc. (d)Human Resource Policy Manual They will, at first, ensure the proper distribution of available human resources in the infrastructure of the financial institutions. It should also delineate the authority and responsibility of each employees . To find out the right person for setting up them at the right position is very crucial. The rewarding method of that department should be impartial. They will ensure staff welfare which will ultimately encourage people and create a healthy working atmosphere. This manual should contain inter alias the following: Recruitment policy Background checking policy Leave policy Compensation policy Reward and Recognition policy Termination retirement policy Promotion and increment policy Training guidelines Employees code of conduct etc. (e)Information Technology Manual This manual should contain the following areas: MIS to be generated Security of Data and programme Back up system Control mechanism of data and files Disaster recovery plan Networking Hardware maintenance Service agreements etc. Training Manpower backup Power backup system Data storage 20 EXAMINATION OR EVALUATION OF CONTROL As soon as the implementation of control is completed the next question is how to evaluate the effective functioning of this system. Evaluation may be done in the following ways: a. Verification of departmental function through Check List b. Reviewing the documentation relating to operational activities through a check list c. Preparing quarterly report and reviewing the same d. Risk analysis e. Audit Process communication of weakness Departmental Control Function Checklist (DCFCL) {Appendix 7. 1 to 7. 4} ) The guideline/procedure deals with matters relating to review/verifications of departmental functions to ensure that prescribed procedures are being followed by each department. b) All departments are required to check that prescribed controls are being observed and laid down procedures are not overlooked relaxed. c) Departmental Managers /Branch Managers will review the DCFCL to ensure that control functions are performed and documented in the control sheets (Appendix 1) at the prescribed frequencies i. e. Daily, weekly, monthly and quarterly. d) The DCFCL Checklist should be retained with the branch/departments for future inspection by Internal Control and Senior Management. Loan Documentation Checklist {Appendix 7. 6} The checklist deals with matters relating to security/other documentation for sanctioning credit facilities to ensure that prescribed documentation is being obtained to safe guard financial institutions interest in case of litigation. Copy of the loan documentation check list shall be sent to the lease/loans department for their use. Quarterly Operations Report {Appendix 7. 5} This guideline/procedure relates to reporting of operational functions of each branch/centre under the following heads on the enclosed format: i. Policies, Procedures and Controls ii. Protection of Valuables iii. Proofs/Verifications and Internal Checks iv. Personal and Supervision and v. Premises Management vi. Confirmation on Regulatory Compliance This report will be prepared by the Departmental/Branch Head . This will be prepared in duplicate copies one copy is to be dispatched to Internal Audit Department and another copy to the Audit Committee of the Board by 10th of the following month. The items which are not applicable for individual Department should be marked as N/A and no signature is required against the items marked as N/A. Any deviation in the quarterly operations report must be reported in a separate exception report or shall be marked specially in the report. Risk Analysis of Control Functions Individual items in the DCFCL need to be assigned a risk rating in terms of the following dimensions: a) Impact: Before taking into account the mitigation (i. e. Insurance) what is the impact of the lapse/omission. b) Probability: After taking into account of the mitigation what is the likelihood of the event occurring. To assist in this task, the following matrix (Table 1) can be used. However some financial institutions may consider customization of this matrix to suit their own risk profile. Where appropriate, additional details (e. g. financial values can be added). The key principle is that all financial institutions should be able to differentiate between different levels of risk in their own area of activity and then ensure appropriate controls are established. Scores should be plotted on the following table to determine a category of high, medium and low risk. Conclusion Recommendations The quality of internal control is (strong, satisfactory, weak). Note: Examiners should use appropriate tools (e. g. the CEO questionnaire,ICQs, and FDICIA internal control assertion work papers) and findings from all areas under examination, including the OCC’s review of the bank’s audit functions, when completing these objectives and steps. When substantive supervisory concerns about the adequ acy of internal control or the integrity of financial reporting controls exist after achieving the following objectives and performing the following steps, examiners should consider performing additional examination procedures, such as using ICQs,for those areas of concern. If, after completing those additional procedures, examiners remain concerned about internal control adequacy or financial reporting control integrity, they should perform appropriate verification procedures to confirm the existence and description of bank assets. As an alternative, examiners may require the bank to expand its own verification program to include the areas of weakness or deficiency; however, this alternative will be used only if management has demonstrated a capacity and willingness to address regulatory problems, if there are no concerns about management’s integrity, and if management has initiated timely corrective action in the past. Use of this alternative must result in timely resolution of each identified supervisory problem. If examiners use this alternative, supervisory follow-up must include a review of work papers in areas where the bank’s program was expanded The institution’s internal control is (strong, satisfactory, weak)Objective: Assess the overall effectiveness and adequacy of the institution’s internal control, communicate findings to the EIC, management, and the board of directors, and complete/update OCC work papers. 1. Prepare written conclusion summaries, discuss findings with t he Rican communicate findings to management. Conclusion summaries should address, as appropriate,†¢ Whether the internal control environment poses actual or potential undue risk to the institution’s financial performance for any of the following reasons:– The magnitude of control exceptions. – Financial effect of inaccurate, untimely, or improper transactions. – Previous losses from fraud. – Claims against insurance policies. – Employee turnover. – Other high operational losses. – Violations of laws or regulations and nonconformance with established internal policies and procedures related to the internal control functions. †¢ The adequacy of internal control policies, procedures, and programs to control and limit risk in bank operations. †¢ Whether bank personnel operate in conformance with established policies and, if not, the causes and consequences of nonconformance. The adequacy of information on the internal control function received by the board or it s committee†¢ Significant areas of control weakness identified by internal or external audits or other control reviews and the board’s and management’s progress in addressing those weaknesses. †¢ Audit or other control review report findings not acted upon by management, as well as any other concerns or recommendations resulting from the review of internal control functions. †¢ Recommended corrective actions, if applicable, and management’scommitments. 2. Determine how the quality of internal control affects the aggregate level and direction of OCC risk assessments. Examiners should refer to guidance provided under the OCC’s risk assessment programs for large and community banks. 3. Determine how the quality of internal control affects the bank’s composite and component CAMELS ratings. In coordination with examiners performing information system/technology, asset management, and fiduciary reviews, communicate the effect of control findings and conclusions on Uniform Rating System for Information Technology (URSIT), Uniform Interagency Trust Rating System (UITRS),and compliance ratings. 4. Determine, in consultation with the EIC, whether the risks identified are significant enough to merit bringing them to the board’s attention in the report of examination. If so, prepare items for inclusion under the heading â€Å"Matters Requiring Attention† (MRA). MRA comments should cover practices that (1)deviate from sound fundamental principles and are likely to result in financial deterioration if not addressed or (2) result in substantive noncompliance with laws or internal policies or processes. The examiner should provide details regarding:†¢ Factors contributing to the problem’s and management Consequences of inaction.. †¢ Management’s commitment to corrective action. †¢ The time frame for any corrective action and who is responsible further action. 5. Update any applicable schedule or table and include a comment on internal control in the report of examination. The comment should address†¢ Adequacy of internal control policies and processes, internal control and overall programs, personnel, and board oversight. †¢ Significant problems discerned by the auditors or other control reviewers that have not been corrected. †¢ Any deficiencies or concerns reviewed with management, any corrective actions recommended by examiners, and management commitments to corrective actions. 6. Prepare a memorandum and update OCC work programs with any information that will facilitate future examinations. Make recommendations about the scope of the next internal control review and determine whether internal control findings should change the scopes of other area reviews. 7. Update the OCC databases, including rating screens/schedules. How to cite Term Paper on Controlling Proceess, Essays

Thursday, December 5, 2019

Georgis Parasitology for Veterinarians Pageburst †MyAssignmenthelp.co

Question: Discuss about the Georgis Parasitology for Veterinarians Pageburst. Answer: Introduction: Vector borne diseases has several impacts and complications on human health. Recent studies and trends depicts Genetically Modified (GM) vector borne diseases that are carried by mosquitoes from one person to another often leading to an epidemic(Little, 2014). Incidence of vector borne diseases are high in tropical countries but are often carried to other countries as well through persons travelling or visiting those places. WHO estimates life threatening vector borne diseases affect almost 90% of the population in tropical countries. Zika recently carried by Aedes aegypti mosquito typical to Brazil had become a life threatening disease. Scientists have growing fear regarding GM mosquitoes and their effect that they could have on the environment through their gene transfer. Treatment for such GM male mosquito in lab grown conditions through sexual reproduction is also limited(Gubler, 2009). Thus, the fear put forward by GM mosquitoes and their scientific evidence to eradicate vector borne diseases as malaria, dengue, zika and chikungunya are immense. There are also concerns in regards to side effects that arise from morbidity and mortality from drugs of these diseases. A prominent example of side effects include birth defects from microcephaly that is used against Zika virus have impacted innumerous lives. Benefits needs to be analysed against the possible impacts from these various opponents of GM mosquitoes. As scientists are still puzzled and needs to devise methods for arriving at suitbale lab methods for eradicating such diseases. Impact on lives from such vector borne diseases are multifold in nature and continue to raise death rates globally. Reference Lists Gubler, D. J. 2009. Vector-borne diseases. Revue scientifique et technique, 583. Little, S. E. 2014. Vector-borne diseases. Georgis'parasitology For Veterinarians-Pageburst E-Book On Kno10: Georgis'parasitology For Veterinarians-Pageburst E-Book on Kno, 241.

Thursday, November 28, 2019

A good parent free essay sample

Experiences that Changed my Life None of my problems are deferent from other peoples problems. However, what I believe Is that some of them should not come too fast In anybody life; they can change lives completely for good or for bad. Furthermore, there are two things I consider that they came too fast in my life, but also there is one that came in the right moment. I am learning how to deal, live, and learn from them. In addition, I know each of them have a reason for why they happened. Also, those things have oaken me in the place I am right now.And, although two of them are tough hits In my life, I am glad they happened, because they made me see life differently now. In addition, those things are the ones that make me stronger each day. First it all, one of the tough hits happened to me at the age of 12 years old. We will write a custom essay sample on A good parent or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page This was the divorce of my mother and my father. To be honest, I was happy that they were separating from each other. I didnt want to see my father put a hand on my mother again. Furthermore, due to my father abuse against my mother, she wanted to commit suicide.She used to tell me that she would be happy if she was dead. Wish I never have heard those words because they hurt a lot when I remember them. In Dalton, I believe those words hit me harder than the scene of seeing my father hitting my mother. However, that divorce changed my life for better. It made me grow fast as a person, and it made me more mature. The second tough hit that came to my life fast was the death of my sister. As a result of her death, I fell in a big deep depression. I didnt want to eat or hang out with my friends. Furthermore, I was Just thinking in ending my life.And despite that death brought me sadness; It also brought me my mother. I say this because when my mother and my father got divorce. So my mother decided to came to united States. She wanted a better life for my siblings and l. Furthermore, she did what she promised, but she forgot something more important that money, which was her accompany and her love. In addition, I believe those things made my sister take her life easier. But this doesnt mean I am blaming my mother for my sisters death, this just mean that I wish thing would have been efferent.However, what I learned from this was to appreciate my life. It also taught me a really good value, which Is everything has a solution, except the death. Finally, despite I had those two bad experiences in my life, it came one that made me believe in second chances and second opportunities. That was when I met the love of my life. And to be honest, it was really hard for me to believe in men after what I experienced with my father. I didnt even believe in marriage. However, that great man made me believe In love again.I told him almost all my story, and he listened to me patiently. In Dalton, he supported me so much that I see life differently now. Also, I gave credit to my mother for always believe in me. Thank to them I have learned to take every problem as a challenge. A challenge a must overcome. Well, as you can see, there were tough things that came really fast in my life. However, I am thankful because I learned good things from them. Furthermore, people should remember that everybody has problems. But, you must take them as a challenge. For some of every single day.

Sunday, November 24, 2019

The Debate on Existence of the Human Soul According to Rene Descartes and Thomas Hobbes

The Debate on Existence of the Human Soul According to Rene Descartes and Thomas Hobbes Various philosophers have held diverse opinions about the existence of the human soul. Rene Descartes and Thomas Hobbes are among the philosophers who have contributed to this debate. In Principles, part 1, Descartes was of the opinion that there exists a human soul that is actually different from the body. To the philosopher, the soul and the body are two distinct substances, and one substance can be clearly and characteristically understood without considering the input of the other.Advertising We will write a custom research paper sample on The Debate on Existence of the Human Soul According to Rene Descartes and Thomas Hobbes specifically for you for only $16.05 $11/page Learn More The philosopher argued that God had the capacity to create a mental matter to exist all by itself without associating it to any other created matter (Skirry para. 42). In other words, the philosopher was arguing for the likelihood of human souls existing without physical bodie s. This philosophical thought can be used to explain frightening experiences reported in some communities of souls of dead people returning to haunt the living (Fowler 117). According to Descartes, the soul, also called the mind, is the thinking, non-extended matter while the body is the extended, physical and non-thinking substance. The philosopher clearly underlined the existence of the human soul in his arguments on diverse primitive notions. Descartes argued that the notion of the soul consist of all the perceptions of intelligence and the leanings of the human will, and is totally different from the notion of the body which concerns itself with issues of shape and motion (Skirry para 48; Fowler 169). Ultimately, the two are interrelated by the fact that the soul’s power moves the body while the body’s clout is known to cause sensations and obsessions in the soul. In this perspective, the body is made truly human only by the existence of the soul. To Descartes, the soul is the principle of life and is united to the whole body. Accordingly, the body can only be called a corpse without the existence of the soul. The body must act in unison with the soul for it to be referred as a living human body. His arguments are mostly used by contemporary Christians and Muslims to explain death as a process where the body and soul part ways. Thomas Hobbes categorically refuted the claim of an immaterial soul existing without considering the body. He was also opposed to the notion of free will. According to Hobbes, the key mistake â€Å"lies in moving from the observations that we can talk about ‘A’ and ‘B’, and can think about A without thinking about B, to the conclusion that A can exist without B existing† (Duncan para. 34). He was harshly critical of Aristotelians who argued that the human soul can exist by itself when separated from the human body. Hobbes argued that the human soul as described in the scripture signifie s a living creature or a physical body and soul jointly (Hobbes Gaskin XXVII).Advertising Looking for research paper on philosophy? Let's see if we can help you! Get your first paper with 15% OFF Learn More In this perspective, the philosopher affirms an analogous minimalism state about the existence of human souls. To him, if the soul is to be described at all, it can only be depicted as a bodily or corporeal spirit principally because only what is physical can move. In equal measure, the philosopher wondered if it was practically possible to disconnect the critical processes of our corporeal composition from the voluntary choices that ensue from the same faculties (Hobbes, Tuck Silverthorne 59). For example, is it possible to distinguish between the bodily desire of having sex and the mental faculties that triggers the desires? Hobbes believed this to be impractical. Being a materialist, Hobbes gave a purely mechanical explanation to the issue of soul in his concept of human existence. To him, there is no evidence whatsoever about the existence of an innate soul with some innate ideas (Hobbes, Tuck Silverthorne 179). In his mechanical explanation, the philosopher wondered how the non-material, spiritual soul could have the capacity to influence the corporeal organ of the brain or the body itself. According to Hobbes, the world revolved around two metaphysical components – matter and motion. He argued that life was a by product of the two components, and the human soul is only a combination of very subtle atoms. To Hobbes, the thinking process itself was composed of matter and motion. Hobbes was called a fascist for his mechanical explanations Duncan, S. Thomas Hobbes. In Stanford Encyclopedia of Philosophy. Retrieved from https://plato.stanford.edu/entries/hobbes/ Fowler, C.F. Descartes on the Human Soul: Philosophy and the Demands of Christian Doctrine. Springer. 1999. ISBN: 9780792354734 Hobbes, T., Gaskin, J.C.A. Leviat han. Oxford University Press. 1998. ISBN: 9780192834980Advertising We will write a custom research paper sample on The Debate on Existence of the Human Soul According to Rene Descartes and Thomas Hobbes specifically for you for only $16.05 $11/page Learn More Hobbes, T., Tuck, R., Silverthorne, M. On the Citizen. Cambridge University Press. 1998. ISBN: 9780521437806 Skirry, J. Descartes: An Overview. In The Internet Encyclopedia of Philosophy. Retrieved from https://www.iep.utm.edu/descarte/

Thursday, November 21, 2019

Curriculum and course design Research Paper Example | Topics and Well Written Essays - 2500 words

Curriculum and course design - Research Paper Example Too Much Data 7 3.1.1.What Could Be Done? 7 3.2. Too Many Exercises 8 3.2.1.What Could Be Done? 8 3.3. Availability of Answer Key 8 3.3.1.What Could Be Done? 8 3.4.Vocabulary List 8 3.4.1.What Could Be Done? 8 3.5.Daily Mini Diary 9 3.5.1.What Could Be Done? 9 4.Good Class Room Material 9 4.1. Informative and Authentic Reading Material 9 4.2. Computer and Internet 10 4.3.Worksheets and Quizzes 10 4.4.Creative Exercises 10 5. Conclusion 10 1. Introduction Robert Burshfield (author of the book: ‘Unlocking the English Language’) believes: "Any literate, educated person on the face of the globe is deprived, if he does not know English". English, being the language which is most widely published and spoken by more than 250 to 350 million non-native speakers, is now the prerequisite for anyone to consider himself as part of the new concept of globalization. Having an international recognition it is the most commonly spoken and used language as compared to any other colonial la nguages like French, Spanish, etc. In Asian countries like Indian, with variety of languages, English is commonly used as a source to unite them. As a medium of language in schools, court of law, newspaper and other electronic media, it is spoken and written in India, more than in England itself. Having more than 508 million speakers across the globe, English is not used as world language due to number of its speakers but because it is widely used as the foreign or secondary language outside its native areas. This importance of English as a global language, initiated the concept of making it an entire course added as a part to the curriculum of schools across the globe. The course dose not only provide value addition in form another language to the learner but also opens new broad horizons to better understanding of English culture, heritage and civilization. Taking into account the importance of English language, it is concluded that this course is very beneficial to students in se condary school, who do have some previous knowledge of English but lack the full command on it as a language. The benefits will be further highlighted in the report. There is room for some suggestions to further improve the course content which would also be covered as part of the report. 2. Usefulness of Course – A Critical Analysis 2.1. Global Benefits 2.1.1. Jobs and Career As we talked about the new emerging concept of globalization, in the above introductory paragraph, we identify that English language enjoys the recognition of an international language used as a common medium of communication among people from various cultures. The audience of the course is Secondary School entry level students, who in later stage will be required to relocate globally for the purpose of education, jobs, etc. When required to work in diverse cultures, having acquired a command on an international language, they will possess a value addition tool that will help them gain a competitive edg e in their field. They will be preferred over students who lack the element of a common language that is used across the organization in any multinational. 2.1.2. Education In the field of education, globally every university or high school offers courses having English as primary language for instructions. The students having good command in this language will feel more comfortable while selecting their course and will have a more diverse variety of options for selection.

Wednesday, November 20, 2019

Job Analysis Research Paper Example | Topics and Well Written Essays - 500 words

Job Analysis - Research Paper Example This job related behaviors are therefore considered as important in order to define who to hire and recruit. (Fine & Steven F, 1999) One of the key purposes of preparing job analysis is to define the job specifications as well as job descriptions which invariably allow an organization to identify the right kind of attributes required to perform the job. As such the future hiring and selection of the employees takes place based upon this. It is also critical to note that the job analysis is also used for later improvements in the overall job process besides defining the promotion and compensation criteria based upon the overall contents of the jobs. Job analysis is also used for the purpose of defining the training requirements of the employees and what kind of training and development programs need to be implemented in order to allow employees to move from one position to another. It is critical to note that organizations use job analysis as one of the legal defense tools in the courts. Job analysis can have serious legal implications if there are any elements of bias in the overall process of preparing job analysis for the employees. Since job analysis is also used in the supervisory evaluations as well as the rating of the employees, it is therefore important that all the criteria are effectively measured and carefully defined in order to reduce the chance of bias. Uniform Guidelines on employee selection specifically ask for the thorough job analysis as one of the selection criteria for hiring the employees. Further, validity studies are also required to be based upon careful review of the information about the job and the reviews should give due consideration to the job analysis. Americans with Disability Act specifically give more importance to the job analysis and strictly prohibits discrimination against persons with

Monday, November 18, 2019

Secluded Paradise in the Community Park Essay Example | Topics and Well Written Essays - 1000 words

Secluded Paradise in the Community Park - Essay Example Many other oaks look like them, but somehow I know these two more intimately. My special place pertains to that hollow under these trees, my own secluded paradise. These trees and all other elements in my sanctuary refresh my mind and body, help me reflect and think, and inflame my motivations in life. The pin oak leaves contain colors that simmer outwards and the breeze refreshes with greenery scents; these natural elements revitalize my drained mind and body. The demands of school, workplace, and social relationships can be grueling. They crisscross and cut me inside, for whenever I want to spread myself as thickly as possible, I only spread like a thin wafer across multiple activities. After exams and other tiring activities, I often rush to my special space. It provides a time to be one with nature, which can be exceptionally spiritual, for God made these beautiful trees to take care of exhausted people like me. Once I looked at their leaves and wanted to paint them. Not having m y painting tools with me, I memorized their details and what they made me feel. The warm colors of red, orange, and yellow clung to each other, tugging but not fully merging. No color wins or loses in these battles. Vermillion and red orange stained the leaves’ veins, while Naples yellow and other values of yellow flowed outwards to their edges. The red bled into the yellow, as if painting wet red on a wet yellow cotton rag paper. The burst of colors granted me a sense of peace. They reminded me of the wonderful hues in life that change and combine with many others. The breeze forgave my sudden intrusion in their space. It enveloped me with quick warm hugs from time to time. The greenery scents brushed my nose, while faraway laughter of teenagers, kids, and parents flew by. The bench felt cold and rough. It matched my feelings before I went there. Sitting and just staying there invoked positive emotions. My sanctuary breathed freshness into my mind and then slowly massaged my body. I felt as warm as these colors: red, yellow, and orange. I closed my eyes and I spilled over these colors and they spilled over me. I flowed with them, colors on top of colors, never completely mixing. My dark colors subsided. I felt yellow all over. Then, I felt red and orange. Such swirling emotions that fix my darkness instead of muddling my core calmed every bone, muscle, and emotion that previously strained. I flexed and knew my spirit’s weariness had been washed away, as I prepared for moments of reflection. Reflection comes easily under these trees because they take out the confusion and clear the mind. Modern life assaults humanity with so many interferences. Cellular phones ring with text messages or calls. Advertisements blare with large printed words and images. Buy this! You need this! You want this! Automobiles blast their own cacophony of noises. Beep, beep, screech, vroom! People dash in the streets, with no time to stop and speak to one another and purs ue long conversations. Children cry and kick their nannies, while both their parents work full-time. The nannies take the kicks and try to assuage their foster children. The pollution smells toxic with cigarette smoke and garbage heaps, and then perfumes and flower shops ridicule the latter, but not entirely defeating the former’s strength. I cannot help but want to flee this physical battering of my senses. And fled I did. Under my oaks simple scents, noises, sights,

Friday, November 15, 2019

Threats To Darkroom Workers

Threats To Darkroom Workers In terms of exposure to harmful chemicals, darkroom workers and hobbyists are often in a worse position than chemical workers. Darkroom workers, especially hobbyists, normally receive no training in the proper use of chemicals. Perhaps the main reason for this laxity is that photo chemicals are generally regarded as safe by the photographic community. Many photographers think that since most photo chemicals are diluted before use that the danger is low. But most photographers lack the knowledge necessary to make decisions about chemical exposure. This is shown in the lack of precautions that most photographers take; many immerse themselves, literally, in their solutions and advise their students to do the same. Contact with high levels of some photo chemicals can lead to acute problems such as burns, dermatitis, dizziness, vomiting, asphyxiation and central nervous system failure. Long-term, low-level exposure can result in chronic problems such as allergic reactions, headaches, depression, lung ailments and cancer. Individuals vary in their responses to chemicals; some are more susceptible to adverse reactions than others. Reactions also depend on the concentrations of the chemicals and the conditions under which they are used. The greatest danger to darkroom workers and hobbyists is through the inhalation of powders or vapors. Additionally, most chemicals in the darkroom are liquids in open trays or tanks which increases the chance for spills. Absorption through the skin is also easy if the photographer routinely handles chemical-covered films or prints. Most darkroom workers seem to rely on the rule of thumb if I can tolerate the odor, the ventilation is adequate. But there are dangers from inoffensive chemicals that arent offensive: what you cant smell CAN hurt you! www.subclub.org/darkroom/safety.htm INTRODUCTION The Trinidad and Tobago Police Service or TTPS is the law enforcement agency of Trinidad and Tobago and has been in operation for over 200 years. One of the specialization within the Service was the introduction of plain-clothes officers in 1862 to assist in crime fighting during. Included in this section is the Photography department one of the specialist section whose function is to photograph the scene of crimes, serious accidents and any material relating to the commission of a crime or incident. This includes the photographing of fingerprints and questioned documents in order to preserve evidence of value in the process of crime investigation or presentation before the courts. Persons coming into custody of the Police and those participating in riots and demonstrations are also photographed for evidence of infractions of the law. These highly trained officers gain their expertise by participating in courses provided by senior officers and at international agencies. http://www.ttps.gov.tt This study focuses on the Hazards associated with the photography department in the Trinidad and Tobago Police Service. No research was found on the topic in Trinidad and Tobago, however, international agencies, such as the University of Florida and Kodak International and other agencies have put systems in place to protect photographers, darkroom enthusiast and other persons from hazards that they may encounter in the dark rooms. Dark Rooms are an official part of the Trinidad and Tobago Police Service. They are used for developing images after processing scenes of crimes. The crime scene is photographed to record a vivid understanding of what the scene looked like and to record items of possible evidence. Crime scene photographs are normally taken in two groupings, overall views and items of evidence. http://www.feinc.net/cs-proc. Photographers play an important role in the entire Police service of Trinidad and Tobago. Most of the work is carried out in a Photographic Lab which is commonly called the Dark Room. The photographer, or more specifically the crime scene photographer, must know how to create an acceptable image that is capable of withstanding challenges in court. These photographs are seen by Judges, Magistrates, Lawyers and Jurors, fellow officers and witnesses. It is commonly said that a picture paints a thousand words, however, the technical aspects are unknown to our fellow Officers and other Civilian members. The Police photographer operates in the front line and the greatest feats are spent behind the scenes. Photographers are not taken seriously as everyone now owns a camera and play the role of amateur photographers; they are further disrespected by being called photo take outers. The assumption is they click away and wolla photograph appears like magic. There are numerous hazards associated with dark rooms and wet photography. Photography uses three basic chemicals in the processing of light sensitive materials. The first chemical is called Developer. The developer detects changes in the silver salt in the emulsion of the film or paper and turns those that have been struck by light into metallic silver. The second chemical is stop bath and is used to stop the developer from working any longer. Plain water is sometimes used for this step. The final chemical is fixer. It fixes the film or paper so that it is no longer sensitive to light. It dissolve the unexposed silver salt from the light sensitive emulsion while leaving the metalic silver in tact. Fixer will, however, bleach the metalic silver if left in contact for a long enough period of time. Finally wash the emulsion to remove the dissolved unexposed silver salt as well as all the fixer residue. Chemical Safety scphoto.com/html/chemicals.html It is noted that persons working in the department today and persons who have worked in the department before are not made aware of some of the chemical composition and their hazards. Long hours are spent in the lab with the pungent odour. The author will examine the systems in place to effectively minimize and control the inhalation of chemicals. 1.1 JUSTIFICATION/ RATIONALE This research provides for an investigation into the reasons, why the Police Photographers are not sensitized to the hazards and risks they are prone to daily. What the effects of the various hazards pose when they are not prepared; and what makes them most vulnerable than their peers. The photography department consists of Forty four persons inclucive of men and women Police officers whose services are shared throughout the country inclusive of Tobago Division. They are also called upon to provide service by the various branches and sections within the Police Service. The photography department of the Northern Division has an office space which measures 6 feet by 13 feet in size, and contains three office desks a refrigerator, two filing cabinets and one overhead cupboard. The dark room area measures 6 feet by 9 feet, has a counter 4 ½ feet in height by 3 feet in length, a sink, a photographic enlarger and two filing cabinets. The dark room is situated nearby (at the back of the office), this area is where the negatives and the printing of photographs are done. The close proximity of the dark room where chemicals are being used emits a pungent odour into the office area. The photographers work in the scented office over a long period of time as such, they are immune to the scent. A vague awareness becomes evident when other fellow officers visit the office and remarks are made about the scent to which the photographers are oblivious to. The hazards and risk of injuries can be attributed to a number of factors such as: Physical hazards Injury, as a result of accidental contact, spillage, or inhalation of darkroom chemicals. Slips, trips, and falls, cramped spaces, surfaces made slippery by spilled liquids and the movement of heavy tripod. Chemical hazards Exposure to a wide variety of photographic chemicals and their vapours and fumes Ergonomic Eye strain as a result of moving frequently from the dark or semi-dark into strong light. Increase in crimes means frequent visits to crime scenes which in turn, mean long hours in the dark room. The officers have not yet experienced any major disaster or injury, however; subtle changes have been noticed, mentioned and simply brushed aside. This study is appropriate to generate findings which should result in the implementation of Administrative and Engineering Controls. The Police Photography Department is of paramount importance, it is imperative that the working conditions and the health and safety of the photographers be looked into. Section 6 (1) (12) of the OSH Act 2006 it shall be the duty of every employer to ensure, so far as is reasonably practicable, the safety and health and welfare at work of all his employees. 1.2 AIMS To determine the risks and hazards associated with working in the Police Photography Laboratory in Trinidad and Tobago. 1.3 OBJECTIVES The objective of this study is to determine the following: To determine the level of volatile organic compounds present in the working environment. To determine the adverse health effects associated with exposure to the VOCs To ascertain whether there are systems in place to deal with exposures and disposal of chemicals. To determine compliance with OSH Act of No 3 of 2006 and compare other legislations and regulations. 1.4 METHODOLOGY A research was conducted in order to obtain the literature on the relevant title Questionnaires will be distributed within the department as it relates to the project Multirae tester will be used to measure the Voc, Ammonia Sulpha Dioxide and Oxygen levels. 2.0 LITERATURE REVIEW Volatile Organic Compounds (VOCs) Volatile organic compounds (VOCs) are emitted as gases from certain solids or liquids. VOCs include a variety of chemicals, some of which may have short- and long-term adverse health effects. Concentrations of many VOCs are consistently higher indoors (up to ten times higher) than outdoors. VOCs are emitted by a wide array of products numbering in the thousands. Examples include: paints and lacquers, paint strippers, cleaning supplies, pesticides, building materials and furnishings, office equipment such as copiers and printers, correction fluids and carbonless copy paper, graphics and craft materials including glues and adhesives, permanent markers, and photographic solutions. www.epa.gov/iaq/voc.html Toxicity of substances Toxicity is the ability of a substance to produce injury once it reaches a site on or in the body. The degree or harmful effect which a substance can have depends on the inherent harmful properties and the route and speed of entry in the body. Exposure may be short term (acute effect) or after long or repeated exposure (chronic effect). (Holt, St John Allan) What makes the substance toxic is the quantity, concentration, duration of exposure, the physical state of the material its affinity for human tissue and sensitivity to attack human tissue or organs. Routes of entry How do hazardous agents get into the body? The diagram of the human body below illustrates the effects when it is exposed to the outside world through a variety of surfaces. These include the skin, lungs, nose, mouth and the digestive, urinary, and genital tracts. Hazardous agents (e.g. chemicals and micro-organisms such as bacteria and viruses) can get into the body through any of these surfaces. The most common routes of entry are: (a) through the lungs (inhalation) (b) through the skin (absorption) (c) through the mouth (ingestion). http://actrav.itcilo.org/ http://actrav.itcilo.org/actrav-english/telearn/osh/body/body1.gif actrav.itcilo.org Health Effects There are several factors from Particulate Matter that contribute to adverse health effect s. According to World Health Organization (WHO) PM affects more people than any other pollutant. The major components of PM are sulfate, nitrates, ammonia, sodium chloride, carbon, mineral dust and water. It consists of a complex mixture of solid and liquid particles of organic and inorganic substances suspended in the air. The particles are identified according to their aerodynamic diameter, as either PM10 (particles with an aerodynamic diameter smaller than 10  µm) or PM2.5 (aerodynamic diameter smaller than 2.5  µm). The latter are more dangerous since, when inhaled, they may reach the peripheral regions of the bronchioles, and interfere with gas exchange inside the lungs. www.who.int/mediacentre/factsheets/fs313/en/index.html The Environmental Protection Agency discusses the ability of organic chemicals to cause health effects varies greatly from those that are highly toxic, to those with no known health effect. As with other pollutants, the extent and nature of the health effect will depend on many factors including level of exposure and length of time exposed. Eye and respiratory tract irritation, headaches, dizziness, visual disorders, and memory impairment are among the immediate symptoms that some people have experienced soon after exposure to some organicsà ¢Ã¢â€š ¬Ã‚ ¦ Many organic compounds are known to cause cancer in animals; some are suspected of causing, or are known to cause, cancer in humans. Eye, nose, and throat irritation; headaches, loss of coordination, nausea; damage to liver, kidney, and central nervous system. Key signs or symptoms associated with exposure to VOCs include conjunctival irritation, nose and throat discomfort, headache, allergic skin reaction, dyspnea, declines in seru m cholinesterase levels, nausea, emesis, epistaxis, fatigue, dizziness. http://www.epa.gov/iaq/voc.html body6.gif (328222 bytes) The following are recommend revised limits for the concentration of selected air pollutants on Particulate matter from WHO 2005 Air Quality Guidelines : Guideline values PM2.5 10 ÃŽÂ ¼g/m3 annual mean 25 ÃŽÂ ¼g/m3 24-hour mean PM10 20 ÃŽÂ ¼g/m3 annual mean 50 ÃŽÂ ¼g/m3 24-hour mean Ozone (O3) Guideline values O3 100 ÃŽÂ ¼g/m3 8-hour mean The previously recommended limit, which was fixed at 120 ÃŽÂ ¼g/m3 8-hour mean, has been reduced to 100 ÃŽÂ ¼g/m3 based on recent conclusive associations between daily mortality and ozone levels occurring at ozone concentrations below 120  µg/m3. Nitrogen dioxide (NO2) Guideline values NO2 40 ÃŽÂ ¼g/m3 annual mean 200 ÃŽÂ ¼g/m3 1-hour mean The current WHO guideline value of 40  µg/m3 (annual mean) set to protect the public from the health effects of gaseous NO2 remains unchanged from the level recommended in the previous AQGs. Sulfur dioxide (SO2) Guideline values SO2 20 ÃŽÂ ¼g/m3 24-hour mean 500 ÃŽÂ ¼g/m3 10-minute mean A SO2 concentration of 500  µg/m3 should not be exceeded over average periods of 10 minutes duration. Studies indicate that a proportion of people with asthma experience changes in pulmonary function and respiratory symptoms after periods of exposure to SO2 as short as 10 min EXPOSURE LIMITS The airborne exposure limits established by OSHA include: Permissible Exposure Limit (PEL): The allowable limit that is representative of a workers exposure, averaged over an 8-hour day. Short-term Exposure Limit (STEL): The allowable limit that is representative of a workers exposure, averaged over 15 minutes. ACGIH is a professional organization whose members work within the government or academia. This organization annually publishes a booklet entitled Threshold Limit Values (TLVs) for Chemical Substances and Physical Agents and Biological Exposure Indices (BEIs). ACGIH TLVs are exposure guidelines and do not have the effect of law. These values change in response to new data and are usually more rapidly updated than OSHA limits.The Threshold Limit Value (TLV) refers to airborne concentrations of substances and represents conditions under which it is believed that nearly all workers may be repeatedly exposed day after day without adverse health effects. The ACGIH TLVs include: Threshold Limit Value-Time- Weighted Average (TLV-TWA): The time-weighted average concentration for a normal 8-hour workday and a 40- hour work week, to which nearly all workers may be repeatedly exposed, day after day, without adverse effect. http://www.hse.gov.uk/coshh/oel.pdf Disposal of Chemicals According to the University of Florida disposal procedures of darkrooms photo chemicals with a pH of less than or equal to 2 or greater than or equal to 12.5 can be disposed of down the drain. Therefore, developer (alkaline) and stop bath (acidic) may be combined in a container (with good ventilation) to neutralize the solutions (pH 7) and make it nonhazardous. Then the combined solution can be disposed of down the sink. Fixers cannot be placed down the sink because of silver and other heavy metals content. These chemicals can be combined into one container and must have a Hazardous Waste Label on it. All unused, concentrated photographic materials must be handled by EHS as a hazardous waste. Photographers should never put any hazardous (or even potentially hazardous) materials down the drain without explicit permission According to Michael McCann the disposal of old or unused concentrated photographic chemical solutions, developer, stop baths, fixing baths, and other solutions should be treated as hazardous waste. To dispose of photographic wastes, label them with a hazardous waste tag, store them in secondary containment and submit a waste pickup request. Fixers contain some silver, which must be treated or recovered before it can be disposed of. There are two options available for recycling this material: Have a commercial company service your photographic needs (typically keeping your developer and fixer stocked and your waste removed), or have EHS collect the waste. EHS is permitted to treat. It is important to remember that when handling fixers, developer, or other photographic products that proper Personal Protective Equipment (PPE) be worn at all times. Kodak literature on Disposal of Processing Wastes guidelines are to direct discharge of untreated processing effluents to receiving water, or to surface drains or storm sewers that discharge directly to receiving waters, is not recommended or lawful. Septic tanks are biological systems, but are not recommended for disposal of photographic processing wastes. Septic tanks may not degrade wastes sufficiently. They are generally designed for small volumes, produce odorous products, cannot be installed in all locations, and may contaminate ground waters. Aerated lagoons have been used successfully by some processors to pre-treat their wastes to lower the oxygen demand before discharging them into a municipal treatment system. The University of Florida, Michael McCann and Kodak Literature in their research all agreed that photochemical disposal should be treated as hazardous waste. Hazardous waste or even potentially hazardous materials should never be poured down the drain. The University of Florida labels the hazardous waste and Contacts the Environmental Health and Safety Department who is permitted to treat hazardous waste. Both, The University of Florida and Michael McCann suggest the services of the EHS department. Kodak in their findings suggests an aerated lagoon. Hazard pictograms GHS The following labels are found on the packages of the fixer, and developers.For the labelling based on the Regulation (EC) No 1272/2008 (CLP Regulation, GHS), the following hazard pictograms have to be used according to the classification of the substances or preparations (mixtures). http://www.bag.admin.ch/anmeldestelle/00933/12871/index.html?lang=enimage=NHzLpZeg7t,lnp6I0NTU042l2Z6ln1ad1IZn4Z2qZpnO2Yuq2Z6gpJCKeIR_fWym162bpYbqjKbNpJyZlq7p Pictogram GHS05 Symbol: corrosion Hazard class and hazard category Corrosive to metals, hazard category 1 Skin corrosion, hazard categories 1A, 1B, 1C Serious eye damage, hazard category 1 http://www.bag.admin.ch/anmeldestelle/00933/12871/index.html?lang=enimage=NHzLpZeg7t,lnp6I0NTU042l2Z6ln1ad1IZn4Z2qZpnO2Yuq2Z6gpJCKeIR_g2ym162bpYbqjKbNpJyZlq7p Pictogram GHS06 Symbol: skull and crossbones Hazard class and hazard category http://www.bag.admin.ch/anmeldestelle/00933/12871/index.html?lang=enimage=NHzLpZeg7t,lnp6I0NTU042l2Z6ln1ad1IZn4Z2qZpnO2Yuq2Z6gpJCKeXt2g2ym162bpYbqjKbNpJyZlq7p Pictogram GHS09 Symbol: environment Hazard class and hazard category Hazardous to the aquatic environment Acute hazard category 1 Chronic hazard categories 1, 2 http://www.bag.admin.ch 3.0 Hierachy of Control Measures While systems of control should be as effective as it is practicable to make them, it is desirable to have some guide to which the efficiency of control can be related For each substance a figure of concentration in atmosphere is given. If this concentration is exceeded, further action is necessary to achieve satisfactory working conditions (MoL, 1960) Authors emphasis {pg 12} http://www.hse.gov.uk/coshh/oel.pdf The following control measures should be utilize to reduce exposure levels to (as low as reasonable practicable ) ALARP 3.1 1. Elimination The best way to control a hazard is to eliminate it and remove the danger. This can be done by changing a work process in a way that will get rid of a hazard; substituting a non-toxic chemical for a toxic substance; having workers perform tasks at ground level rather than working at heights. 2. Substitution The second best way to control a hazard is to substitute something else in its place that would be non-hazardous or less hazardous to workers. For example, a non-toxic (or less toxic) chemical could be substituted for a hazardous one. Isolation and enclosure of the process can be achieved by the use of physical barriers, or by relocation of processes and/or facilities. Local exhaust Ventilation (LEV is achieved by trapping the contaminant close to its source, and removing it directly by purpose built ventilation prior to its entry into the breathing zone of the operator or the atmosphere. LEV have four parts: Hood, Ducting, Air purifying device eg charcoal filtrs to prevent further pollution and Fans to move air through the system. The efficiency of LEV is affected by draughts capture hood design and dimensions, air velocityachieved and distance of capture point from source. General or Dilution Ventilation uses natural air movement through open doors or assisted ventilation by roof fans, or blowers to dilute the contaminant. It should only be considered if; There is a small quantity of contaminant. The contaminant is produced uniformly in the area. The contaminant material is of low toxicity. Housekeeping lessens the likelihood of accidental contact with a contaminant. It includes measures to anticipate and handle spillages and leaks of materials, and minimize quantities in open use. Reduced exposure time to a contaminant may be appropriate, provided that the possible harmful effect of the dose rate is taken into account, i.e high levels of exposure for short periods of time may be damaging. Training should emphasise the importance of using the control measures provided, and give an explanation of the nature of the hazard which may be present together with the precautions which individuals need to take. Personal Protective Equipment and Clothing may be used where it is possible to reduce the risk of injury sufficiently using the above control strategies. In that case suitable protective equipment must be used. http://t3.gstatic.com/images?q=tbn:ANd9GcT8a2gMMIEgccZST4or753KegN5brXR6Kenuv4NRA9Y2UnB8qXw designconsiderationsfig7.gif sebastiandarkroom.com http://ts1.mm.bing.net/th?id=I.4506898942199372pid=15.1 gloves give your hands protection lab coat to protect your clothing condrenrails.com According to literature from Hawaii art photography 2006 handout, which deals with safe and healthful Dark room practices, states that the hazards of the Developer and the Fixer are skin and eye irritants. They can cause allergic reaction and allergic sensitivity, especially hazardous in the stock mixing stage. The precautions given are: To mix stock solutions wear goggles, gloves and respirator or dust mask. Use gloves when mixing working solutions. Avoid skin contact with powders and solution. Concentrate is highly toxic by skin contact, inhalation or ingestion. Continued inhalation of working solution can cause severe sinusitis and bronchitis. http://www.hawaii.edu In the literature from Photographic Processing Hazards by Michael McCann, Ph.D., C.I.H states that the Developer solutions and powders are often highly alkaline, and glacial acetic acid, used in making the stop bath, is also corrosive by skin contact, inhalation and ingestion. Developer powders are highly toxic by inhalation and moderately toxic by skin contact, due to the alkali and developers themselves. The developers may cause methemoglobinemia, an acute anaemia resulting from converting the iron of haemoglobin into a form that cannot transport oxygen. Fatalities and severe poisonings have resulted from ingestion of concentrated developer solutions. The precautions are to use liquid chemistry whenever possible, rather than mixing developing powders. Pregnant women, in particular, should not be exposed to powdered developer. When mixing powdered developers, use a glove box (a cardboard box with glass or plexiglas top, and two holes in the sides for hands and arms), local exhaust ventilation, or wear a NIOSH-approved toxic dust respirator. In any case, there should be dilution ventilation (e.g. window exhaust fan) if no local exhaust ventilation is provided. Wear gloves, goggles and protective apron when mixing concentrated photo chemicals. An eyewash fo untain and emergency shower facilities should be available. Fixing baths contain sodium thiosulphate (hypo) as the fixing agent, and sodium sulphite and sodium bisulphite as a preservative. Fixing baths also may also contain alum (potassium aluminium sulphate) as a hardener and boric acid as a buffer. www.trueart.info/photography.htm The University of Florida literature on photographic materials; safety issues and procedures outlines that the developer solutions and powders are often highly alkaline and are moderately to highly toxic. They are also sources of the most common health problems in photography; skin disorders and allergies. Developers are skin and eye irritants and many are strong allergic sensitizers. Some common ingredients in developers are hydroquinone and sodium sulphite. Hydroquinone can cause de pigmentation and eye injury after five or more years of repeated exposure, it is also a mutagen. Sodium sulphite decomposes to produce sulphur dioxide (a toxic gas), when heated or allowed to stand for a long time in water or acid. Precautions are to ensure good ventilation of the darkroom. At least, 10 air changes per hour. Wear gloves and goggles. If a splash occurs, flush affected areas (15-20 minutes for eyes) immediately with water using an eyewash or safety shower. Solutions are should be covered when not in use to prevent evaporation or release of toxic vapours and gases. Fixer contains sodium thiosulphate, sodium sulphite and sodium bisulphite. It may also contain potassium aluminium sulphate as a hardener and boric acid as a buffer. Fixer solutions slowly release sulphur dioxide gas as they age. However, when these solutions are contaminated with acid from the stop bath, the gas sulphur dioxide is released at a more rapid rate. http://www.ehs.ufl.edu The use of Personal Protective Equipment is of great importance to the three institutions. The researchers found in their findings and agreed that the Developer and Fixer that is used in the photography lab are highly toxic and are skin and eye irritants. They all emphasize goggles and gloves, eye wash fountains and emergency showers. Michael McCann included the use of an apron while mixing chemicals. Michael McCann and the University of Florida go in-depth into the various chemical compositions and the danger they pose. There was a slight variation on the type of ventilation system which should be installed; however, the important factor here is that one should be place. He also added information on mixing powdered developers in a glove box. Precautions given are to wear goggles, gloves and respirator or dust mask. According to Kodak guidelines on the safe handling of processing chemicals, all chemicals have MSDS. MSDSs are provided for customers for all photographic processing chemicals which are clearly outlined: Photographic processing facilities are required by OSHA to have MSDSs for all hazardous chemicals. MSDSs provide detailed information about each product. Information included in MSDSs is outlined in the following categories: à ¢Ã¢â€š ¬Ã‚ ¢ chemical and manufacturer identification à ¢Ã¢â€š ¬Ã‚ ¢ composition/ingredients à ¢Ã¢â€š ¬Ã‚ ¢ hazard identification à ¢Ã¢â€š ¬Ã‚ ¢ first-aid measures à ¢Ã¢â€š ¬Ã‚ ¢ fire-fighting measures à ¢Ã¢â€š ¬Ã‚ ¢ accidental release measures à ¢Ã¢â€š ¬Ã‚ ¢ handling and storage The University of Florida outlines storage handling and general housekeeping which is documented in the updated MSDS on all chemicals used in the developing of film. These sheets must be kept in a binder and be available at all times. Keep the darkroom and other work areas uncluttered and eliminate trip hazards by not storing items on the floor. Wet and dry areas should be clearly separated. Liquid chemicals are to be stored off the floor, by compatibility and below shoulder height. Do not eat, smoke or drink in the storage room, darkroom or studio. The darkroom should be well ventilated with 10 to 20 air changes per hour. Using a pre-made liquid developer is safer than mixing powdered developers. If powdered chemicals must be mixed, do so in a fume hood or glove box. All darkrooms should have eyewash stations that connect to the water supply and use hands-free operation. Pregnant women, in particular, should not be exposed to powdered developer. Store concentrated acids and other co rrosive chemicals on low shelves so as to reduce the chance of face or eye damage in case of breakage and splashing. Kodak literature on photo chemicals safety, storage and general housekeeping alerts DO NOT store chemicals where you handle or store food. DO NOT eat, drink, or smoke in chemical-handling areas. Always wash your hands thoroughly after handling chemicals, especially before eating or drinking. Store corrosive materials away from any materials with which they may react, and away from other incompatible materials. See the stability and reactivity section on the MSDS for more information. The researcher found that The University of Florida notes that pregnant women, in particular, should not be exposed to powdered developers. Michael McCann also noted this hazard of the developer in his findi