INTERNAL CONTROL POLICY:
CONTROL ENVIRONMENT
46200 Department of Natural Resources (including North Georgia Mountains Authority, Sapelo Island Heritage Authority, and Georgia Natural Resources Foundation)
Prepared by: Denise Bowen
Phone: 404 463-2881
Email Address:
POLICY STATEMENT
The purpose of this policy is to establish the environment required to promote:
· Activities are carried out in an efficient and orderly manner to achieve DNR objectives
· Adherence to management policies
· The safeguard of DNR’s assets
· The accuracy and reliability of DNR records.
A control conscious environment is a critical element of internal control. It is an environment that supports ethical values and business practices. A control conscious environment conveys an attitude of honesty and accountability at all levels. It is a preventive control. Management is responsible for “setting the tone at the top” for their areas and encouraging the highest level of integrity and ethical behavior, as well as exhibiting leadership behavior that promotes internal control and accountability.
PROCEDURE
1. Management and the oversight body should demonstrate a commitment to integrity and ethical values.
1.1. Tone at the top
Tone at the top reflects the integrity and ethical values expected throughout the organization and is driven by management’s and the oversight body’s attitude, actions, and decisions which can influence the behavior of their staff.
o Expected behaviors are included in each employee’s Performance Management Plan.
o Managers are expected to act ethically and follow policies and procedures.
1.2 Standards of Conduct
Standards of conduct define and communicate expectations relating to allowable behavior for integrity and ethical values and reinforces that expected behavior.
o Employees must adhere to the State of Georgia’s Code of Ethics. The Code of Ethics Executive Order is posted on the DNR Intranet under Human Resources Directives which is available to all DNR employees.
o Employees must periodically certify that they have read and understand the policies and procedures.
o All department directives, policies and procedures are readily available on the DNR intranet for employees to access as needed.
o New employees are informed of the Standard Operating Procedures (SOP) during the New Employee Orientation and must sign an acknowledgement statement that the policies and procedures have been read and understood.
o Ensure that employees comply with the State of Georgia’s Conflict of Interest regulation and disclose potential conflicts of interest (such as employee or immediate family members’ ownership interest in entities doing business or proposing to do business with DNR).
1.3 Adherence to Standards of Conduct
Adherence to standards of conduct is a process to evaluate actual performance against the expected standards of conduct and address any differences in a timely manner.
o Management evaluates personnel twice a year, Mid-year and Annual, using the Performance Management process (PMP).
o Employee Discipline standards are outlined in the HR SOP # 024
o There is a formal fraud reporting link in the Resource Center section on the Team GA website which leads to the Office of the Inspector General.
o The DNR Board receives copies of the annual audit report completed by the Department of Audits which would detail any financial non-compliance discovered during the audit or review.
o The DNR Board meets periodically and makes decisions on various activities.
o Georgia does have some mechanisms in place to report non-compliance. There is a formal fraud reporting link in the Resource Center section on the Team GA website which leads to the Office of the Inspector General.
2. The oversight body oversees the internal control system.
2.1. Oversight Structure
The oversight body consists of the Board of Natural Resources, the Commissioner of Natural Resources, and the Environmental Protection Division Director.
o By law (O.C.G.A. § 12-2-24), the Board has the power to establish the general policies to be followed by the Department of Natural Resources that is administered by the Commissioner of Natural Resources. It also enacts rules under the Administrative Procedures Act that govern the work of the Department. The Board does not manage or administer the Department, which is the responsibility of the Commissioner of Natural Resources and the Environmental Protection Division Director. The Board does, pursuant to law and subject to the approval of the Governor, appoint the Commissioner of Natural Resources and the Director of the Environmental Protection Division. By its own policies, it approves the appointment of all other Division Directors. The Department consists of the Environmental Protection Division, the Coastal Resources Division, the Law Enforcement Division, the Wildlife Resources Division, the Parks, Recreation and Historic Sites Division, and the Historic Preservation Division.
The Board of Natural Resources consists of 19 citizens appointed by the Governor and confirmed by the Georgia Senate. There is one member from each of the 14 congressional districts of the state. There are four “at large” members and one additional member from one of the coastal counties (Chatham, Bryan, Liberty, McIntosh, Glynn, and Camden Counties). The members are appointed for seven-year terms, which are staggered so that there is a continuity of experienced members on the Board. Each January, the Board elects its officers, which consists of a Chairman, a Vice-Chairman, and a Secretary. The Board is responsible for setting rules and regulations ranging from air and water quality to hunting seasons and provides input into issues such as the agency’s budget recommendations and legislative initiatives.
The Board does not issue environmental permits or make regulatory decisions in environmental matters. Further, it is not legally empowered to alter or modify permits or licenses.
The Board does not have any power to affect or deal with matters concerning The Stone Mountain Memorial Association, the Jekyll Island State Park Authority, or the Lake Lanier Islands Development Authority. The Commissioner, or his designee, is by law a member of the governing boards of those authorities, but the Board of Natural Resources does not act on any of the activities of those separate authorities. Pursuant to an Army Corps of Engineers lease, the Department is the “landlord” for the Lake Lanier Islands Development Authority, but does not have a role in the day-to-day operation of the facility located at Lake Lanier.
The Board holds regular meetings approximately 10 times a year. The Board’s Chairman determines the agenda for each meeting. The printed agenda is posted on the Department’s website. The committees of the Board meet prior to the full Board meeting (usually the afternoon before the full Board meeting but occasionally the same day as the full Board meeting). These committees deal with specific areas of concern to the Board, such as environmental rules, land purchases, and fishing and hunting regulations. The committees make recommendations to the full Board at its meeting. It is the Board’s preference that members of the public present their concerns during the committee meetings. All Board Members in attendance are present for each committee meeting.
Please keep in mind that the Board does not make or review regulatory and permitting decisions of the Commissioner and the Division Directors and cannot modify or change those decisions.
2.2. Oversight for the Internal Control System
The Commissioner of Natural Resources and the Environmental Protection Division Director provides the oversight for the Internal Control System. Those individuals are responsible for the management and administration of the Agency.
The Commissioner, or his designee, and the EPD Director, or his designee, will review the internal control documentation.
2.3. Input for Correction of Deficiencies
The DNR Board members receives copies of the audit reports and are allowed comment regarding the findings. However, the Commissioner, or his designee, and the EPD Director, or his designee will provide input to management’s plans for correction of deficiencies.
3. Management establishes a structure, assigns responsibility, and delegates authority.
3.1. Organizational Structure
The DNR Management Organization Chart is posted on the DNR Intranet under Human Resources – Contacts. The chart shows the area of responsibility for Management.
3.2. Assignment of Responsibility and Delegation of Authority
PMP Process
o DNR adheres to the Georgia Performance Management Process by requiring all employees to have a Performance Plan and be evaluated by their manager twice a year. The process is posted on the DNR Intranet under Human Resources Performance Management.
o Performance Management is an ongoing process of establishing clear expectations and providing ongoing feedback and coaching to ensure those expectations are achieved. Performance management is a partnership between the employee and his/her manager. The process should be focused on the ongoing communication between the employee and his/her manager.
o The Performance Plan details the responsibilities of the employee. These performance expectations determine WHAT is to be accomplished, HOW it is to be accomplished, HOW and WHEN progress is to be measured and the TIMEFRAME in which the expectation is to be accomplished.
3.3. Documentation of the Internal Control System
The Internal Control System will be posted and maintained within the Internal Control Policy. This policy, along with all other DNR policies, will be posted on the DNR’s intranet where it will be available for all employees to reference.
Periodic reviews of the policy will be completed and updates will be made on an as needed basis.
It is important that adequate documentation is present when documenting internal controls. The policy consists, mainly, of narratives. Flow charts and pictures should be used when necessary to document processes.
4. Management demonstrates a commitment to recruit, develop, and retain competent individuals.
4.1. Expectations of Competence
New Hire Process
o To be considered for a position with DNR, applicants MUST meet the Minimum Qualifications listed in the DNR Vacancy Announcement. Applicants must be screened by the Division HR Representative/Manager to ensure they meet the Minimum Qualifications. Only those applicants that meet the Minimum Qualifications can be considered. The detailed “Filling a Vacant Full-time Position” SOP is located on the DNR intranet.
DOAS Human Resources Administration Division (DOAS HRA)
o HRA provides human resource guidance and leadership to State entities’ Human Resource personnel. Jobs are established at the State level to outline core responsibilities/duties and qualifications for jobs at similar levels with similar focus. They provide a foundation for managing career opportunities and pay in a consistent way across all State entities.
o Positions exist at the agency level to provide a way for agencies to describe the specific responsibilities and experience required for a job within the agency. Each agency “position” relates back to a “job” and a job code at the State level.
PMP Process
o Once employed, employees must work with their supervisors to complete their Performance Management Plan. Managers will review the employees with the Mid-Year and Annual Reviews to assess whether the employees are meeting expectations. The employee and manager will discuss the review and address any needs for improvement. The employee’s manager’s manager must also approve the evaluation. The entire process is detailed on the DNR intranet.
4.2. Recruitment, Development and Retention of Individuals
DNR provides the following to assist in reducing job turnover and creating a positive work environment:
Training
o Several training videos are available on the DNR intranet to reinforce standards of conduct such as:
o The Security Awareness Video is designed to make employees aware of this issue and to provide guidanceregarding keeping information secure.
o DNR Customer Service Training Video - Improving customer service involves making a commitment to learning what our customers’ needs and wants are, and developing action plans that implement customer friendly processes.
o The State of Georgia partners with the Carl Vinson Institute to offer State employees the opportunity to take their knowledge and leadership skills to the next level through the Institute's many state training programs, from professional development programs that cover a broad array of financial, legislative, and special topics, to certification programs in leadership and management.
o Criteria-Based Increase for completion of the State Financial Management Certificate Program.
DNR’s Leadership Academy
o Creates agency leaders who are exemplars of public service and share a common culture of collegiality and performance excellence.
4.3. Succession and Contingency Plans and Preparation
Plans to continue operations under turnover of state personnel or external third parties are critical to the continuance of the internal control system operating effectively.
o Documents are maintained on the Shared drive (S drive) to assure access by others if the need arises.
o DOAS HRA is responsible for creating enterprise-wide HR programs that help agencies attract, develop and retain a high-performing workforce.
5. Management evaluates performance and hold individuals accountable for their internal control responsibilities.
5.1. Enforcement of Accountability
Accountability is driven by the tone at the top and is essential to an effective internal control system otherwise personnel may be inclined to not perform their responsibilities.
o PMP Process
o The employees’ internal control responsibilities are detailed in the PMP.
o Managers manage performance through the ongoing communication between the employee and his/her manager. It may be necessary during the performance period for supervisors to meet with employees to discuss performance deficiency issues. Managers should use the Corrective Interview Form as documentation of the discussion. The form will be reviewed and approved by the Unit Director. The entire PMP process is detailed on the DNR intranet.
5.2. Consideration of Excessive Pressures
If personnel are under pressure, they may be tempted to “cut corners” or not bring problems forward to management.
o Workloads should be periodically evaluated by managers, and if possible, workloads should be reallocated.
o Vacant positions will be filled as the need arises. Division Directors must ensure that they have completed the Budget Approval for Announcement of Vacant Positions form and obtained approval from the Director of Administrative Services before proceeding with the hiring process.