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ENVIRONMENTAL COMPLIANCE

Every USAID-funded programme is required to comply with the U.S. Government’s (USG’s) environmental regulations (often referred to as “Reg. 216”). Reg. 216 outlines the Environmental Impact Assessment (EIA)process that USAID has designed to identify potential effects —positive or negative— that a project or activity may have on the environment. The process is intended to prevent activities that are likely to cause significant environmental harm and to ensure that projects monitor and mitigate any negative effects on the environment. (For more information, see Title 22 of the Code of Federal Regulations and the administrative guidelines in Chapter 204 of USAID’s Automated Directives System.)

As the initial and foundational step of the environmental compliance process, USAID issues a pre-award analysis of potential activities that will be supported by the project to determine what environmental impacts a project’s activities may have in the course of implementation. This pre-award analysis is called an Initial Environmental Examination (IEE) and serves as the source document for development of the Environmental Review Form (ERF), which in turn serves to inform the development of the Environmental Mitigation and Monitoring Plan (EMMP). An adequately developed EMMP enables the programme to comply with all USAID Environmental Compliance requirements to minimise environmental hazards.

All USAID implementing partners, are required to review their planned activities to identify activities which may pose an environmental risk. This is performed using the Environmental Review Form or ERF, which is completed prior to the implementation of activities and submitted to USAID for approval. As part of the ERF, each activity is measured as part of the Screening result as “Very Low Risk”, “High-Risk” or “Moderate or unknown risk”.

The Environmental Mitigation and Monitoring Plan or EMMP identifies the activities requiring mitigation, describes the environmental threats posed by the programme activities as well as the mitigation measures planned to combat the threats and indicates the plan for monitoring of these mitigation measures. The plan includes indicators, frequency and responsibility for monitoring of the mitigation measures, and is submitted to USAID for approval.

Our Products and Services

SustainAbility Solutions specializes in working with organizations that are executing programmes funded by the US Government and other donors. As part of our Environmental Compliance service offering, we provide guidance to prime recipients of USAID funding and their sub-recipients on how to meet the USAID Environmental Compliance requirements.

As part of our environmental compliance service offering, we perform the following:

(a) Considering all requirements of Federal Regulations Part 216 (Environmental Procedures), we can assist organisations to review their planned activities against a pre-defined list of programme activities which may pose an environmental risk.

(b) Using the outcomes of step (a), we can help will develop the Environmental Mitigation and Monitoring Plan to identify the activities requiring mitigation, describe the environmental threats posed by the programme activities, the mitigation measures that will be implemented to manage the identified threats and the monitoring and reporting of mitigation measures.

(c) We can assist management to create an Environmental Policy to:

      • Identify potential negative environmental impacts of programme activities;
      • avoid, prevent, reduce, mitigate or offset those potential negative environmental impacts;
      • plan and budget for project activities to meet the above requirements; and
      • monitor and report on environmental impact mitigation.

 

RISK MANAGEMENT AND INTERNAL AUDIT

Risk Management

Non-governmental organisations (NGOs) and governments are faced with difficult decisions when trying to balance the needs of the communities they are trying to support with the necessity to manage possible harm to people, resources and reputation. In response to these risk, increasingly sophisticated risk management strategies and procedures are being adopted by a number of large, international NGOs. Risks faced by NGOs include critical areas such as security and safety in addition to traditional uncertainties faced by most organisations such as economic or political events, technology, financial, legal, reputational, operational, and information risks.

To navigate these uncertainties, organisations need a comprehensive strategy and a unified approach to risk management. Prudent, forward-looking risk management can help organisations improve their ability to achieve their objectives and maximize the value they bring to their communities.

Internal Audit

For USAID & HHS/CDC/NIH Recipients of US Government funding there are separate but similar pieces of legislation that deal with the requirements of internal controls. For USAID Recipients the Federal Register 2 CFR 200.303 requires that entities have an internal control system. "The non-Federal entity must:

Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." For HHS Recipients, the same requirement is called out in 45 CFR 75.303.

In addition to legislation requiring internal controls, an effective internal control system can also help organisation manage change in their operating environment, demands, risks and priorities. As programs and technology evolves, the organisation should evolve with it, should strive to continuously improve operations, risk management processes and the system of internal controls.

A competent and knowledgeable internal audit function is essential to ensure a healthy system of internal controls, strong corporate governance, effective and efficient risk management strategies, and robust compliance practices. As organisations recognize the value that an internal audit function can add, the demands on internal audit increases. Internal audit is often required to provide the proficiency and understanding needed to address a broad spectrum of risks.

Our Products and Services

Our risk management approaches are grounded in the real-world realities of business while also keeping the big picture in mind. We work with our clients to understand their operations, objectives, compliance requirements and the uncertainties they face.

This leads us to help our clients implement effective risk management strategies that enable them to achieve their goals. As part of these risk management strategies, we perform the following:

  • Organization-wide risk assessments.
  • Assist the recipient in ensuring Governance and organizational effectiveness.
  • Enterprise Risk Management (ERM) design and implementation and process and controls optimization.

As part of our internal audit service offering, we perform the following:

  • Outsourced internal audit services to help clients assess, remediate and improve control issues identified, while also assisting in identifying and managing risk across all areas of the business.
  • Help organizations achieve cost efficiencies in their existing internal audit functions through a co-sourcing agreement.
  • Bring thoughtful advice and a wide array of subject matter experience in complex areas related to NGOs globally, allowing clients to derive meaningful value from internal audit and other priority functions of the organization.