Select Committee on European Union Fortieth Report


EUROPEAN COURT OF AUDITORS' ANNUAL REPORT (8630/06)

Letter from Ivan Lewis MP, Economic Secretary, HM Treasury to the Chairman

  I am pleased to enclose a copy of the UK's response to the European Court of Auditors' (ECA) Report on the 2004 EC Budget, including responses to specific UK references therein. These responses may be analysed in the Commission's follow-up report on the financial year 2004. As Member State's responses are not published in full, your committee may find it opportune to have the UK response in full at this stage.

31 January 2006

Annex A

CHAPTER 3: REVENUE

3.9-3.18  Electronic customs clearance

  The Court carried out an audit in the UK from 10-14 May 2004 and notified its findings in PF 1568 dated 16 December 2004. The UK replied on 16 March 2005. The Commission followed-up the findings in BUDG 58350 dated 22 September 2005. All the points are closed except 23-27 Temporary storage and 43-45 Supporting documents missing.

  On the first point, the ECA discovered 77 items for which no customs approved treatment or use had been assigned within the time limits. On the second point, the ECA discovered 7 entries for which no certificates of origin were held by Customs although preferential duty rates were applied. Customs are in the process of obtaining the additional information requested by the Commission and will reply when the details are available.

3.23  Amounts established but not vet made available to the Commission (B Accounts)

  The Court carried out an audit in the UK from 1-2 February 2005 and notified its findings in PF 1809 dated 15 July 2005. The UK replied on 5 September 2005 but we have not yet received any follow-up from the Commission.

  The B Accounts have been centralised and `significant progress has been made with the transfer of cases from the regional offices. The central site will monitor the progress of cases referred to the central Debt. Management Unit. A new form has been introduced to support cancellations. Procedures for write-offs will be reviewed to ensure that they are justified in terms of own resources and that accounting action is correct and timely. Systematic checks will be introduced on the aggregation and production of the B statements. These measures should produce improvements in the accuracy and completeness of the B Accounts.

CHAPTER 4: COMMON AGRICULTURAL POLICY

Paragraph 4.20—Footnote 13

  The ECA noted that the Commission intends to make corrections based on financial errors detected in a further four paying agencies (including Forestry Commission and SEERAD).

  The Commission's findings are in line with UK expectations which related to observations made by the Commission in respect of under-declared interest in the Forestry Commission's Table 104 and unidentified corrections for SEERAD's in the Table 105. Both observations relate to findings made by the Certifying Body during the 2004 Certification of Accounts.

  For the Forestry Commission, the necessary under-declared interest has already been repaid in the February 2005 Table 105: no further financial adjustment is required. The Commission have also formally reported that the appropriate corrective action has been taken to avoid any future reoccurrence and, as such, no additional corrections are to be proposed.

  For SEERAD, the Commission have proposed a financial correction of £497,130.69 (ie the full amount of the unidentified corrections included in the Table 105). As these cannot be identified against specific budget postes, it is not feasible to repay the Commission via the Table 104. The total sum concerned will therefore be included as a single correction in a future ad hoc compliance clearance decision. Again no additional systematic correction has been proposed.

CHAPTER 5: STRUCTURAL MEASURES

  Paragraph 5.21—The Scottish Executive accept that the MA and PA work within the same division and that they both report to the same head of division. However the procedures for processing claims and the IT system have been developed to ensure that we have a full and proper separation of both functions. The responsibilities of each area are, we believe, fully defined in the desk instructions. Access to IT functions that relate tgo MA are restricted to the staff working in the MA and the same is true of PA functions. Access rights can only be changed by an IT support team based outwith the division and only if authorised by branch heads.

  The Scottish Executive also accept that the unit responsible for the 5 per cent sample checks (VAC) operates within the same Division. Here again, they believe that the desk instructions can demonstrate a clear separation of the respective responsibilities. However, when the Division relocated to Glasgow in 2004 a conscious decision was taken that the VAC team should remain in Edinburgh close to internal audit services. Although they believe that the separation of duties was always clearly defined it was felt that locating the units in different locations would serve to further underline this separation and to stress the functional independence of the VAC team.

  The UK would agree with the Commission's reply for Western Scotland under paragraph 5.21, ie the view that "It considers that for the 1997-99 Western Scotland programme the structure met the minimum requirements laid down for the 1994-99 period".

  Paragraphs 5.22 to 5.30—further documentation has been produced by the government Office and they are updating internal systems and procedures including the findidngs of audits.

  Paragraph 5.24—The control environment applied to the programme was monitored by the independent bodies throughout the period and in particular during the closure process. The independent body considered the control environment to be sufficient to comply with the requirements of the regulations applying to this programme.

  Since the closure of the 94-99 programme significant enhancements have been made to the control checks being undertaken on expenditure. These have, in part, resulted from feedback from ECA and DG audits and from regular contact with the independent Article 15 body. As an example of the changes that we have made we have widened the number, scope and depth of checks pre-payment and introduced post payment checks on a sample of claims. In addition the timelines we have set for closure of the current problems will prevent the claiming of expenditure incurred after the final date allowed for this programme.

  Paragraphs 5.25 and 5.29—The Scottish Executive accept that the VAC Team only visited 11 out of 345 projects but would stress that they did achieve the 5 per cent target in compliance with Regulation 2064/97. However, this analysis does not provide the full picture. The 345 projects were sponsored in total by 90 applicants, the VAC Team carried out 11 visits to individual projects/applicants with a further eight project sponsors visited on other programmes, resulting in approximately 20 per cent of project applicants being the subject of an on-the-spot inspection.

  There appears to be some confusion regarding the risk analysis and the selection criteria for the West of Scotland visits. In the past the criteria was set at all projects over £1(m) but following a visit by the ECA (in March 2000) the system was reviewed and a more robust risk analysis was put in place. The 11 projects visited were all subject to the revised risk assessment and selected as appropriate. As is rightly pointed out, only projects over £1(m) were selected but this is clearly one of the restrictions of the risk analysis, especially when you are trying to ensure that foremost you achieve the 5 per cent target.

  The comment that there is a need to cover a wide range of projects and you will wish to note that risk analysis for the current programme has been rationalised and now ensure that we do get a more appropriate mix of types and size of operations.

  The Scottish Executive accept that the audit does not cover 100 per cent of the expenditure declared but would like to point out that although it does not carry out a sampling methodology, once it has been presented with a transaction listing it tries to cover as much of the expenditure as possible and select invoices covering all contracts and all aspects of the project. On the issue of extrapolation, it is not normal policy to count extrapolated expenditure on ERDF projects towards the 5 per cent target. However, if they do identify what would be described as a systemic error they would calculate the total error and record this in their Management Information System. This ineligible expenditure would be compared against the actual expenditure substantively checked and not the total project value when calculating the error rate.

  Paragraph 5.29—sample selection was based on a mixture of risk and randomly selected checks. The use of randomly selected checks allowed the calculation of more representative error rate. The sample selection process was then audited by the Article 8 body and found to be satisfactory. On the statements selected mention is made at Section 5 that "a number of Government Offices adopted a risk-based approach" and these were not included in the error rate calculation.

  In addition, the issue of sample selection should be taken in the context of the size of the programme and the level of sampling carried out. One of the programmes selected was a very small programme and 97 per cent of the programme spend was checked.

  Also on paragraph 5.29, we agree with the Commission's comment that "they had sufficient information to close the programme".

  5.3—The Scottish Executive accept that the closure process took longer than expected and a lot longer than desirable. This was caused, at least in part, by pressure of other work at MS level and at the Commission. In particular the diversion of resources to the operation of the 2000-006 Programmes meant that they were unable to respond to requests from the Commission as quickly as they would have liked. They have identified this as a risk to closing the current programmes. They have already started planning for closure of the 2000-06 programmes so that they can ensure that resources are sufficient to support an efficient closure process.

  Paragraph 5.36—a guidance note on the preparation of Article 9 declaration of expenditure to the Commission is being prepared. A new directive on procurement comes into effect in January 2006 and will form part of UK guidance to Government Offices and grant applicants. The UK recently issued a guidance note on the method to be used for the calculation of overhead expenditure to projects.

  Paragraph 5.36—The Scottish Executive provide guidance to all their project sponsors to ensure that the rules of state aid are fully respected. They consider charitable organisations engaged in economic activity to be analogous to public organisations, as they are neither profit making nor profit distributing. The areas targeted by such organisations are those which have suffered severe and persistent market failure and only public sector agencies are prepared to engage there. The services supplied by such organisations are vital when the market fails to address the often acute lack of economic prospects.

  In respect of comment 52 to paragraph 5.36, referring to expenditure incurred outside the eligible period; the eligible period aspect was a matter of discussion at an article 48 committee which gave a verbal instruction that quite probably was interpreted differently by Member States or even regions within Member States.

GENERAL POINTS

  As regards programme closures in general the closure process was hampered by the invoking of additional requirements for information above and beyond that contained in the Regulations. However, the UK have a working group to assess and try to resolve problems as quickly as possible in respect of the 1994-99 programmes. It is also working on a closure package development to aid in closing the 2000-06 programmes in a timely manner.

  The Office of the Deputy Prime Minister (ODPM) accepts the general feel of the report and agree that there are still areas within the management of the fund where improvements are necessary both at the managing/paying authority level and at project level. The Government Office for the North East together with ODPM and the Government Office Audit Team have responded to the findings of the ECA visit to the NE Objective 2 ERDF programme, agreeing to some of the findings and providing additional information (which was not readily available during the visit) to clarify others. There are other areas which are under discussion with officials from the Commission, including interpretation of the publicity requirements for retrospective projects.

  ODPM officials have formed similar views to the ECA from monitoring of the quarterly Article 10 reports on the 5 per cent inspection of total eligible expenditure. Further guidance notes have either been issued or are under preparation, to address the issues raised by the ECA.

  The UK would ask that consideration be given, especially to avoid confusion within the media circle, to the ECA report specifying that their findings were totally about the management of the fund and recommendations were being made for improvement, rather than anything fraudulent. The current style of reporting could be damaging for the programme, the region and affect the moral of those associated with it.

  Also the ECA should perhaps consider organising "open days" similar to those being organised by the Commission, or make a series of visits to Member States, explaining, for example, what they do and what they expect to see during their visits to Member States. This should include their interpretation of the regulations.

  With regard to audits in general, we would like to make the following observations. While we are in agreement with may of the aspects of a roadmap, we also feel that there should be some emphasis on simplyfying Regualtions rather than clarifying which seems to result in additional and more complicated Regulations. In addition, if audits could be set more as system and benefit cost audits rather than transaction tracing audits this would help enormously. Transaction tracing audits bring up specific timed errors, often of minor amounts, which they extrapolated can make it look as though the whole programme is in error. These errors are also often corrected later but this is not recognised when checks take place within a specific period.

CHAPTER 7: EXTERNAL ACTIONS

  We welcome the Court's recognition that External Actions performance continues to improve in line with the Court's recommendations in its 2003 report. It confirms other evidence that the Commission's reforms are feeding through into improved practices and procedures which has greatly improved the effectiveness of the EC. However, as in previous years, the report continues to raise concerns over recurrent weaknesses in the system. Steady progress is being made by both EuropeAid and ECHO but more need to be done to improve their internal controls, adherence to contracting procedures and strengthening their monitoring and reporting standards. These are essential elements in improving accountability and transparency. EuropeAid is managing billions of Euros and pursue relations with all kinds of partners across the globe, clear and strong procedures are paramount to making sure funds are used for their intended purposes. We share the Court's concern about getting the right level of staff and the appropriate skills mix in Delegations. We acknowledge the Commission is working on this but they are still understaffed compared to other donors, and at times lack the skills needed. On paragraphs 7.26 and 7.27 we would urge the Commission to continue action to introduce standardised documentation to tighten the implementing organisations terms of reference for external auditors in Delegations. Also, more needs to be done on the segregation of duties between the authorisation and accounting systems (7.31 and 7.32) to provide protection against misuse of funds. We welcome the Commissions actions to take corrective steps.

  With the transfer of the CARDS work to DG Enlargement, the need to look more carefully at implementing organisations are just as valid for Enlargement as for EuropeAid. We accept that much will have changed but the Court should consider, in future audits, looking at the effectiveness of expenditure in terms both of project delivery meeting project objectives and of project design reflecting Regulation goals.

CHAPTER 8: PRE-ACCESSION AID

  Overall, we support this report. It was reassuring to see that the general conclusion of the Court findings on the supervisory and control systems for all pre-accession instruments at the level of the Commission's central services and delegations and certifying authorities were basically sound, and worked in practice. However, paragraphs 8.9, 8.31 and 8.32 show the inconsistency in the decision to substantially increase assistance to Bulgaria and Romania for 2004 when there were reservations about the capacity to manage and implement increasing amounts of aid. According to the Commission this was a political decision and the increase is dependent on improvements. We would like to see more on how the Commission plan to help with improvements. Extended Decentralised Implementation System (EDIS) is a clear test for progress in this area. A significant part of Phare's objectives are to increase administrative capacity in preparation for Structural funds post-accession, and a key part of this is the implementation of EDIS in candidate countries to allow them to implement their own structural and regional funds post-accession. Achievement of EDIS provides a clear benchmark for the efficiency of candidate countries in handling funds. Although of the 2004 accession countries, only Hungary achieved EDIS before accession, paragraph 8.18 notes that Romania and Bulgaria aim to have EDIS in place by 2006.

EDF

  We note that the Court has issued a Statement of Assurance on Activities funded by EDFs 6-9 but that there are still a number of areas for improvements. We were concerned at the Court's report on the lack of key information and explanations in the Commission's financial reporting, the continuing slow pace of Stabex clearance, the persistent weaknesses in the supervisory and control systems and the non-compliance with the Court's definition of legality and regularity. Progress on follow up activities on observations from previous reports has also been slow. However, we note that the Commission does not disagree with any of the Court's findings, and we welcome actions being taken to correct some of these concerns, such as improvements in the Stabex inventory and identification of recoverable amounts. We would expect to see marked improvements in the Court's report for 2005. The devolution of responsibilities to Delegations should further improve the Commission's capacity to fully address the Court's concerns. There is evidence that this is already happening.

UK RESPONSE TO THE EUROPEAN COURT OF AUDITORS' REPORT ON THE 2004 BUDGET

ERRORS NOTED BY THE COURT IN THE STATEMENT OF ASSURANCE:

SUBSTANTIVE ERRORS



DAS error reference
Nature of error
UK Reply
Remedial measures taken

04.P.R2.DOR 2107-01
04.P.R2 DOR.2107-02
04.P.R2.DOR.2107-05
04.P.R2.DOR.2107-06
04.P.R2.DOR.2107-07
04.P.R2.DOR.2107-08
Error In sample: Legality and Regularity UK Reply of 9 August 2005The UK has accepted a number of the errors and put remedial meausres in place. The ECA has agreed with some of the observations made by the UK and withdrawn some of its opinions.
04.P.R2.DOR 2205.01
04.P.R2.DOR 2205.02
04.P.R2.DOR 2205.05
04.P.R2.DOR 2205.06
04.P.R2.DOR 2205.07
04.P.R2.DOR 2205.09
04.P.R2.DOR 2205.11
04.P.R2.DOR 2205.12
04.P.R2.DOR 2205.13
04.P.R2.DOR 2205.14
04.P.R2.DOR 2205.15
04.P.R2.DOR 2205.17
04.P.R2.DOR 2205.19
Error In sample: Legality and Regularity Scottish Executive Rely of 11 August 2005The Scottish Executive has accepted a number of the errors and put remedial measures in place, They have also given explanations as to why they disagree with other findings. The ECA has agreed with some of the observations made by the Scottish Executive and withdrawn some of its opinions.
04.P.RI.FIA.1081
04.P.RI.FIA.1084
04.P.R1.FIA.1085
04.P.R1.FIA.1086
04:P.RI.FIA.1087
04.P.RI.FIA.1133
Error In sample: Legality and Regularity Reply from Derek Lee UK Co-Ordinating Body, dated 26 August 2005 The UK have accepted most of the findings and taken steps to either recover monies incorrectly paid or to change procedures to avoid errors occurring in future. In those cases where they do not agree, or do not fully agree, they have provided explanations as to why this is


FORMAL ERRORS


DAS error reference
Nature of error
UK Reply
Remedial measures taken

04.P.R2.DOR 2107-01
04.P.R2 DOR.2107-02
04.P.R2.DOR.2107-05
04.P.R2.DOR.2107-06
04.P.R2.DOR.2107-07
04.P.R2.DOR.2107-08
04.P.R2.DOR.2107-09
04.P.R2.DOR.2107-10
Error IN sample: Legality and Regularity UK Reply of 9 August 2005The UK has accepted a number of the errors and put remedial measures in place. The ECA has agreed with some of the observations made by the UK and withdrawn some of its opinions.
04.P.R2.DOR 2205.01
04.P.R2.DOR 2205.04
04.P.R2.DOR 2205.05
04.P.R2.DOR 2205.07
04.P.R2.DOR 2205.08
04.P.R2.DOR 2205.09
04.P.R2.DOR 2205.10
04.P.R2.DOR 2205.11
04.P.R2.DOR 2205.12
04.P.R2.DOR 2205.14
04.P.R2.DOR 2205.17
04.P.R2.DOR 2205.20
Error In Sample: Legality and Regularity Scottish Executive Reply of 211 August 2005 The Scottish Executive have accepted a number of the errors and put remedial measures in place. They have also given explanations as to why they disagree with other findings. The ECA has agreed with some of the observations made by the Scottish Executive and withdrawn some of its opinions.
04.P.R1.FIA.1087
04.P.R1.FIA.1133
04.P.R1.FIA.1143
Error In sample: Legality and Regularity Reply from Derek Lee, UK Co-Ordinating Body, dated 26 August 2005 The UK have accepted most of the findings and taken steps to either recover monies incorrectly paid or to change procedures to avoid errors occuring in future. In those cases where they do not agree, or do not fully agree, they have provided explanations as to why this is.


NON-OPINION


DAS error reference
Nature of error
UK Reply
Remedial measures taken

04.P.R2.DOR 2107-01Error In sample: Legality and Regularity UK reply of 9 August 2005The UK has accepted a number of the errors and put remedial measures in place. The ECA has agreed with some of the observations make by the UK nd withdrawn some of its opinions.
04.P.R2.DOR 2205.01
04.P.R2.DOR 2205.07
04.P.R2.DOR 2205.08
04.P.R2.DOR 2205.10
Error In sample: Legality and Regularity Scottish Executive Reply of 11 August 2005 The Scottish Executive have accepted a number of the errors and put remedial measures in place. They have also given explanations as to why they disagree with other findings. The ECA has agreed with some of the observations made by the Scottish Executive and withdrawn some of its opinions.
04/SYS/RD/TOR.0082System Weaknessses Reply from Sarah Connor, HM Revenue & Customs, dated 5 September 2005 The UK authorities have accepted the opinions expressed by the Court and changes have been implemented or will be implemented to meet the necessary requirements.
N/AElectronic Customs Clearance Reply from Sarah Connor, HM Revenue & Customs, dated 16 March 2005 The UK authorities are taking steps to meet the points made by the ECA.


Letter from the Chairman to Ivan Lewis MP

  Thank you very much for your Explanatory Memorandum dated 19 December 2005[10] regarding the European Court of Auditors' Annual Report for financial year 2004; and your letter of 31 January regarding references to the UK in this report. Both of these documents have been considered recently by Sub-Committee A. The Sub-Committee have decided to hold the original Explanatory Memorandum under scrutiny and to launch an inquiry into the reasons behind a lack of a positive Statement of Assurance on the annual accounts for the last 11 years.

  In due course we will be looking to arrange a mutually convenient time to meet you formally to discuss the situation. However, in advance of this session, do the Government consider that the mechanisms already suggested by the Commission to improve the management of the budget are adequate and likely to lead to a positive DAS on the accounts by the end of the tenure of the Barroso Commission? In addition, do the Government consider that the working methods, staffing and organisation of the Court of Auditors is appropriate and effective? Do you have any suggestions for improvement?

  For your information I enclose a copy of the Call for Evidence (not printed) which the Committee has recently published.

8 February 2006

Letter from Ivan Lewis MP to the Chairman

  Thank you for your letter of 8 February. I am pleased that Sub-Committee A has decided to launch an inquiry into the reasons behind the lack of a positive Statement of Assurance on the EU's accounts for the last 11 years, and will be happy to meet you formally to discuss this.

  You asked two questions in advance of my session. First, whether the mechanisms suggested by the Commission to improve the management of the budget are adequate, and likely to lead to a positive DAS on the accounts by the end of the tenure of the Barroso Commission. The Commission's strategic objective to achieve a positive DAS by 2009 is indeed an ambitious and challenging target and will require considerable effort by itself and by Member States. It is encouraging that the 2004 report gives assurance on a greater proportion of the budget than ever before, because of improvements on financial management and control in key areas of expenditure, but there is still a long way to go. The Commission's Action Plan[11], in response to the November ECOFIN conclusions on the "roadmap to an integrated internal control framework"[12] does offer the prospect of further progress towards the achievement of a positive DAS, perhaps most significantly through the launching of an inter-institutional dialogue between the Council and the European Parliament on the risks to be tolerated in the underlying transactions. The continuing efforts to simplify complex legislation are also likely to have a beneficial effect on the level of assurance achieved. But ultimately it is for the Court of Auditors to consider how any proposed changes impact on its approach and the level of assurance it can give. I do not think that anyone could say definitely that a 100 per cent positive DAS will be achieved by 2009, although I would be very happy to be proved wrong. But I do think that we will have made much more progress towards providing the kind of assurance that the Court is looking for.

  Secondly, you asked whether the Government considers that the working methods, staffing and organisation of the Court of Auditors' are appropriate and effective. Concerning the ECA's organisation, I am reminded of Sub-Committee A's earlier inquiry into this[13], the findings of which played a major part in the Government's efforts to introduce reform of the ECA during the last Inter-Governmental Conference (IGC). As you know, there was little support for the Government's proposal that the ECA should be re-organised in the form of a 9-member Executive Board supervised by a part-time 25-member Governing Committee. The Government still considers that the ECA's current organisation in the form of a Court of 25 members is unwieldy and inefficient, and there may be scope for reviving the reform proposal in the future.

  The ECA, like other independent audit bodies, works to international auditing standards. But I am also reminded that the Committee of Public Accounts drew attention to the effectiveness of the ECA's work in its report last year on "Financial Management of the European Union"[14]. They suggested (as has the European Parliament) that it should consider arranging a peer review of its approach and work to test the quality and relevance of what it does and to demonstrate its willingness to learn from others. The Government agreed that there would be benefits in carrying out a review, or in introducing systems for ongoing external review. Processes of ongoing review and feedback similar to those recently agreed for our own National Audit Office could also be considered for the ECA. The ECA has since decided to submit to a peer review, and we await the outcome.

  Finally, you explained that Sub-Committee A intended to keep the Explanatory Memorandum on the European Court of Auditors' Annual Report for the 2004 financial year under scrutiny, pending its inquiry. As you know, the Council recommendation on discharge for 2004 will be considered by the ECOFIN Council on 14 March, and all Member States should have completed their Parliamentary Scrutiny of the ECA report by then. I should therefore be very grateful if the Sub-Committee would consider whether they could clear the Explanatory Memorandum in advance of the inquiry.

28 February 2006




Letter from the Chairman to Ivan Lewis MP

  Thank you very much for your letter of 28 February regarding EM OJC 301, the Annual Report of the European Court of Auditors concerning financial year 2004. Sub-Committee A considered this at their meeting on 7 March.

  The Sub-Committee noted your assurances that you will be happy to attend a formal evidence session in the near future as part of our inquiry into the audit and management of European funds; and, in response to your request in the penultimate paragraph of your letter, have agreed to clear the document from scrutiny.

  At the same meeting, the Sub-Committee also considered EM 5509/06 on the Commission's Action Plan towards and Integrated Internal Control Framework and decided to hold this under scrutiny pending your oral evidence session.

8 March 2006

Letter from the Chairman to Ed Balls MP, Economic Secretary, HM Treasury

  Thank you very much for your Explanatory Memorandum 8630/05 on Member States' replies to the European Court of Auditors' 2004 Annual Report. This was considered by Sub-Committee A at their meeting on 20 June.

  The Committee found this information extremely useful and valuable in relation to its current inquiry into the management and audit of EC expenditure and accounts. Therefore, we have decided to continue to hold the document under scrutiny as part of this inquiry.

22 June 2006



10   (OJC 301, Volume 48). Back

11   5509/06, COM (2000) 9 final of 17 January 2006: Commission Action Plan towards an Integrated Internal Control Framework, EM submitted on 7 February 2006. Back

12   10326/05, COM(2005)252 final of 15 June 2005, Communication from the Commission to the Council, the European Parliament and the European Court of Auditors on a roadmap to an integrated internal control framework, EM submitted on 20 July 2005. Back

13   12th Report, Session 2000-01 "The European Court of Auditors: the case for reform". Back

14   18th report, Session 2004-05. Back


 
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