Laser Audit of the Application of Gender-based Analysis Plus

Laser Audit of the Application of Gender-based Analysis Plus - PDF Version (727 KB)

Table of contents

• Executive Summary
• Recommendation
• 1 Introduction
  • 1.1 Background
  • 1.2 Audit Objective and Scope
  • 1.3 Methodology and Audit Approach
  • 1.4 Conformance with professional standards
• 2 Finding and Recommendation
  • 2.1 Finding
  • 2.2 Conclusion
  • 2.3 Recommendation
  • 2.4 Management Action Plan
• Annex A: Audit Criteria

July 2019

Executive Summary

Gender-based Analysis Plus (GBA+) is an analytical tool designed to systematically integrate gender and other identity factors throughout the decision-making process and to assess the potential impacts of policies, programs or legislation on diverse groups of people in order to inform the development and delivery of more responsive initiatives.

It is the responsibility of each department or agency to determine whether there is a potential gender or diversity consideration within the proposed policy, program, initiative or service. Cabinet documents and Treasury Board Submissions are expected to be tailored to adequately address all gender and diversity considerations revealed through the GBA+, thereby ensuring that the different needs, priorities, interests, and roles and responsibilities of diverse groups of people are being addressed and integrated appropriately. To support the departments, Privy Council Office, Treasury Board of Canada Secretariat and Department for Women and Gender Equality have developed a framework and tools for the implementation and application of GBA+.

In the 2018-19 Departmental Plan, Public Safety Canada committed to ensure the application of GBA+ in the development and implementation of its policies and programs. This commitment is elaborated in Public Safety Canada’s 2018-19 GBA+ Action Plan through the following objectives:

• Increase awareness of enhanced GBA+ obligations and shared responsibility for performance;
• Build capacity, including access to training, tools and a support network for analysts conducting GBA+; and,
• Enhance governance, assessment, tracking and reporting on departmental GBA+ performance and the implementation of this Action Plan.

Finally, the Departmental GBA+ Action Plan contains individual GBA+ Branch Plans that set training commitments and initiatives against which biannual progress reports are tabled at the Internal Policy Committee.

Audit Objective and Scope

The objective of this audit was to assess if Public Safety Canada has effective key elements in place that support GBA+ implementation and application.

The scope of the audit focused on the corporate key framework elements in place to support the implementation and application of GBA+. The audit reviewed relevant documents and information between April 2017 and February 2019.

The audit did not assess the quality of the GBA+ submitted in Cabinet documents and Treasury Board Submissions, nor did it question the need of GBA+ for programs where it was deemed not required. Additionally, the engagement did not assess the Memoranda to Cabinet and Treasury Board Submission processes and related reviews.

Why is this important?

Since 1995, the Government of Canada committed to using GBA+ in the development of policies, programs and legislation. It provides federal officials with the means to continually improve their work and attain better results for Canadians by being more responsive to specific needs and circumstances.

GBA+ consists of taking into consideration all the intersecting identity factors of diverse groups of people to ensure an inclusive approach to developing, delivering and evaluating initiatives^Footnote1.

Without GBA+, there is a risk of missing or misreading the experiences of a significant portion of the Canadian population and, as a consequence, risk developing policies and initiatives that can inadvertently increase inequalities. It is therefore critical to apply GBA+ in order to optimize the impact and effectiveness of our Departmental initiatives.

Key Findings

Public Safety Canada has key GBA+ elements in place that align with the government suggested approach; however, improvements to its GBA+ Framework are required to strengthen the commitments made to ensure that the Department applies GBA+ in the development and implementation of  policies, programs, and operations.

To implement GBA+, Public Safety Canada has developed a Departmental GBA+ Action Plan. This Plan sets the foundation and defines the approach for GBA+. While the Plan contains roles and responsibilities, they are not clear and do not align with other corporate documentation that refer to GBA+ commitments, such as the 2017-18 Departmental Results Report.

The Internal Policy Committee records of decision demonstrate the committee’s approval of the Public Safety Canada’s GBA+ Action Plan and its oversight of the bi-annual reports on GBA+ implementation. Despite this, GBA+ governance and associated responsibilities are not clearly defined and documented in the Public Safety Canada’s GBA+ Action Plan or the committee’s Terms of Reference.

Finally, in its Action Plan, Public Safety Canada stipulates that the progress of commitments made in GBA+ Branch Plans is expected to be reported on. The review of bi-annual progress reports demonstrates that tracking and reporting are performed; however, the links between the GBA+ Branch Plans and the progress reports are not always evident.

Conclusion

Public Safety Canada has key elements in place to support the implementation and application of GBA+. These elements align with GBA+ Framework suggested by WGE. While the Department has made progress in the implementation of GBA+, improvements can be made to clarify the roles and responsibilities of key players, the established governance, and the tracking and reporting requirements to support the effectiveness of key GBA+ elements in place.

Recommendation

The Assistant Deputy Minister, Portfolio Affairs and Communications Branch, in collaboration with all Assistant Deputy Ministers, should revise and strengthen the Public Safety Canada GBA+ Framework to ensure that:

• Clearly defined governance and roles and responsibilities for all key players are documented and implemented to ensure a sustainable GBA+ application; and,
• Detailed measures that demonstrate and support the commitment to a sustainable GBA+ are clearly established, tracked and regularly reported on.

1 Introduction

1.1 Background

In the 1995 Federal Plan on Gender Equality, the Government of Canada solidified its commitment to implementing Gender-based Analysis (GBA) throughout departments and agencies.

The Office of the Auditor General (OAG) conducted an audit in 2015 to assess the Government’s implementation of GBA. In response to the audit’s recommendations, the Department for Women and Gender Equality (WGE) (formerly Status of Women Canada), the Privy Council Office (PCO) and the Treasury Board of Canada Secretariat (TBS) developed an Action Plan on Gender-based Analysis (2016-20) that includes commitments to review and strengthen the implementation and application of GBA. Through the Action Plan, WGE, PCO and TBS committed to work with all federal departments and agencies to identify the barriers to implementing GBA and to periodically assess and report on progress.

Addressing OAG recommendations also lead to further consideration of other diversity factors such as age, education, language, geography, culture, income, race, and religion, which resulted in Gender-based Analysis Plus (GBA+). GBA+ is an analytical tool designed to systematically integrate gender and other identity factors throughout the decision-making process and to assess the potential impacts of policies, programs or legislation on diverse groups of people in order to inform the development and delivery of more responsive initiatives.

It is the responsibility of each department or agency to determine whether there is a potential diversity consideration within the proposed policy, program, initiative or service. Cabinet documents and Treasury Board (TB) Submissions are expected to be tailored to adequately address all gender and diversity considerations revealed through the GBA+, thereby ensuring that the different needs, priorities, interests, roles and responsibilities of diverse groups are considered and integrated appropriately. To support departments and agencies, PCO, TBS and WGE have developed a framework and tools for the implementation and application of GBA+.

Through the implementation of the Action Plan on Gender-based Analysis (2016-20), WGE has taken a leadership role by providing other federal departments and agencies with training and tools to support and promote the implementation and application of GBA+. Part of the guidance is a GBA+ Framework that is founded on six core elements, which consist of:

1. Developing a GBA+ statement of intent or policy;
2. Establishing a Responsibility Centre to monitor the implementation of the framework and the practice of GBA+;
3. Identifying mandatory GBA+ training for all senior officials, analysts and other appropriate staff;
4. Providing guides, manuals and other appropriate tools for promoting GBA+;
5. Reporting on progress in the Departmental Plan (formerly Reports on Plans and Priorities), Departmental Report on Results (formerly Departmental Performance Report); and,
6. Completing annual self-assessments on implementation of frameworks and practice of GBA+ on specific initiatives.

GBA+ at Public Safety Canada

In the 2018-19 Departmental Plan, Public Safety Canada (PS) committed to ensure the application of GBA+ in the development and implementation of its policies and programs, and in how it manages its operations. This commitment is elaborated in the PS’ 2018-19 GBA+ Action Plan that includes GBA+ Branch Plans and targets related to GBA+ application.

The initial PS GBA+ Action Plan (2017-18) was approved on April 18, 2017 at the Internal Policy Committee (IPC), with its objectives stated as follows:

• Increase awareness of enhanced GBA+ obligations and shared responsibility for performance;
• Build capacity, including access to training, tools and a support network for PS analysts conducting GBA+ analysis; and,
• Enhance governance, assessment, tracking and reporting on departmental GBA+ performance and the implementation of this Action Plan.

While the Departmental 2018-19 GBA+ Action Plan remained the same as the previous year, the individual GBA+ Branch Plans were updated and tabled at IPC with the annual GBA+ progress update report.

The PS Action Plan also sets forward collective roles and responsibilities for the implementation and application of GBA+, as outlined in the Figure 1 below.

Figure 1: GBA+ Roles and Responsibilities

Furthermore, the PS GBA+ Action Plan provides the following three key implementation pillars:

1. Public Safety Canada’s GBA+ Advisor Network;
2. Implementation of the GBA+ Branch Plans; and,
3. Reporting and Tracking.

These pillars provide additional guidance on how the outlined roles and responsibilities support the implementation and application of the GBA+ as well as providing further direction on monitoring and reporting requirements of the established commitments.

1.2 Audit Objective and Scope

The objective of the audit was to assess if Public Safety Canada has effective key elements in place that support GBA+ implementation and application.

The scope of the audit focused on the key corporate framework elements in place to support the implementation and application of GBA+. The audit reviewed relevant documents and information between April 2017 and February 2019.

The audit did not assess the quality of the GBA+ submitted in the Cabinet documents and TB Submissions or question the need of GBA+ for programs where it was deemed not required. Additionally, the engagement did not assess the Memoranda to Cabinet and TB Submission processes and related reviews.

1.3 Methodology and Audit Approach

To conduct the engagement, the audit team completed the following:

• Review of documentation between April 2017 to February 2019;
• Interviews with key players; and,
• Surveys with GBA+ Advisors and policy/program analysts.

A list of GBA+ Advisors is maintained by the GBA+ Coordinator and was used to determine the Advisor population. Excluding those within the Internal Audit and Evaluation Directorate, the survey was sent to a total of 29 Advisors. Of the 29 Advisors, there were 19 respondents.

Due to the lack of information available to identify a population of policy/program analysts within the Department, an additional survey was sent to 18 employees who contributed to TB Submissions within the 2018-19 fiscal year. The survey results provide insight into the perspective of a policy or program analyst; however, since the sample is not representative, the results were not used to draw conclusions about the population of analysts within the Department.

1.4 Conformance with professional standards

The audit conforms with the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing and the Government of Canada’s Policy on Internal Audit, as supported by the results of the Quality Assurance and Improvement Program.

2 Finding and Recommendation

2.1 Finding: Public Safety Canada has key GBA+ elements in place that align with the suggested approach for the Government of Canada; however, improvements to the PS GBA+ Framework are required to strengthen the commitments made to ensure that the Department applies GBA+ in the development and implementation of policies, programs, and operations.

As mentioned before, the suggested GBA+ approach for the Government of Canada is communicated through the WGE GBA+ Framework. The Framework is composed of six core elements previous listed that range from providing guidance in establishing key roles and responsibilities to setting a tone regarding tracking and reporting requirements. In assessing PS GBA+ implementation approach against these elements, the audit found that the department has implemented most aspects of these components.

Roles and Responsibilities

WGE provides guidance in the establishment of a “Responsibility Centre” in its second core element. The centre’s “overall role is to lead, enhance, support, and monitor implementation of a GBA+ Framework and the actual practice of GBA+”. This role can be implemented under one or more of the following approaches as:

• A facilitator, who enables the practice of GBA+; supports its implementation and capacity development; creates and disseminates the available tools and templates; and, coordinates GBA+ reporting and self-evaluation;
• A convenor, who stimulates debate and discussion on the application of GBA+;
• An expert, who provides GBA+ support to colleagues in their work; and,
• A monitor, who oversees the implementation of GBA+. 

While the Responsibility Centre aims to provide the support, the success of the GBA+ implementation and application rests with all employees across the Department. This shared responsibility is demonstrated through WGE’s guidance to create support mechanisms such as GBA+ Champions and internal and external working groups.

To implement GBA+, PS developed a Departmental GBA+ Action Plan. This Action Plan sets the foundation and defines the departmental approach for GBA+, as well as the collective roles and responsibilities described in Figure1. Aligned with the definition of a GBA+ Responsibility Centre as described in the WGE Framework, PS has a designated GBA+ Focal Point and Coordinator that act as facilitators, who are responsible for the coordination and support for GBA+ implementation and the dissemination of resources and  tools. These roles rest within the Portfolio Affairs and Communications Branch (PACB).

In addition, the Department has GBA+ Advisors who act as experts by providing support to colleagues in their work. Advisors are the link between the GBA+ Coordinator and the policy/program analysts. They provide analysts, in their respective directorate, with GBA+ support, advice and tools, and coordinate the reporting against Branch GBA+ commitments. Each directorate has identified at least one GBA+ Advisor and at the time of the audit, there were 31 GBA+ Advisors across the Department. While the PS Action Plan stipulates that the Assistant Deputy Ministers (ADMs) are responsible to nominate GBA+ Advisors for their Branch, interviews and survey results indicate that most Advisors have volunteered or were asked to fulfill the role by their superiors. Since the GBA+ Coordinator ensures that all newly recruited Advisors receive the Welcome Email with links to resources, such as the GBA+ Action Plan, they need to be notified of GBA+ Advisor nominations. Without a formal notification process, the GBA+ Coordinator cannot ensure an up-to-date list of Advisors and therefore, faces challenges in fulfilling their responsibility to onboard and disseminate information. Although volunteering for the role demonstrates engagement and grassroots commitment, a formal process to accommodate this interest is beneficial to support the key players involved in meeting their roles and responsibilities.

Taking WGE’s guidance to create an internal working group, PS has put in place the GBA+ Advisor Network.  According to the PS Action Plan and interviewees, the purpose of the Network is to create a forum for Advisors to support each other and share best practices. Chaired by the GBA+ Coordinator, the Network also serves as a venue for the chair to share updates and best practices received from WGE and other departments. Although the purpose of the Network is documented, survey results show that the majority of respondents only find the purpose of the Network “somewhat defined”. According to interviews, the GBA+ Advisor Network meetings do not have high attendance and only few survey respondents stated that they attend all meetings, which may impede on the Network’s objective to serve as a venue for sharing GBA+ information and lessons learned.

Contributing to the collective roles and responsibilities related to GBA+ implementation, PS ADMs have a key role that includes leading by example and encouraging the use of GBA+, supporting and promoting related training, and overseeing the quality and application of Branch GBA+ work, through MCs and TB Submission approvals. ADMs interviewed were clear on their GBA+ responsibilities and commitments, as well as their ability to tailor their GBA+ processes and practices according to their Branch needs. PS Managers and Executives also have a key role in promoting GBA+ in the day-to-day work of their units, and providing time for GBA+ training. Finally, analysts drive the implementation and application of GBA+ by conducting complete and accurate analyses in the development of policies and programs.

The ADMs and analysts’ roles and responsibilities with respect to GBA+ are clear as they relate to their respective operational positions. Despite the Department’s practices to disseminate information regarding roles and responsibilities, such as providing a welcome email to new GBA+ Advisors and publishing the GBA+ Action Plan on PS’ intranet, survey results indicate that most GBA+ Advisors consider roles and responsibilities of GBA+ key players to not be clearly defined and communicated. Furthermore, our review of the 2017-18 Departmental Results Report noted that the successful creation of the GBA+ Network was reported on. The document stipulates that the Network’s role is to ensure GBA+ integration across the organization, which differs from the one defined in the PS Action Plan as described in Figure 1.

Governance and GBA+ Policy Statement

Through its GBA+ Framework, WGE encourages the establishment of a “statement of intent” or policy to “clearly articulate [the department’s] commitment to GBA+” and effectively enable “an organization’s GBA+ capacity.”  Specifically, WGE guidance articulates that the “statement of intent” should include the following:

• An organizational commitment to GBA+;
• The need for GBA+ with an emphasis on its relevance to the organization’s work/issues;
• A clear indication of the organization’s commitment to both implementing and sustaining the practice of GBA+; and,
• A requirement that GBA+ be a standard function of a systematic, integrative and evidence-based approach to developing and evaluating research, policies, programs and legislation.

In its GBA+ Action Plan, PS committed to applying “gender and diversity analysis in the development and implementation of its policies, programs and operations”. This commitment is articulated through the previously stated objectives that focus on:

• Increasing awareness of enhanced GBA+ obligations and shared responsibility for performance;
• Building capacity, including access to training, tools and a support network; and,
• Enhancing governance, assessment, tracking and reporting on departmental GBA+ performance and implementation of the GBA+ Action Plan.

These objectives highlight the importance of GBA+ conducted by PS in order to “generate more inclusive program and policy results for Canadians” and ultimately contribute to building a safe and resilient Canada.

The mandate of the Internal Policy Committee (IPC) is to consider key Departmental policy issues and provide the Deputy Minister with advice on draft Memoranda to Cabinet (MC). Although the Terms of Reference for IPC does not specifically include a responsibility for GBA+, the committee has approved the GBA+ Policy Statement in June 2016 and GBA+ Action Plan in April 2017. Interviewees have referred to IPC as the GBA+ oversight committee, due to its focus on policy/program discussions and the bi-annual reporting on GBA+ progress. Furthermore, the 2018-19 Departmental Plan states that “an internal senior management committee monitors the quality and consistency of application of Gender-Based Analysis+ through biannual reviews” and that ”the senior management committee responsible for reviewing policy proposals, the Internal Policy Committee, has committed to ensuring the all proposals going forward will have a robust GBA+ assessment that informs decisions”. ^Footnote2 While efforts are made to remind the presenters to include GBA+ considerations in their information tabled at IPC, our review of committee records of decision and presented material revealed that bi-annual reporting on progress is performed by all Branches, and that in some cases GBA+ is discussed as part of specific policy presentations. Nevertheless, it is difficult to determine if GBA+ is being presented at IPC on a consistent basis to meet the commitments made in the Departmental Plan.

Although the established policy statement and associated objectives demonstrate PS’ commitment to GBA+ and its implementation through the delivery of the Department’s mandate, the tracking and reporting requirements can be further clarified and implemented to enhance governance and accountability, which would contribute to ensuring the quality and consistency of GBA+ application.

Clearly established GBA+ governance and associated responsibilities in the PS GBA+ Action Plan and the committee’s Terms of Reference are required for the Department to ensure sustainable GBA+ that is a standard function of a systematic, integrative and evidence-based approach to develop and evaluate research, policies, programs and legislation.

Tracking and Reporting on GBA+ progress

According to the WGE GBA+ Framework, departments and agencies are asked to report on their GBA+ activities and practices by:

• Identifying their organization’s GBA+ Framework and its elements in the Departmental Plan;
• Reporting on implementation of the GBA+ Framework in their Departmental Results Report (DRR);
• Reporting in the DRR if differential gender impacts were identified in the development of policy, program outcomes;
• Tracking the number of MCs and TB Submissions to which GBA+ was applied; and,
• Reporting in other similar documents, such as annual reports.

In its 2017-18 Departmental Plan, PS committed to reporting on GBA+ and contributing to WGE’s mandate to preventing and reducing gender-based violence, through its evaluation and renewal of the National Action Plan to Combat Human Trafficking. This commitment was also recorded in the 2017 responses to the WGE Gender-based Analysis Plus Implementation Survey.

The Horizontal Evaluation of the National Action Plan to Combat Human Trafficking assessed to which extent gender and diversity was considered during the implementation of the National Action Plan to Combat Human Trafficking; however, a conclusion could not be formulated due to a lack of data. While this initiative was not reported on in the 2017-18 Departmental Results Report, PS did provide examples of GBA+ initiatives, such as “a new Canadian-led G7 project assessing the role of Gender-based Analysis+ in counter-terrorism policy/program development” and the creation of the GBA+ Advisor Network.

The 2018-19 Departmental Plan commits to ensuring the application of GBA+ in its policies, programs, and management of operations. This commitment aligns with the previously mentioned policy statement established in the PS GBA+ Action Plan. The Departmental Plan also refers to the annual update of the PS GBA+ Action Plan and a senior management committee responsible for monitoring the quality and consistency of GBA+ application through bi-annual reviews. These commitments provide a clear indication that the Department has increased engagement to implement GBA+. Although our review of the material presented revealed that GBA+ is discussed as part of specific policy presentations; it is difficult to conclude that GBA+ information presented at IPC is sufficient for the committee to fulfil its GBA+ responsibility as stated in the Departmental Plan. The results achieved against these commitments could not be assessed, as the 2018-19 Departmental Results Report was not complete at the time of the audit.

As previously indicated, our review of records of decision tabled confirmed that GBA+ bi-annual progress reports are presented at IPC. According to the PS GBA+ Action Plan, Branch Advisors are responsible to track and report on the implementation of the measures identified in their respective GBA+ Branch Plan. Although survey results indicate that the majority of GBA+ Advisors are aware of the established reporting requirements, not all interviewees were aware that they needed to specifically report against the commitments made in their GBA+ Branch Plans. The GBA+ commitments included in the Plans vary as they are tailored to the nature of Branch activities. For example, some initiatives/measures focused on facility development (e.g. implementing a gender-neutral bathroom); whereas others focused on capacity building for policy/program analysts (e.g. improving GBA+ online training completion rates). We reviewed the GBA+ Branch Plans against the bi-annual progress reports presented at IPC. Our results demonstrate that the majority of 2017-18 Branch initiatives/measures were reported on; however, there are no specific target completion dates associated with the initiatives, which may lead to difficulties in holding Branches accountable for their progress.  In addition, it was found that several initiatives/measures for 2017-18 were reported on in the following fiscal year; however, the audit team could not fully conclude on 2018-19 reporting cycle because it was not complete at the time of the audit.

GBA+ Training, Guidance and Tools

According to the WGE GBA+ Framework, the development of relevant resources, tools and training is a critical element in the implementation and sustainability of GBA+. The training areas essential to the framework are:

• Senior Management Training that focuses on high level analysis and accountability; and,
• Online Introduction Training to GBA+ that provides basics of GBA+, federal accountabilities, tools, and department-specific application of GBA+.

Furthermore, as a government-wide leader on GBA+, WGE provides a variety of tools and templates, such as the “Demystifying GBA+ Job Aid”, to help organizations embrace the implementation of GBA+ and support analysts in conducting quality gender and diversity analyses.

Although PS has not established a mandatory requirement for GBA+ training, the 2017-18 GBA+ Branch Plans demonstrate a commitment and senior management support in ensuring that staff is provided with necessary training. The 2018-19 GBA+ Branch Plans indicates progress against the commitments made towards GBA+ training. In their Plans, Branches have set targets and report on the number of employees that have completed the WGE Online Introduction Course. In addition to the WGE Introduction Course, the following GBA+ training was also available during the scope of the audit: 

• Gender-based Analysis Plus (GBA+): Applying Your Knowledge, a one-day classroom course offered by the Canada School for Public Service;
• Gender-based Analysis Plus Premium, a pilot three-day classroom course, also offered by the Canada School for Public Service; and
• Tailored in-house workshops, and case studies developed and provided in collaboration with WGE and Global Affairs Canada’s Centre for Intercultural Learning.

Overall, surveys’ respondents have a general awareness of the key training and tools available to them. While respondents have completed the Online Introduction Course offered by WGE, the majority felt that the available training is not sufficient to build Branch capacity and support the conduct of quality GBA+. The GBA+ Coordinator disseminates information on key training and tools to GBA+ Advisors through the Welcome Email, which includes links to available GBA+ training, a copy of the GBA+ Action Plan, and a link to the PS GBA+ GCconnex page, which was created as a repository of available GBA+ material resources. Despite these efforts, survey results for GBA+ Advisors indicate that the communication of training and tools is informal, most often occurring through verbal conversation.

Interviews with senior management noted that Branches are encouraged to work with the GBA+ Coordinator to organize and hold training that is tailored to their needs. We were informed that one of the Branches took the initiative to have a tailored in-house case-study workshop. This was deemed highly successful based on the participation level. Furthermore, the GBA+ Coordinator organized Department-wide learning sessions in 2018 to promote GBA+ and available training. According to the interviewees, this event was well received and attended.

2.2 Conclusion

PS has key elements in place to support the implementation and application of GBA+. These elements align with GBA+ Framework suggested by WGE. While the Department has made progress in the implementation of GBA+, improvements can be made to clarify the roles and responsibilities of key players, the established governance, and the tracking and reporting requirements to support the effectiveness of key GBA+ elements in place.

2.3 Recommendation

Assistant Deputy Minister, Portfolio Affairs and Communications Branch, in collaboration with all Assistant Deputy Ministers, should revise and strengthen the PS GBA+ Framework to ensure that:

• Clearly defined governance and roles and responsibilities for all key players are documented and implemented to ensure a sustainable GBA+ practice; and,
• Detailed measures that demonstrate and support the commitment to a sustainable GBA+ are clearly established, tracked and regularly reported on.

2.4 Management Action Plan

Acknowledgements

IAED would like to thank all those who provided advice and assistance during the audit.

Annex A: Audit Criteria

The following criteria have been developed to ensure sufficient and appropriate testing to support the audit objective and opinion:

Date modified:

2022-07-21