RUSADA publishes an open letter
in response to the ROC official statement
We can only regret that representatives of the Russian Olympic Committee, who launched the mechanism of RUSADA defamation, seeing obvious problems in the report made public by the founders themselves, not only do not try to find a constructive way out of the situation simulated by them, but continue the escalation based on an unreliable report, ordered by ROC representatives.
Despite all the obvious contradictions (supported by RUSADA documents) of the report received by the ROC, the official statement of ROC representatives regarding the theses of the special report (prepared by the audit company FinExpertiza on the results of the study of the effectiveness of the functioning of the internal control system in relation to RUSADA business processes) remained unchanged, even though the fact that this report cannot be recognized as reliable, objective, since the auditors did not use all documents available in RUSADA accounting department while conducting their audit, and therefore the objectivity and reliability of the auditors' judgments and conclusions is highly controversial.
Next attempts of the Russian Olympic Committee representatives to claim that the arguments presented by RUSADA are another attempt to divert attention from the facts and essence of the discrepancies under consideration is untenable, since we provided detailed and reasoned arguments based on real documents, and not on speculation and assumptions, concerning all significant issues of the charges. On the contrary, RUSADA not only does not distract attention, but draws and focuses attention on all the “probabilistic” conclusions of the auditor, as well as on how the analysis was carried out and conclusions were drawn on each significant aspect.
ROC representatives are surprised at their false conclusions with an emotional connotation that does not correspond to the status of the ROC document. In addition to our arguments, RUSADA once again, for the objectivity of judgments, provides its reasoned information:
1. From the statement of ROC representatives: “It is also surprising that behind the lengthy rhetoric and comments of the theses of the audit report, falsifications of signatures on documents with counterparties and other no less indicative facts are nowhere refuted in RAA “RUSADA” arguments. Unfortunately, we are forced to state the fact of knowingly submitting incorrect information”.
RUSADA, for its part, draws attention of ROC representatives and all interested parties to p. 23 of RUSADA’s arguments, where this refutation is indicated: “Never and no one in the Accounting Department was engaged in forgery of documents. RUSADA can provide all the original documents on the basis of which the payments were made, all signatures there are real, and not printed from a computer. For quick payment, we send scans to the mail, but then they are always in 100% of the cases are supplemented with the originals. All documents are in the Accounting Department and can be provided for verification". The auditor, offering his false assumptions, neither requested the original documents, nor conducted a graphological examination, but simply presented an unconfirmed false assumption, and ROC representatives have accepted this and continue to insist on the auditor's false assumptions.
2. From the ROC’s statement on taxi: “RAA “RUSADA”’ Director General thoroughly argued with references to accounting documents that the sum of 11 million rubles as taxi expenses does not correspond to reality and was never spent by his organization. However, in the RAA “RUSADA” Arguments published on July 21 he already admits that the indicated amount was actually spent on taxi services. This, in particular, is pointed out by the auditors, who, based on the results of the audit, raised the issue of the opacity of the amounts spent”.
RUSADA, for its part, draws attention of ROC representatives and all interested parties on pages 63 - 64 of our arguments, which contains all the justifications and arguments supported by documents that directly refute the conclusions of ROC representatives:
“For information: Those who have the right to use a taxi include:
1. All employees of RAA “RUSADA” – only for official travel, in the manner and under the conditions provided for by the Documented procedure for the use of official transport and taxi;
2. Physical persons who are RAA “RUSADA” sample collection agents (doping control officers and chaperones) – exclusively on the terms defined by civil law contracts signed with them.
The amount of 11 348 289,78 rubles for 2018 and 2019 was indeed spent on payments for taxi services. This amount of expenses is primarily due to the fact that taxi services are used by sample collection agents along with Agency employees as individuals acting on behalf of and at the expense of RAA “RUSADA”. The use of taxi services by agents when executing an order is only possible if the criteria set out in the Agency agreement are met, the list of these criteria is closed".
RUSADA has never refused to confirm the real amount of taxi expenses spent on RUSADA operational tasks confirmed by accounting documents. The ROC statement does not correspond to reality, as well as to the details provided by us in the arguments by whom and for what purpose the taxi was used. Moreover, a detailed breakdown by years of RUSADA Director General’s taxi use is given in order to show that it is false to project the total amount of expenses of 11 348 289,78 rubles for 2018 and 2019 on Y. Ganus alone. The expenses of RUSADA management are reasonable and more than modest. However, the emphasis on taxi services’ use suggests that not only the auditors, while preparing their opinion, but also ROC representatives, forming a false position in their statement, do not understand how RUSADA business processes and logistics of sample collection are built by doping control officers (DCO’s). For the information of all stakeholders, in 2019, 88 DCOs and 37 chaperones, not counting the medical staff of medical institutions involved in collection of blood samples, worked on RUSADA missions, and RUSADA collected 9068 samples out of 11072.
3. In order to compensate for possible unfounded arguments and claims on the expediency of RUSADA management business trips, which are taken exclusively for professional purposes in order to strengthen and develop Russian anti-doping system and therefore increase confidence in Russian sports throughout the world, are carried out rationally and efficiently, one can compare travel expenses (both Russian and foreign) of RUSADA and the Russian Olympic Committee:
With the staff of 135 people in 2019, the ROC total expenses for travel and business trips amounted to 63 061 thousand rubles;
With the staff of 67 people, RUSADA total travel costs (both Russian and foreign) of all employees amounted to 11 573 thousand rubles;
Therefore, the given expenses on business trips (both Russian and foreign) of all RUSADA employees are almost three times less than ROC expenses calculated for a comparable headcount.
4. From the ROC’s statement: By their statement “The authors of this document (RUSADA note – RUSADA arguments) question the professional level of FinExpertiza LLC, directly accuse its employees of bias and prejudice”. The ROC representatives do not want to accept the obvious fact that FinExpertiza LLC itself evaluates its actions by the work presented by its document based on incomplete information with obvious evidence of the auditor's misunderstanding of RUSADA business processes, as well as on unconfirmed probabilistic arguments. Such kind of auditor’s analysis cannot be considered as credible and reliable document, especially for an organization such as the ROC.
In addition, the information we received from open sources served as confirmation of the caution towards the results of FinExpertiza LLC special report, prepared at the request of ROC representatives. In March 2013, the Federal Service for Financial and Budgetary Supervision carried out a planned external audit of the audit organization “FinExpertiza” LLC work quality. The audit disclosed violations of requirements of the Federal Law of December 30, 2008 No. 307-FZ "On Audit Activities" and Federal standards on auditing. Based on the results of the audit, an order was issued against “FinExpertiza” LLC to suspend the membership of “FinExpertiza” LLC in the self-regulatory organization of auditors NP "Audit Chamber of Russia" for a period of 60 calendar days, as well as an order to eliminate violations revealed by the results of the external quality audit during the suspension period of the audit organization’s membership in the self-regulatory organization of auditors. Link: https://www.audit-it.ru/news/audit/630188.html
This information can be confirmed by the text of the decision of the Federal Antimonopoly Service in case No. 1-00-735 / 77-16 on violation of tendering and contracting procedures (the decision is publicly available), which states that “FinExpertiza” LLC has submitted an information letter dated February 24, 2016 about passing the audit by the Federal Service for Financial and Budgetary Supervision, in which the company declared the fact of passing external quality control from 03/04/2013 to 04/01/2013, as a result of which the organization was issued an order to suspend membership in the self-regulatory organization of auditors for a period of 60 calendar days, as well as a letter on termination of suspension and membership’s reinstatement of “FinExpertiza” LLC activities from 17.08.2013 was submitted with confirmation of all necessary documents. Link: https://br.fas.gov.ru/documents/1-00-735-77-16/
It should be noted that, according to the information posted by the website kommersant.ru with reference to Rosfinnadzor, violations of the Law on Auditing and Federal Standards of Auditing (FSAD) requirements became the basis for the sanctions application. “Finexpertiza” reported that the reason for the application of the sanction was the fact that several working documents were signed, in particular, by "technical" employees who did not have common diploma certification (required since 2012 for audit of socially significant public organizations). According to Pavel Kuznetsov, Head of the Rosfinnadzor Department for Supervision of Audit Activities, “Finexpertiza” admitted these violations. Link: https://www.kommersant.ru/doc/2244889
5. We draw the attention of ROC representatives to the fact that the audit organizations offered to the founders by RUSADA were selected not on the basis of their belonging to the organizational cluster of “FinExpertiza” LLC, but on the recommendations of the authorized representatives, since RUSADA management builds its work on the principles of trust and mutual respect. We are not trying to compile the dubious activities to discredit RUSADA and its management with the entire Russian Olympic Committee, we understand that this is the will of individual ROC representatives who are pursuing their own goals.
6. From the ROC statement: “Yuri Ganus stated that he trusts the results of the mandatory audit conducted by FinExpertiza LLC”. RUSADA has no reason not to trust the results of the annual mandatory audit, particularly because this work was carried out by various auditors of FinExpertiza LLC. According to the auditor’s opinion, the attached annual accounting (financial) statements for 2018 and 2019 accurately reflect, in all significant aspects, the financial situation in the Agency as of December 31, 2018 and 2019, respectively, and accurately reflect the intended use of funds and their movement in 2018 and 2019 in accordance with the accounting policy established in the Russian Federation. A similar conclusion was given in 2017. Both in 2018 and in 2019, it was indicated that the inventory of property and obligations before the preparation of the annual financial statements was in fact carried out and executed in accordance with the requirements of the legislation. But no less important: "No significant shortcomings in the internal control system have been identified." How not to trust what there are grounds for in RUSADA, determined by the organization of RUSADA work itself and business culture of the agency, aimed not at plundering funds, but at agency revival and dynamic development, at creating conditions for early changes in the anti-doping system in Russia, which could open international sports competitions of the highest level for our clean athletes.
Thus, the difference in the conclusions of the mandatory audit conducted by FinExpertiza LLC for 2018 and 2019 and the special audit commissioned by ROC representatives is probably determined by the difference in professional approaches to the performance of their task by those auditors of FinExpertiza LLC who conducted the annual mandatory audit and those auditors who worked on a special report at ROC request.
It seems that either ROC representatives are reading another document that reveals our arguments, or ROC representatives are not interested in any of RUSADA arguments on the way to their goal.
It only confirms the true intentions of the founders to achieve their goal at any cost, in violation of not only Russian legislation, but also the international anti-doping standard for the protection of privacy and personal information. All this testifies to the fact that ROC representatives, while reaching their goals, do not seek to conduct a dialogue based on mutual respect and trust.
At the same time, this situation does not affect our respect for the Russian Olympic Committee as a whole institute, we share our attitude to the spirit and traditions of the Olympic and Paralympic values, the keepers of which are the Russian Olympic Committee and the Russian Paralympic Committee. And we regret the demonstration of leadership, culture and methods shown in relation to RUSADA, which are far from traditional and correspond more to a different era, from which our country has been out since long, and to a different level of relations.
During the campaign of the special report against us, RUSADA website, where our arguments have been posted, was subjected to an attempted hacker attack, which has been successfully blocked. We are strengthening our efforts to identify sources of threats and to protect our resources.
It is very important that ROC representatives understand possible consequences of their biased line of action and decisions regarding the national independent anti-doping agency and its management, while acting in the interests of clean sports in Russia, and therefore in the national interests, and enjoying trust in the world, and the likely impact of such actions not only on the Russian Olympic Committee, the Russian Paralympic Committee, but also on the entire Russian sport, since RUSADA activities are aimed at all Russian sports organizations. RUSADA currently remains the last bridge for the restoration of Russian sports in the shortest possible time, which directly depends on the actions of the Russian sports authorities and have recently been fatal. These actions, with a high degree of probability, can lead to an increase of the financial burden on the budget of the Russian Federation, and ROC representatives leading this campaign against RUSADA should understand this. This assumption has a high degree of probability, in contrast to those unsound speculations and probabilistic judgments in the special report commissioned by ROC representatives.
RUSADA sincerely hopes to restore the dialogue with the founders on the basis of mutual respect and trust.