July 15, Russia, Moscow
On July 13 at 23.20 (Moscow time) Russian anti-doping agency "RUSADA" reviewed the joint statement of the Russian Olympic Committee and the Russian Paralympic Committee, as well as the report published on the official websites of these organizations “On the results of a study of the effectiveness of the functioning of the internal control system in relation to business processes “Sales of products” ,“Acquisition of goods, works and services” and “Remuneration of employees” of RAA RUSADA”.
RUSADA undergoes annual audits on the ISO quality management system https://rusada.ru/about/documents/dokumenty-rusada/, the audit is conducted by a subsidiary of the Russian Association of French Standardization and Certification Association AFNOR.
RUSADA passed WADA audits for compliance with the World Anti-Doping Code in 2017 (https://rusada.ru/news/main/vada-provelo-audit-vsekh-podrazdeleniy-raa-rusada/), 2018 (https://rusada.ru/news/press-releases/vada-zavershilo-audit-rossiyskogo-antidopingovogo-agentstva/).
RUSADA activities are accompanied by independent audit organization verifying the correctness of registration and accounting of operations.
Moreover, in order to increase transparency and ensure proper risk control processes inside RUSADA, an internal control service has been created and is functioning.
RUSADA underwent an annual financial audit, which in 2017 and 2018 was carried out by an audit company (AUDITALL LLC), approved by the General Meeting of RUSADA Members (ROC and RPC). RUSADA's audit reports and work report were reviewed by RUSADA Supervisory Board members and then approved by the General Meeting of Members (all decisions are recorded in the minutes).
Please note that Director General of the Agency cannot, in accordance with the Charter, choose an audit company, it is the duty of the General Meeting of Members in accordance with clause 6.2.11 of the Charter (https://rusada.ru/about/documents/dokumenty-rusada/). Also, according to paragraph 6.6 of the Charter, the General Meeting of Members is held no later than four months after the end of the financial year for approval of the annual results of operations and accounting (financial) statements.
The General Meeting of Members did not conduct the proper approval process for the auditor company in accordance with the Charter, since representatives of the ROC (Russian Olympic Committee) and RPC (Russian Paralympic Committee ) did not initiate such meeting.
RUSADA initiated holding of the first General Meeting of Members on April 30, 2019, at which an audit report was prepared, it was prepared by the LLC AUDITALL organization that was approved earlier by the ROC (Russian Olympic Committee) and RPC (Russian Paralympic Committee) in 2017 and in 2018, the report was previously considered at the pre-annual meeting of RUSADA Supervisory Board.
According to the minutes of the meeting dated April 30, 2019, it was decided to choose a new auditor company and conduct a second audit of financial and economic activities. The second audit, according to the decision of the General Meeting of Members, was funded by the ROC (Russian Olympic Committee).
Thus, the information provided on the websites of the ROC and RPC on the retroactive submission by the Director General of a report does not correspond to reality.
This, in turn, means the absence of grounds for an “in-depth audit to assess the operational effectiveness of the internal control system in relation to business processes: “Remuneration of RUSADA employees”, “Acquisition of goods, works and services” and “Product sales”.
RUSADA employees were not aware of the organization of such an “in-depth audit to assess the operational effectiveness of the internal control system in relation to business processes: “Remuneration of RUSADA employees”, “Acquisition of goods, works and services” and “Sales of products” of FinExpertiza LLC which was held in parallel with the main financial audit of the same company and whose reports contain the main conclusions that “According to the auditors, the attached annual accounting (financial) statements reflect reliably in all material respects the financial position of the Association Russian Anti-Doping Agency “RUSADA” as of 12/31/2019, the targeted use of funds and their movement for 2019 (as well as in 2018) in accordance with the rules for the preparation of financial statements established in the Russian Federation” (https://fedresurs.ru/sfactmessage/DF724D2CCFE0440C81E72D082879C09B?attempt=1)
These Reports on the results of the audit of the annual accounting (financial) statements of RAA RUSADA for 2019, as well as for 2018, indicate “In order to ensure the reliability of accounting data and accounting (financial) statements, by Director General’s order No. 56-OD of 18.12 .2019 the inventory of property and obligations of the Agency is regulated as of December 31, 2019. In fact, an inventory of property and liabilities before the preparation of annual financial statements was carried out and executed in accordance with the requirements of the law. ”
And in the main Report on the results of the audit of the annual accounting (financial) statements of RAA “RUSADA” for 2019, the conclusion is made: “There are no significant deficiencies in the internal control system,” which contradicts the “accusatory” report presented by the ROC (Russian Olympic Committee) and RPC (Russian Paralympic Committee).
Our analysis of the report submitted by the ROC (Russian Olympic Committee) and RPC (Russian Paralympic Committee), analysis of the conclusions made by the auditor in the Report on the results of the study of the effectiveness of the internal control system in relation to business processes “Product sales”, “Acquisition of goods, works and services” and “Remuneration of employees” of RAA RUSADA ” indicate that the auditor probably approached the audit either superficially or tendentiously.
The conflicting, incompatible with organization of RUSADA’s work auditor's findings testify to this. There are questions about attempts by the auditor to give conclusions on organizing functional tasks that are exclusively characteristic of national anti-doping agencies that perform work in accordance with international anti-doping standards. We have no information that FinExpertiza LLC has passed the compliance with the requirements of WADA and can be considered an accredited organization by WADA in this area. The findings of the auditor in the report clearly indicate that the auditor did not understand the organization of the activities of the national anti-doping agency, and therefore its findings cannot be considered reliable and cannot reflect the objective state of affairs within RUSADA.
In addition, such conclusions indicate a attempt of interference into operational independence of an independent national agency by an entity that does not have the rights granted by the international regulator.
The ROC (Russian Olympic Committee) and RPC (Russian Paralympic Committee), giving public this contradictory report, did not even try to get clarifications from RUSADA, thus confirming the fact that they themselves are not fully versed in organization of professional activities of anti-doping agencies.
RUSADA expresses its deep disappointment with the fact that the ROC (Russian Olympic Committee) and RPC (Russian Paralympic Committee) posted on their website information that was “strictly confidential” (Section 1.4 of the Report).
RUSADA is carefully studying the comprehensive consequences of such disclosure.
The information set forth in the “Report” is analyzed in detail. RUSADA report will be submitted to the Supervisory Board.