Action Plan developed by Ordre des Comptables Professionnels Agréés d Haïti (OCPAH) BACKGROUND NOTE ON ACTION PLANS

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BACKGROUND NOTE ON ACTION PLANS Action Plans are developed by IFAC members and associates to address policy matters identified through their responses to the IFAC Compliance Self-Assessment Questionnaires. They form part of a continuous process within the IFAC Member Body Compliance Program to support the ongoing development and improvement of the accountancy profession around the world. Action Plans are prepared by members and associates for their own use based on the national frameworks, priorities, processes and challenges specific to each jurisdiction. As such, they will vary in their objectives, content and level of detail, consistent with their differing national environments and stages of development, and will be subject to periodic review and update. Refer to responses to the Part 1 Assessment of the Regulatory and Standard-Setting Framework Questionnaire and Part 2 SMO Self-Assessment Questionnaire for background information on each member and associate their environment and existing processes. These responses may be viewed at: http://www.ifac.org/complianceassessment/published_surveys.php Use of Information Please refer to the Disclaimer published on the Compliance Program website. PLAN OF ACTION IFAC Member/Associate: Approved by Governing Body: Conseil de l Ordre des Comptables Professionnels Agréés d Haïti Approved: January 2013 of Publication: January 2013 Next Update: January 2014 Status as of of Publication Page 1 of 18

Action Plan Subject: Governance Action Plan Objective: Provide the entity with a sound technical and administrative structure that allows it to fulfill its mission # Start Actions Completion Reinforcing the Technical and Organizational Capacity of the Professional Accountancy Organization Resource 1. Oct. 2012 Organizational restructuring: improvement of members June 2013 Board database, update of the accounting software. 2. Feb. 2010 Seeking out additional resources (human, financial, Board material). 3. Oct. 2012 Setting-up of a in charge of monitoring the money efforts aimed at providing the Professional Oct. 2012 Board and Management Accountancy Organization (PAO) with its own premises. 4. Oct. 2012 Creation of a fund aimed at providing the PAO with its own Board premises. 5. Dec. 2012 Setting-up of a discussion Platform for Accounting Firms Jan. 2013 Board and Professional Auditors. 6. Jan. 2013 Make the discussion platform a permanent discussion tool Board / Norms for Accounting Firms and Professional Auditors with the objective of building the profession s capacity. 7. March 2013 Survey on professional accounting practice in Haïti (at the July 2013 Board / Norms level of universities, of Accounting firms, of companies and of the public administration). 8. Oct. 2012 Initialization of the membership listing. Dec. 2012 Executive Management 9. Aug. 2013 Implementation of a Research and Development Unit. Feb. 2014 Board and Task Force Supporting Continuous Professional Development 10. Oct. 2012 Development and implementation of a monitoring system for the training of the members. 11. Jan. 2013 Design, implementation and updating of a Train the Trainers program and of Continuous Professional Development plan. Status as of of Publication Page 2 of 18

# Start Actions Completion 12. Nov. 2012 Raise funds. Board /Public Relations Resource Improving the Communications System and Raising Awareness of OCPAH 13. Strengthening relations with the University. Training/Norms and Public Relations 14. August 2013 Organization of an Inter-American seminar. August or Sept. 2013 Training/Norms and Public Relations 15. July 2013 Organization of an Accounting Student s Congress. July 2013 Training/Norms and Public Relations 16. Strengthening relations with the authorities and the socioprofessional sector. Training/Norms and Public Relations 17. June 2013 Reactivation of the agreement with CCIH. Board, Executive Management 18. Organization of regular radio broadcasts. Active participation of members in OCPAH s TV Broadcast OCPAH MAGAZINE. Public Relations 19. March 2013 Strengthening and frequent updating of OCPAH s website. Board, Executive Management 20. Oct. 2012 Strengthening of the partnership with regional, interregional and international organizations (FIDEF, AIC, IFAC, and others). Board, International Relations Status as of of Publication Page 3 of 18

Action Plan Subject: SMO1 - Quality Assurance Action Plan Objective: Develop the Quality Assurance review system and ensure the adoption and implementation of ISQC 1 and ISA 220 # Start Actions Completion Background: Resource There is no Quality Assurance (QA) review system in place in Haiti. OCPAH is planning to develop such a system for its members. Designing a Strategy to Effectively Implement a Quality Assurance Review System 21. March 2013 The Board to deliberate on the principles to retain for the implementation of the QA review system: - Lobbying before the authorities for the implementation of international norms - Adoption of quality factors including the International Standard on Quality Control (ISQC) 1, the International Standard on Auditing (ISA) 220, the Code of Ethics for Professional Accountants of the International Ethics Standards Board for Accountants (IESBA), and the International Education Standard (IES) 7, Continuing Professional Development. Assisting firms with the implementation of these standards and developing training. May 2013 Board and Quality Control 22. Apr. 2013 Development and adoption by the Board of a Quality Approach Chart. Adopting ISQC 1 and ISA 220 23. Jan. 2013 Obtain a French translation of clarified ISQC 1 and ISA 220 as well as all documents useful for their adoption. 24. Feb. 2013 Analyze requirements foreseen by ISQC 1 and ISA 220. Review the Guide to Quality Control for Small- and Medium-Sized Practices published by the IFAC Small and Medium Practices (SMP). Develop an implementation guide on the international standards which should be adapted to the various sizes of firms. May 2013 Board and Quality Control Jan. 2013 Board and Quality Control Apr. 2013 Board and Quality Control Status as of of Publication Page 4 of 18

# Start Actions Completion 25. May 2013 The Board to adopt ISCQ 1 and ISA 220 and to approve Mai 2013 Board implementation guides. Resource Disseminating and Implementing of ISQC 1 and ISA 220 26. June 2013 Develop Train the Trainers seminars as well as training materials. June 2013 Board and Quality Control 27. June 2013 The Board to approve training materials and selection of trainers. July 2013 Board 28. August 2013 Launch training campaign targeting members of the Association. Board and Quality Control Reviewing Effective Implementation of Quality Control and Other Relevant Standards 29. August 2013 Monitor the effective implementation of : - IESBA Code of Ethics; ISQC 1 and ISA 220; and - IES 7 Annual Review Board and Quality Control Developing and Implementing an External QA Review System 30. Sept. 2013 Develop an external QA review system that meets the SMO1 requirements and that ensures the implementation of the quality control standards by OCPAH members. Sept 2013 Board and Quality Control 31. June 2014 Implementation of supervision tools and procedures for the internal and external quality assurance system (quality approach). Board and Quality Control Maintaining Processes 32. Identification and analysis of the malfunctioning of the quality assurance system and implementation of corrective measures. Board and Quality Control 33. Continue to ensure that OCPAH s QA review system is operating effectively and in compliance with the requirements of SMO 1 Board and Quality Control Status as of of Publication Page 5 of 18

# Start Actions Completion requirements. This includes periodic review of the operation of the QA review system and updating the Action Plan for future activities as necessary. Review of OCPAH s Compliance Information Resource 34. Perform periodic review of OCPAH s response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 1 as necessary. Once updated, inform IFAC Compliance Staff so that they can republish revised information. Board and Quality Control Status as of of Publication Page 6 of 18

Action Plan Subject: SMO2 - International Education Standards Action Plan Objective: Promote the Incorporation of the International Education Standards into the National Requirements # Start Actions Completion Resources Background: The Ministry of Education has responsibility for setting the general accountancy education requirements in Haiti. OCPAH candidates for membership are required to complete a professional accountancy education program with universities, five years of practical experience requirement, and pass final examinations with the OCPAH. In addition, OCPAH members are required by the Ordre to complete 20 hours of Continuing Professional Development (CPD) per year. Promoting International Education Standards in Haiti 33. Jan 2013 Raise public authorities awareness of IES requirements. March 2013 34. Par. 2013 Communicate the IES requirements to the universities that include Accounting in their teaching curricula. June 2013 35. June 2013 Assist universities that include Accounting in their teaching curricula in analyzing the gaps between their Professional Accountancy Programs and the IES requirements. 36. June 2013 Make available to universities that include accounting in their teaching curricula the common content for the development of their professional accountancy education program which should meet the requirements of the IESs. Require the integration of the related courses in the universities curricula. 37. Jan. 2014 Ensure that public authorities and universities adopt a professional accountancy education program which meets the requirements of the IES. Status as of of Publication Page 7 of 18

# Start Actions Completion Resources Enhancing Continuing Professional Development 38. Jan. 2013 Disseminate the content of IES 7, Continuing Professional Development. January2013 39. Feb. 2013 The Board to adopt IES 7 and require members to follow CPD courses as required by IES 7. CPD program should include courses on the IESBA Code of Ethics, ISQC 1, and ISAs. Mai 2013 40. Feb. 2013 Develop a system of annual declaration of completed CPD. Apr. 2013 41. May 2013 The Board to approve the document for annual declarations. Mai 2013 Board 42. June 2013 Disseminate the declaration document to professionals on the field. Sept. 2013 43. Oct. 2013 Collect information and analyze it. Dec. 2013 Training Reviewing Final Examinations 44. Nov. 2012 Periodic review of training system and implementation of a corrective action plan. 45. Dec. 2012 Analyze the gaps between the OCPAH final examinations and the IES, including IES 6, Assessment of Professional Competence. 46. Jan. 2013 Revise the OCPAH final examinations. Jan. 2013 47. Nov. 2013 Organize first final examinations in compliance with IES requirements. Status as of of Publication Page 8 of 18

# Start Actions Completion Resources Maintaining Processes 48. Dec. 2013 Ensure that CPD system functions as intended. 49. Establish a monitoring committee for regularly updating the training system. Review of OCPAH s Compliance Information 50. Perform periodic review of OCPAH s response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 2 as necessary. Once updated, inform IFAC Compliance Staff so that they can republish revised information. Status as of of Publication Page 9 of 18

Action Plan Subject: SMO 3 - IAASB Pronouncements Action Plan Objective: Establish mechanisms for the ongoing adoption and implementation of IAASB Pronouncements # Start Actions Completion Resources Background: OCPAH has proactively taken responsibility for the adoption and implementation of auditing standards in the country. The professional accountancy organization had established ongoing convergence with the Pronouncements of the International Auditing and Assurance Standard Board (IAASB) as an objective but has not adopted new and revised standards in an ongoing manner. OCPAH is planning to make further progress in this area and to develop activities to assist its members with the implementation of the auditing standards. Establishing Mechanisms for the Adoption of International Standards 50. March 2013 Analyze the IAASN 2012 Handbook of International Quality Control, Auditing, Review, Other Assurance, and Related Service Pronouncements. June 2013 Board / Standards 51. July 2013 The Board to adopt current French translation of IAASB Pronouncements, including International Auditing Standards (ISAs). July 2013 Board 52. June 2013 Raise public authorities and universities awareness of IAASB Pronouncements. August 2013 Board / Standards Assisting OCPAH Members with the Implementation of the IAASB Pronouncements 53. July 2013 Develop training tools and materials. August 2013 Board / Standards 54. Sep. 2013 Train the Trainers on ISAs and other IAASB Pronouncements. Dec. 2013 Board / Standards 55. January 2014 Train OCPAH members on ISAs and other IAASB Pronouncements. January2014 Standards / Trainers Status as of of Publication Page 10 of 18

# Start Actions Completion Resources Review of Implementation 56. Feb. 2014 Develop monitoring tools to further ensure ISAs and other IAASB Pronouncements are properly implemented. March 2014 Standards 57. March 2014 Analyze results and implement corrective measures as needed. Apr. 2014 Standards 58. April 2014 Implementation of sanctions systems. June 2014 Board / Standards Maintaining Processes 59. Monitor the evolution of the new and revised standards and pronouncements issued by the IAASB. Board / Standards 60. Update auditing standards as needed. Board / Standards Review of OCPAH s Compliance Information 61. Perform periodic review of OCPAH s response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 3 as necessary. Once updated, inform IFAC Compliance Staff so that they can republish revised information. Board / Standards Status as of of Publication Page 11 of 18

Action Plan Subject: SMO 4 - IESBA Code of Ethics Action Plan Objective: Adopt the IESBA Code of Ethics and Assist OCPAH Members with its Implementation # Start Actions Completion Background: Resources OCPAH has responsibility for adopting ethical requirements with respect to its members. The professional accountancy organization has adopted a Code of Ethics which is not set in accordance with the Code of Ethics for Professional Accountants issued by the IESBA. In addition, OCPAH are required to comply with additional legal ethical requirements in the course of their activities. OCPAH is now planning to adopt the current IESBA Code of Ethics as ethical requirements. Promoting the Adoption of the New Legal Framework for the Accountancy Profession in Haiti 61. July 2012 Encouraging public authorities to adopt and support the implementation of the new Accountancy Law in Haiti. May 2013 Board and Ethics Revising and Updating of OCPAH By-laws, Regulations and Code of Deontology, Adoption of the IESBA Code of Ethics 62. Dec. 2013 Analyze the gaps between OCPAH and IESBA Codes of Ethics. January2013 Ethics 63. Feb. 2013 Develop new Code of Ethics. March 2013 Board and Ethics 64. May 2013 The Board to ratify the revised Code of Ethics as well as By-Laws and regulations as needed. May 2013 Board 65. July 2013 Present the revised Code to the General Assembly for approval. July 2013 Board Advocacy for the revised By-laws, for the Code of Ethics and Regulations and Assisting OCPAH Members with the Implementation of the Code of Ethics 66. March 2013 Develop tools to assist OCPAH members with the implementation of the Code of Ethics. Apr. 2013 Board and Ethics Status as of of Publication Page 12 of 18

67. June 2013 Dispatch revised documents to OCPAH members. June 2013 Board / Executive Management 68. June 2013 Broadcast two televised programs on the revised documents. 69. August 2013 Encourage public authorities to support the revised documents. June 2013 August 2013 Board / Ethics / Public Relations Board / Ethics 70. August 2013 Organize Train the Trainers seminars on the revised Code of Ethics. 71. August 2013 Divulgation of the revised Code of Ethics in professional spheres. Sept. 2013 August 2013 Board / Ethics Board / Ethics Maintaining Processes 72. Apr. 2013 Develop monitoring and control tools to ensure the Code of Ethics is properly implemented. June 2013 Board/Ethics 73. July 2013 Implement monitoring and control tools. Sept. 2013 Board/ Ethics 74. Implement a monitoring system to review new and revised IESBA pronouncements and update the Code of Ethics as needed. Board/Ethics Review of OCPAH s Compliance Information 75. Perform periodic review of OCPAH s response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 4 as necessary. Once updated, inform IFAC Compliance Staff so that they can republish revised information. Board / Ethics Status as of of Publication Page 13 of 18

Action Plan Subject: Action Plan Objective: SMO 5 - International Public Sector Accounting Standards Improve accounting practices in the public sector through the increase of accounting knowledge of IPSAS # Start Actions Completion Background: Resource The Cour Supérieure des Comptes et du Contentieux Administratif (CSCCA) has responsibility for adopting public sector accounting standards in Haiti International Public Sector Accounting Standards (IPSASs) have not been adopted in the country. OCPAH is planning to promote the adoption of the IPSAS in Haiti. Raising the Public s Awareness of IPSAS and Distributing the Standards to Professional Accountants in General and Public Sector Accountants in Particular 75. Oct. 2012 Compile IPSAS on various medias. Dec. 2012 Board and Standards 76. Jan. 2013 Distribute compilation of IPSAS to Professional Accountants, including Public Sector Accountants. March 2013 Board and Standards 77. Jan. 2013 Distribute IPSAS to state entities such as CSCCA (National Audit Office), Ministry of the Interior, UCREF, ULCC, and Ministry of Economy and Finance. March 2013 Board and Standards 78. Jan. 2013 Advert IPSASs via the OCPAH Magazine. Mai 2013 Public Relations 79. Jan. 2013 Insert links to IPSAS in the OCPAH Website. Jan 2013 Executive Management 80. Feb. 2013 Organize advocacy campaign for teaching IPSAS in universities. May 2013 Board and Standards Organizing Training Seminars on IPSAS for Professional Accountants in General and Public Sector Accountants in Particular 81. Jan. 2013 Choose themes for IPSAS training seminar. Feb. 2013 Training 82. Jan. 2013 Identify trainers to deliver the seminars. March 2013 Training Status as of of Publication Page 14 of 18

# Start Actions Completion 83. Jan. 2013 Advertize the themes on which the seminars will be March 2013 organized. Public Relations Resource 84. Apr. 2013 Organize the seminars on IPSAS. Sept. 2013 Training Encouraging the Cour Supérieure des Comptes et du Contentieux Administratif to Include Articles in the Accountancy Bill and Establish IPSAS as the Public Sector Accounting Standards in the Country 85. Jan 2013 Drafting a text explaining the importance of including IPSAS in the project of Accountancy Law. Feb. 2013 Standards 86. March 2013 Meeting with the Directors of CSCCA on the need for taking IPSAS into account in the project of reform of the Accountancy Law. March 2013 Board Maintaining Processes 87. May 2013 Development of follow-up and monitoring tools to ensure the proper implementation of IPSAS (when adopted). May 2013 Standards and Training 88. June 2013 Implementation of follow-up and monitoring tools July 2013 Standards and Training 89. August 2013 Implementation of a monitoring system to ease the identification of new and revised IPSAS issued by the International Public Sector Accounting Standards Board (IPSASB) and the development of related recommendations to the CSCCA. August 2013 Standards and Training Review of OCPAH s Compliance Information 90. Perform periodic review of OCPAH s response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 5 as necessary. Once updated, inform IFAC Compliance Staff so that they can republish revised information. Board and Standards Status as of of Publication Page 15 of 18

Action Plan Subject: SMO 6 Investigation and Discipline Action Plan Objective: Strengthen the Disciplinary and Investigation Mechanisms # Start Actions Completion Background: Resources OCPAH has responsibility for establishing mechanisms for investigating and disciplining (I&D) its members for misconduct and breach of the rules. The I&D mechanisms established by OCPAH are complaints and information based. These mechanisms do not include all SMO 6 requirements and do not function as intended due to financial and institutional lack of capacity. OCPAH is planning to strengthen its I&D mechanisms, in line with the SMO 6 requirements. Strengthening of the disciplinary and investigation system 90. Feb. 2013 Brainstorm on the composition of the committee and the possibility to include public authorities representatives as part of its members. Feb. 2013 Board / Disciplinary 91. Jan. 2013 Develop disciplinary procedures and a Charter. Jan. 2013 Board / Disciplinary 92. Feb. 2013 Communicate the Charter to public authorities, members, and aspiring members. Board / Disciplinary Maintaining Processes 93. June 2013 Review implementation of revised I&D mechanisms to ensure compliance with SMO 6 requirements. Board / Disciplinary 94. Monitor new and revised SMO 6 requirements issued by IFAC. Board / Disciplinary Review of OCPAH s Compliance Information 95. Perform periodic review of OCPAH s response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 6 as necessary. Once updated, inform IFAC Compliance Staff so that they can republish revised information. Board / Disciplinary Status as of of Publication Page 16 of 18

Action Plan Subject: SMO 7 - IFRS Action Plan Objective: Contribute to the Dissemination and Implementation of IFRS in Haiti # Start Actions Completion Background: Resources The law refers to the International Financial Reporting Standards (IFRS) as the accounting standards to be used in the country and CSCCA reviews and promulgates new and revised IFRS in an ongoing manner OCPAH is planning to further assist with the disseminations and implementation of the international standards. Raising Awareness of the IFRS and Communicating on the International Standards (IAS, IFRS) 95. Feb. 2013 Compilation of IFRS norms on various medias. March 2013 Board / Standards 96. Apr. 2013 Distribution of compilations of IFRS to Professional Accountants and raising OCPAH members awareness of website providing information on such standards. Apr. 2013 Board / Standards 97. Apr. 2013 Distribution of compilations of IFRS to universities where accounting is taught and raising their awareness of website providing information on such standards. 98. Apr. 2013 Publicize IFRS through issues of the OCPAH Magazine and seminars organized by OCPAH. 99. Apr. 2013 Creation of a link on the OCPAH Website that refers the reader to IFRS. 100. Apr. 2013 Encouraging Higher Education Authorities to further focus accounting education program on IFRS. Apr. 2013 Apr. 2013 Apr. 2013 Apr. 2013 Board / Standards Public Relations OCPAH Executive Management Board / Standards Organizing Training on IFRS 101. Jan. 2013 Choose themes for training seminars on IFRS. Feb. 2013 Training 102. March 2013 Design and implement a training plan on IFRS. March 2013 Training Status as of of Publication Page 17 of 18

# Start Actions Completion 103. March Identify trainers capable of delivering seminars on the themes March 2013 Training 2013 that are retained. 104. Jan. 2013 Publicize the themes of seminars and training plan. Feb. 2013 Public Relations 105. Apr. 2013 Deliver training seminars on IFRS. Sept 2013 Training Resources Encouraging Universities to Update their Training Program to Include Courses on IFRS 106. Jan.2013 Draft a curriculum that emphasizes IFRS. March 2013 Standards 107. Jan. 2013 Meet with universities that teach accounting to discuss March 2013 Standards curriculum that emphasizes IFRS. 108. Jan. 2013 Collect curricula of universities that teach accounting. March 2013 Standards 109. Apr. 2013 Propose personalized approach to each university that teaches accounting concerning to ease the implementation of the Draft Curriculum that emphasizes IFRS. June 2013 Standards Maintaining Processes 110. Jan. 2013 Develop monitoring and control tools to review implementation of new and revised IFRS. March 2013 Standards and Training 111. Jan. 2013 Implement monitoring and control tools. May 2013 Standards and Training 112. March 2013 Implement a monitoring system that facilitates the identification of new and revised IFRS and their timely dissemination and implementation. Standards and Training Review of OCPAH s Compliance Information 113. Perform periodic review of OCPAH s response to the IFAC Compliance Self-Assessment questionnaires and update sections relevant to SMO 7 as necessary. Once updated, inform IFAC Compliance Staff so that they can republish revised information. Board / Standards Status as of of Publication Page 18 of 18