Accounts Payable (APA) - Key Controls

Question 1

APA01.1

Answer 1

Review vendor master file on an annual basis

1. Annual
2. Approval of deactivation in the past year
3. Document justification for retention if not used in last 15 months

Question 2

APA05.1

Answer 2

Review and pre-approve all purchases in line with authorization matrix

1. Transactional
2. All purchases, even intercompany, except for media
3. SOD
4. Confirm business purpose, amount, and vendor are appropriate
   
   • Vendor should be within the vendor master file & confirmation of this should be documented
5. Review
6. Can define thresholds for low spend/one off transactions where pre-authorisation is not required

Question 3

APA05.2

Answer 3

Review and match all purchase invoices to the purchase authorization (3 way match)

1. Transactional
2. All purchases, even intercompany
3. SOD
4. Agree invoice to system
5. Agree invoice to purchase authorisation
6. Investigate any differences above the OpCo’s tolerable threshold & document/approve rationale for this threshold
7. Review

Question 4

APA05.3

Answer 4

Review and approve all invoices in line with the authorization matrix (3 way match)

1. Transactional
2. SOD
3. Confirm invoice amount & that goods/services have been received from the expected vendor
4. Review

Question 5

APA05.4

Answer 5

Review and approve thresholds used for self-approved purchase pre-authorizations

1. Semi-Annual
2. SOD
3. IUC check
4. Verify
   
   • No thresholds were exceeded
   • Follow ups and resolves any exceptions
   • Documents rationale for why the threshold is still appropriate or if it should be altered
5. Review

Question 6

APA06.1

Answer 6

MRC

Review the accruals related to operating expenses to determine completeness and accuracy of the accruals.

1. Monthly
2. SOD
3. Each accrual must be validated with supporting documentation
4. Must include confirmation of completeness of accruals listing
5. Can set a threshold for recording accruals but this must be justified and a true-up must occur biannually (June and Dec)

Question 7

APA06.2

Answer 7

MRC

Review the accruals related to billable (whether disclosed as Direct costs or COGS) expense accruals

1. Monthly
2. SOD
3. Each accrual must be validated with supporting documentation
4. Must include confirmation of completeness of accruals listing
5. Recording of accruals can be done on an estimate (ie weighted average) but this must be true-ed up bi-annually (at June and Dec)

Question 8

APA07.1

Answer 8

Review and approve staff expenses by the appropriate individual per OpCo policy.

1. Transactional (although the CEO expenses must be sent to Regional on a quarterly basis)
2. Each expense item must be supported with a receipt
3. Each expense should be confirmed as a business expense in line with the OpCo/WPP policy
4. If there are participants - names of participants must be included
5. Expense items should be classified as internal or chargeable
6. Document review

Question 9

APA08.1

Answer 9

Review reconciliation of the Accounts Payable subledger to the Trial Balance and investigate differences.

1. Monthly
2. SOD
3. IUC check
4. Any differences between the AP subledger and the TB must have documented plans to resolve the differences
5. Review

Question 10

APA10.1

Answer 10

Review new supplier related party, requestor and supplier documentation

1. Transactional
2. Applicable to:
   
   • All third party vendors, with a potential exemption for national utilities vendors if there is not already an existing ethical issue
   • All intercompany entities including JVs and associates, except subsidiaries where WPP is the 100% owner
3. SOD
4. Review details of any related parties that have been disclosed
5. Review the supplier RP declaration to identify any other items for consideration
6. Approve mitigation plan if applicable
7. Document review before ordering services
8. OpCo can define a threshold for low spend or one off vendors

Question 11

APA10.2

Answer 11

Ensure that WPP Supplier Code of Business Conduct is signed by all vendors

1. Transactional
2. Applicable to all third party vendors, with a potential exemption for national utilities vendors if there is not already an existing ethical issue
3. SOD
4. Ensure Supplier CBC signed off, or obtain supplier’s CBC
   
   • If Suppliers CBC - documented review
   • APP Approved Vendor - written confirmation from WPP that vendor is approved
5. Document review before services are ordered
6. Can define a threshold for one off/low spend vendors

Question 12

APA10.3

Answer 12

Ensure that WPP Advisor Policy is complied with

1. Transactional
2. Applicable to all third party vendors
3. Control Owner must be CEO or CFO
4. The following forms must be completed:
   
   • Advisor Information Form (AIF)
   • Advisor Approval Form
   • External Due Diligence
5. Ensure sent to WPP for approval
6. Ensure approval obtained from WPP
7. Document review before ordering services

Question 13

APA10.4

Answer 13

Review and approve new supplier - Due diligence

1. Transactional
2. SOD
3. Proof of existence of supplier
4. Written confirmation of bank details
5. Include everything as required in APA 10.1, 10.2, and 10.3
6. Final approval of new vendor, if not Control Owner
7. Document review before services are ordered

Question 14

APA10.5

Answer 14

Review and approve new supplier - Advanced Due diligence

1. Transactional
2. SOD
3. Required for vendors that annual spend exceeds the annual spend thresholds per WPP Procurement Policy
4. Includes:
   
   • Enhanced searches to understand ownership
   • Enhanced creditworthiness checks
   • Reference checks
   • At least three quotations for comparable product and/or services
5. Document review before ordering services
6. OpCos can set up lower thresholds based on their own risk assessment

Question 15

APA11.1

Answer 15

Review and approve changes to vendor master file.

1. Monthly
2. Relevant for ALL vendors (ie also intercompany)
3. SOD
4. IUC check
5. All changes must be agreed to support, being:
   
   • Written confirmation from vendor for changes to details (except for bank detail changes which must be done verbally and then confirmed via email)
   • Approval from the appropriate individual for the changes to be made
   • For new vendors,
     
     • Proof of existence
     • Confirmation of bank details
6. Review