Defending Dignity A Manual for National Human Rights Institutions on Monitoring Economic, Social and Cultural Rights Model Characteristics Westminster model The institution typically has a powerful head – called the auditor general – who can only be removed by the parliament. The model requires the legislature’s active participation to follow up on audit findings. Board model The institution consists of several members who form part of its governing board and report jointly to the legislature, through committees such as the Public Accounts Committee (PAC). The board might consist of multiple committees (“colleges”) specializing in certain technical areas and following different audit approaches. The board model is highly inclusive, but this can also slow decision making and the board may not always speak with one voice, which may undermine consistency. Judicial model The institution is made up of judges and is a part of the national judicial system. A key aspect of the judicial model is that government officials are held personally liable for illegal transactions. The institution judges the legality of their actions and can either “discharge” them from further liability or impose a penalty. Unlike the Westminster model, the judicial model has only a limited relationship with the legislature. The institution itself acts on its audit findings, rather than placing the audit reports of individual agencies before the legislature. Public sector audits generally take one of the following three forms. 12.4.1. Financial audits In a financial audit, the auditor verifies the accuracy and fairness of the State’s financial statements. Specifically, the auditor scrutinizes a sample of transactions to establish their authenticity and determine whether the accounts fairly present the Government’s financial affairs. The auditor’s observations are recorded in an audit report, which may list all errors and irregularities that were uncovered. In many countries, the audit report also contains a formal opinion by the auditor on whether the financial statements present a true and fair picture of the Government’s financial position and whether the receipts and payments have been applied as per the budget law. Under a Westminster model, the auditor primarily performs financial audits, rather than compliance audits. 12.4.2. Compliance audits When conducting a compliance audit, the auditor answers the following questions: • Has the expenditure been authorized by a competent authority? • Has the expenditure been authorized by the budget appropriation law and made in accordance with the terms of the law? • Does the expenditure conform to the procedures (relevant rules, regulations, and orders) promulgated under the country’s various public finance and other laws? 12.4.3. Performance audits In recent decades, auditors in some countries have broadened their mandates to include measuring “value for money”. Since the auditor seeks to report on a particular programme’s management and technical operations, performance audits are often resource intensive and require large expenditures. 122