Compliance Review Report - Hamilton Wholesalers Ltd.

i) Passing on the Subsidy

Review Objective: Verify that the recipient is passing on the value of the subsidy to consumers, i.e. that selling prices are reduced by the amount of the subsidy.

Conclusion: The recipient is passing on the subsidy to the consumer for NNC-eligible items shipped by air freight.

ii) Program Visibility

Review Objective: Verify that program visibility requirements are met (e.g. that the amount of the subsidy reduction is clearly identified on customers' invoices).

Conclusion: The review revealed that the recipient was clearly identifying the subsidy reduction on the customer invoice.

iii) Claims and Reporting

Review Objective: Test the recipients' reporting and claiming systems and procedures with regards to gap and control issues, i.e. verify that the process used by recipients to prepare detailed reports and calculate the amount of subsidy to be claimed is sound and precise, and that mechanisms to detect and correct errors are in place.

Conclusion: The review of the reporting and claiming systems and related procedures revealed that the controls were adequate to ensure the subsidy being claimed is precise and that the mechanisms to detect and correct errors were in place.

iv) Respect of Program Rules

Review Objective: Verify that recipients respect all program rules, especially in regards to sales to ineligible consumers such as mining camps or construction companies.

Conclusion: The review revealed that the recipient was respecting the program rules with respect to sales to ineligible consumers.

2.1 Background

On April 1, 2011, Nutrition North Canada (NNC) replaced the Food Mail Program, which was operated by Canada Post since the late 60's. Much like Food Mail, the purpose of NNC is to make nutritious food more accessible and more affordable to residents of isolated northern communities that lack year-round surface and marine transportation links to southern centres.

There are currently 103 communities eligible for the program (84 are eligible for a full subsidy and 19 for a partial subsidy), located in Nunavut, the Northwest Territories, Yukon, Labrador, Quebec, Ontario, Manitoba and Saskatchewan. Two levels of subsidy rates per kilogram have been established for each community; Level 1 (higher) for the most nutritious perishable foods and Level 2 (lower) for other eligible items. Communities where operating and transportation costs are higher (e.g. Grise Fiord, Nunavut) tend to have higher subsidy rates.

Northern retailers and southern suppliers registered with the program (the recipients) are responsible to manage their supply chain and claim a subsidy from NNC for eligible food and non-food items that they air ship to eligible communities. On a monthly basis, they must submit a claim form (kg x subsidy rates), a detailed shipment report (kg per item, community, client type, etc.), invoices and waybills to receive the payment (most receive advance payments based on forecasted weights). These documents are submitted to the program's claims processor under contract with AANDC (the Saskatchewan Institute of Information Technology in collaboration with Crawford). The claims processor verifies the claims and provides NNC with a recommendation for payment. Registered northern retailers must also submit, directly to NNC, a monthly pricing report for a pre-determined list of food items. These and other program requirements are identified in contribution agreements between the recipients and AANDC.

As of July 1, 2012, eight northern retailers, 25 southern suppliers and three country food processors were registered with NNC. Northern retailers are those entities that operate one or multiple food retail stores in eligible communities. Southern suppliers are food providers operating out of non-NNC communities that supply eligible items directly to small northern retailers, commercial establishments (restaurants, etc.), social institutions (daycares, etc.) and individuals (referred to as direct or personal orders) located in eligible communities. Country food processors are plants located in Cambridge Bay, Rankin Inlet and Pangnirtung in Nunavut that transform fish and meat for distribution to eligible communities within the region.

The selection of recipients for this compliance review was based on perceived risk and geographical location. Risk levels for compliance review purposes were based on the current experience with recipients regarding the claiming and reporting process, i.e. difficulties encountered by the claims processor, on information brought to the program's attention by interested parties, and on materiality. For practicality and cost-effectiveness reasons, at least two recipients have been selected per geographical location.

2.2 Objectives

The objective of the recipient compliance review is to provide assurance that the NNC recipient is in compliance with the terms and conditions of the funding agreements signed with AANDC. Specifically, the compliance review will:

1. Verify that recipients are passing on the value of the subsidy to customers, i.e. that selling prices are reduced by the amount of the subsidy;
2. Verify that program visibility requirements are met (e.g. for northern retailers, that subsidy rates are written on cash receipts and that program materials, such as posters, are clearly visible in the store, and, for southern suppliers, that the amount of the subsidy reduction is clearly identified on customers' invoices);
3. Test the recipients' reporting and claiming systems and procedures with regards to gap and control issues, i.e. verify that the process used by recipients to prepare detailed reports and calculate the amount of subsidy to be claimed is sound and precise, and that mechanisms to detect and correct errors are in place; and
4. Verify that recipients respect all program rules, especially with respect to sales to ineligible clients such as mining camps or construction companies.

2.3 Scope

The scope included the funding provided by AANDC to Hamilton Wholesalers Ltd. for the period April 1, 2012 to June 30, 2012. (NB: at the time of our onsite visit, Hamilton Wholesalers Ltd. had not submitted their July 2012 claim). The onsite review was conducted at the offices of Hamilton Wholesalers Ltd. in Happy Valley-Goose Bay, Labrador from September 17 to 20, 2012.

2.4 Approach and Methodology

The compliance review included the examination of the following:

• The pricing/invoicing practices in relation to the subsidy, e.g. profit margins on subsidized products vs. unsubsidized products;
• The weighing and shipping process;
• Accounts receivable to ensure that ineligible customers such as mining and construction companies are not receiving the subsidy;
• The sale and/or purchasing records and supporting documentation to verify compliance with program rules;
• The reporting and claiming systems and procedures, to determine how the recipient:
  • ensures that only eligible items are claimed for and reported;
  • calculates the appropriate weight of items being claimed;
  • makes monthly claims and detailed reports that are valid and accurate; and
  • ensures controls are in place to find errors and fix them on a timely basis.

Furthermore, the review included the conduct of interviews with the recipient. The sampling approach and appropriate coverage were determined during the planning phase of the review.

2.5 Conclusion

The recipient has complied with the objectives of the review.

3.1 Passing on the Subsidy

Review Objective: Verify that the recipient is passing on the value of the subsidy to consumers, i.e. that selling prices are reduced by the amount of the subsidy.

Finding: The recipient has instituted procedures to ensure that the value of the subsidy is passed on to the consumer through lower prices.

Conclusion: The recipient is passing on the subsidy to the consumer for NNC-eligible items shipped by air freight.

Observation Note #1: Hamilton Wholesalers Ltd. is a southern supplier who receives orders from northern customers by phone, fax or e-mail. Once an order is taken, it is picked up in the Hamilton Wholesalers Ltd. warehouse and subsequently shipped with the invoice, which indicates the level 1 and level 2 subsidy rebate amounts that were allocated to the order.

The selling price of items is set using the following formula: cost of item plus profit margin plus the freight cost less the subsidy rebate.

3.2 Program Visibility

Review Objective: Verify that program visibility requirements are met (e.g. that the amount of the subsidy reduction is clearly identified on customers' invoices).

Conclusion: The review revealed that the recipient was clearly identifying the subsidy reduction on the customer invoice.

3.3 Claims and Reporting

Review Objective: Test the recipients' reporting and claiming systems and procedures with regards to gap and control issues, i.e. verify that the process used by recipients to prepare detailed reports and calculate the amount of subsidy to be claimed is sound and precise, and that mechanisms to detect and correct errors are in place.

We tested the recipient's reporting and claiming procedure by selecting a random number of transactions from the total claims produced from April 1, 2012 to June 30, 2012 by using statistical sampling techniques.

Conclusion: The review of the reporting and claiming systems and related procedures revealed that the controls were adequate to ensure the subsidy being claimed is precise and that the mechanisms to detect and correct errors were in place with the following observation:

Observation Note #2: The review revealed that in one occasion, the kg per subsidy level on the May 2012 Itemized Shipment Report (ISR) sent to NNC did not reconcile to the kg per subsidy level indicated on the claim. This was due to an error in the manual entry of products sold during the month on the ISR and was not detected by the recipient because of the absence of a formal reconciliation procedure between the claims and the ISR. Since then, NNC added an additional feature in the ISR that summarizes automatically the total kg sold by level of subsidy. The totals are then compared to the claim sent to ensure accuracy of both documents.

3.4 Respect of Program Rules

Review Objective: Verify that the recipients respect all program rules, especially in regards to sales to ineligible consumers such as mining camps or construction companies.

Conclusion: The review revealed that the recipient was respecting the program rules with respect to sales to ineligible consumers.