Checks and Balances

The IMC should open and maintain, in its name (for example, The Incorporated Management Committee of XXX School), at least 2 accounts (one for government funds and the other for non-government funds). All bank accounts should be operated by jointly authorized signatories. Cheques should be jointly signed by any 2 of the registered managers designated for this purpose. An IMC school shall only deposit moneys into the bank account maintained in the name of the IMC. If internet banking is used for managing and operating bank accounts, the procedures for approving payments through internet banking as well as personnel authorizing modification of access control and transaction limits should remain the same as the arrangements for cheque payments, i.e. should be jointly approved by any 2 of the registered managers designated for this purpose. In addition, the issue whether the Supervisor would be one of the authorized signatories should be discussed and decided in an IMC meeting in which the Supervisor presides.

A declaration of interests should be made in writing. An IMC manager shall, at least once in every 12 months, make to the IMC a written declaration which states the particulars of any pecuniary or other personal interests. If there is no such interest, the manager has to state so. A Sample Form for Declaration of Interests is available on the EDB website.

The IMC should appoint a certified public accountant (practicing) to audit the annual school account in accordance with section 40BB(3) and (4) of the Education Ordinance.

Any abnormal or exceptional school incidents (such as cash loss, fraud and fictitious documents, etc.) should be promptly reported to the IMC, the police and the Education Bureau.

A. Quotation and tender information should be kept confidential with restricted access on a need-to-know basis. The staff should sign an undertaking that they would not make any unauthorized disclosure of quotation or tender information
B. Cheques should not be pre-signed
C. The preparation and authorisation of payment vouchers should be conducted by different persons for internal control purpose
D. Physical checking of assets should be conducted at least once a year

A. The Hong Kong Schools Music and Speech Association and the Hong Kong Schools Sports Federation may be exempted from paying hire charges, except air-conditioning charges, when using school halls/playgrounds for holding inter-school competitions.
B. It is advisable not to levy on the non-profit-making uniformed organizations, except air-conditioning charges, for holding training/educational activities.
C. Charges should be waived on the Government departments for holding official activities, except charges for air-conditioning which is operated under non-government funding. If the school’s air-conditioning expenses are jointly funded by the Government and the school’s own resources, charges should be levied on a pro rata basis. Schools should negotiate with Government departments concerned in advance for the charges details (if any) and make necessary arrangement.
D. The use of premises in aided schools designated for polling or counting purposes pursuant to the regulations made under the Electoral Affairs Commission Ordinance (Cap. 541) should be free of charge, except electricity charges.

A. Schools should not charge unsubvented expenditure into government subvention accounts. The cost of airfare and lodging of about $20,000 for the Principal to attend a training course in the United Kingdom was charged to government subvention. According to the guidelines issued by EDB for this training, participants are responsible for their own air-tickets, board and lodging while the course fee would be sponsored by EDB.
B. Schools should not split orders to bypass proper tendering procedures. A school purchased similar furniture items totalling about $260,000 separately in twelve quotations either in the same month or within a short period thereby avoiding tendering procedures. According to EDB Circular No. 4/2013, separate tenders must be invited from at least five suppliers for procurement of stores/services exceeding $200,000 each. Schools may only make repeated procurement of the same items within 12 months by oral quotations and written quotations if the cumulative value of the procurement does not exceed $50,000 and $200,000 respectively. Schools must not split an order as a way to circumvent approval requirement or quotation/tendering procedures.
C. School should credit appropriate income from hire of accommodation to government subvention account. A school sub-let the school premises to another School Sponsoring Body for operating evening courses. The rental income so received could not be found in the school’s bank and books of accounts. A school credited the charge (over $400,000) for hiring out the school premises to the school’s own funds instead of the government funds. According to EDB Circular No. 5/2011, schools must credit 40% of the net income from the hire of school premises to the government subvention account.
D. Schools should not spend tuckshop rental income on staff welfare. An IMC approved an allocation of $25,000 from a school’s tuck shop rental income to carry out welfare activities for their staff. According to the prevailing EDB circular on Trading Operations in Schools, the profits/net income arising from trading operations, including tuckshop rental income, must be applied for the purposes directly benefiting the students of the schools as stipulated in the regulations 99A(3) and 99B(2) of the Education Regulations.