Electronic purchasing card (ePC) policy

7. ePC Responsibilities and Hierarchy

7.1 There should be a clear hierarchal arrangement and chain of authorisation applied to each card. There are 3 roles required to ensure a strict separation of duties between those ordering goods and/or services and those approving them. This safeguards public funds, ensures strict compliance with government arrangements and satisfies auditory requirements. Unless agreed otherwise with the ePC Team, all members of a card hierarchy must be permanent members of staff within their organisation (SG Core and partners). The roles are:

• Card Holder – The owner and user of the card.
• Card Approver – Must be at band B level or above and at least one grade above the card holder (or equivalent in partner organisations). Reviews financial information description and, where appropriate, ensures competition quotes are attached for each transaction.
• Card Controller - Must be at least band C1 level (unless there are exceptional circumstances, in which case please contact the ePC Team via iFix - https://ifix:8443/assystnet/#serviceOfferings/817 or via the ePC mailbox if you do not have access to iFix - EPC_mailbox@gov.scot). Has the same access and rights in SDoL as an approver. If required they can undertake the role of approver (for example, to cover periods of leave or absence).

7.2 Should a hierarchy encounter difficult applying these roles, they should discuss potential alternative arrangements with the ePC Team. In such circumstances, advice will likely be sought from SG Internal Audit prior to decision.

7.3 Quarterly reviews of Hierarchy will be sent to all Card Controllers and confirmation required to ePC Team to advise if in agreement or changes required. Failure to comply may result in suspension of cards.

Mandatory responsibilities

7.4 ePCs are issued in the name of an individual card holder. It is only the card holder(the person whose name appears on the front of the card)that is permitted to undertake purchases on that card.

7.5 Card Holders must:

• Include on SDoL an appropriate description of the transaction, stating what was bought and why, correct financial information and, where relevant, attach the quotes for the purchase. Card holders must also investigate and identify any issues on charges or credits. The ePC team are only there for escalation if there is a situation that cannot be fulfilled by the supplier to the cardholders requirements
• Review each transaction for accuracy within 5 working days of appearing on SDoL (transactions usually appear on SDoL within 48 hours) or as soon as practicable.
• After reviewing the transaction notify the nominated card approver through the SDoL system (sending a message) no later than 7 working days after the transaction appears on SDoL or as soon as practicable.
• Quickly resolve any issues or inaccuracies and ensure transaction activity is sent to an approver within policy timescales.

7.6 Card Approversmust:

• Approve the transaction description, financial information on SDoL within 10 working days of the transaction appearing. They should also ensure that the cardholder has complied with competition requirements and attached, where appropriate, quotes. Card approvers are required to tick the 'approved' box on SDoL.
• If the transaction does not meet the requirements stated above, the approver should reject the transaction by unticking the reviewed box on SDoL and request the cardholder amends the transaction details. If it cannot be amended a request should be made from the relevant card controller and sent via iFIX. If they do not have access to iFIX they send to the ePC team via their business email account.

• Ensure the correct financial information has been applied to the purchase and that any VAT recovery has been actioned.
• Ensure expenditure complies with policy requirements.
• Support the card holder as required.

7.7 Card Controllers must:

• Undertake regular checks to ensure policy and procedures are adhered to and ensure that the card holder and approver(s) actively reviews ePC spend.
• Advise the ePC Team of hierarchy changes and put sufficient resource and proxy arrangements in place for card usage, monitoring and control.
• Ensure that the rules around reviewing and approving transaction activity are being applied as required and issues like splitting transactions do not occur.

7.8 Where specific issues with card usage/behaviour are identified, the card controller must bring this to the attention of the ePC Team as quickly as possible. Failure to adhere may result in card suspension or cancellation.

Proxy and Alternate arrangements

7.9 Business Managers/ Card controllers should put in place proxy arrangements to support local purchasing needs and ensure reviewing and approving responsibilities for ePC can continue uninterrupted during periods of leave or absence.

7.10 Alternative arrangements for purchasing: Identify an alternative existing card holder who can make purchases on behalf of the primary card holder and has access to assign the appropriate accounting information, for example, cost centre etc. to the primary card holder's budget. If a card holder wishes to makes a transaction on behalf of another cardholder in another Directorate, they should contact the ePC team.

7.11 Proxy arrangements for review: A proxy can be set up to undertake a card holder'sresponsibilities toreviewtransaction activity during their absence. There can be more than one proxy assigned to each card. A proxy can be assigned to different card holders.

7.12 Alternative arrangements for approval: Additional card approvers and card controllers can be assigned to approve transaction activity on behalf of another approver or controller in their absence. This ensures that the full card hierarchy are able to meet approver and controller responsibilities in a timely manner.

7.13 There can be more than one approver but only one controller assigned to each card holder, provided that this does not compromise the hierarchy needs of a card.

7.14 To set up proxy arrangements, a request should be made from the relevant card controller and sent via iFIX. If they do not have access to iFIX they should make a request from their business email account to the ePC Team. A user guide for proxy arrangements is available here.

7.20 To support a monthly review process and enable recharging of costs to business areas, all reviewing and approving of transactions must be completed by the end of the second working day of the following month. This is the cut-off point for transaction review and approval and transactions cannot be amended after this date. Failure to do so may result in transactions being allocated to the default accounting details for each cardholder.

7.21 Repeated failure to complete review and approval responsibilities will result in escalation to card controller and potential card suspension.

7.22 The reporting period for transactions is formally set from the 26^th of the month to the 25^th of the following month.

7.23 Transactions made after the 23^rd of each month are likely to be charged against the next financial month. This is because transactions may not appear on the SDoL in time for the cut-off period.

7.24 This is particularly important at the close of any financial year. Upon approval, payment is uploaded to SEAS (the SG accounting system) and recharged (or invoiced to partners not on SEAS, the core SG accounting system) to the relevant business area's budget on the fifth working day of each month.

7.25 Where discrepancies arise (and the matter has subsequently been resolved with the supplier concerned), a member of the card hierarchy should check the next expenditure period to ensure the appropriate correction appears against the relevant SDoL account, to be accurately reflected in the relevant card holder's budget.

7.26 It is the responsibility of card holders, approvers and controllers to inform the ePC Team in good time of any changes in circumstances.

Budget Centre Liaison Officers and Business Managers

7.27 SDoL is a useful source of management information on expenditure incurred by the cards in use in their area. Business areas can apply for their budget centre liaison officer (BCLO) or business manager (BM) to have access to SDoL to download reports to assist with spend reconciliation. Requests should be made to the ePC Team. Specific guidance for BCLO's and BM's is available here.