Audit of the Peace and Stabilization Operations Program

October 2020

Table of contents

Report summary

In accordance with ¶¶ÒùÊÓƵ’s approved 2019-2020 Risk-based Audit Plan, the Office of the Chief Audit Executive conducted an audit of the Peace and Stabilization Operations Program (PSOPs).

Why it is important

PSOPs is the Government of Canada’s principal platform for conflict prevention, stabilization and peacebuilding in fragile and conflict-affected states. The Program is an important vector of Canada’s values and commitments at the international level. ¶¶ÒùÊÓƵ receives $150 million annually for PSOPs, including $117.8 million to disburse through grants and contributions. PSOPs is the largest grants and contributions program within ¶¶ÒùÊÓƵ not directly related to international development.

What was examined

The objective of this audit was to determine whether an effective management control framework had been implemented for the Peace and Stabilization Operations Program to support the achievement of the Program’s objectives. This audit examined PSOPs’ management framework, including program planning and funding, project delivery, and monitoring and reporting activities. The audit focused on the last three fiscal years (2017-18 to 2019-20) but also covered projects that started in 2016-17 and were still active during that period. The audit focused on the activities of the Programing Division (IRG) and the Strategic Planning and Coordination Division (IRC), more specifically programming activities and the support provided to project officers. The audit did not look at the activities of the other two divisions. Interviews were conducted and documentation was reviewed up to and including September 2020. More details about the audit objective, scope and criteria are presented in Appendix A.

What was found

An effective management control framework has been established for the Peace and Stabilization Operations Program. A few areas for improvement were identified to further improve the effectiveness of the framework such as:

Recommendations

Recommendation 1: The Assistant Deputy Minister of International Security (IFM) should require PSOPs to systematically document and track decisions of its governance bodies in order to demonstrate effective oversight exercised over the implementation of its mandate, objectives, and strategies.

Recommendation 2: The Assistant Deputy Minister of International Security (IFM) should:

Recommendation 3: The Assistant Deputy Minister of International Security (IFM) should:

Recommendation 4: The Assistant Deputy Minister of International Security (IFM) should put measures in place to:

Statement of Conformance

The audit was conducted in conformance with the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing and with the Treasury Board Policy and Directive on Internal Audit, as supported by the results of the quality assurance and improvement program.

1. Background

In accordance with ¶¶ÒùÊÓƵ’s approved 2019-2020 Risk-based Audit Plan, the Office of the Chief Audit Executive conducted an audit of the Peace and Stabilization Operations Program (PSOPs).

In August 2016, the Government of Canada launched PSOPs as the new platform for conflict prevention, stabilization and peacebuilding. PSOPs replaced two programs: the Stabilization and Reconstruction Task Force and the Global Peace and Security Fund. It enables Canada to take rapid and coordinated action to prevent and respond to emerging and ongoing instances of violent conflict and state fragility. The Program leverages resources of, and partnerships with, multilateral institutions, non-government organizations, implementing partners, and like-minded nations. PSOPs’ core responsibilities are to:

At ¶¶ÒùÊÓƵ, the Peace and Stabilization Operations Bureau (IRD), under International Security (IFM), is responsible for the management of PSOPs through the following four divisions:

The PSOPs financial assistance envelope is $150 million annually, including $117.8 million for grant and contribution agreements. Potential recipients include: Canadian international and local non government organizations, multilateral organizations (e.g., United Nations agencies), academic institutions and foreign governments - affected States and donor countries (including their institutions, organizations, and agencies), Canadian provincial, territorial, and municipal governments, and Crown corporationsFootnote 1.

Grant agreements/arrangements are used with well-established international partners, primarily multilateral organizations of which Canada is a member. Contribution agreements/arrangements are most often used with local non government organizations, professional organizations, and some private sector organizations, but may occasionally be used with multilateral institutions. These transfer payments are subject to performance conditions specified in the implementing instrument. Contribution allocations are based on the project activities, budget, and the capacity of the organization to deliver the project.

The PSOPs Strategy is aligned with Canada’s priorities and departmental commitments. It includes, amongst others, commitments for gender equality, peace and security, conflict prevention and mediation, the Women, Peace and Security agenda, and engagement in the Middle-East. The PSOPs Strategy also aligns with the Feminist International Assistance Policy, as peace and security is one of the six action areas. The Program’s Strategy identifies priority countries in which to focus efforts.

To provide timely interventions in conflict prevention and stabilization in fragile and conflict affected states, PSOPs developed its own unique business process and Terms and Conditions, which allows for agility and flexibility. It also allows the Program to change focus when conditions evolve and to address emerging priorities. Most of the grants and contributions are delivered through unsolicited mechanism whereby potential recipients submit a concept paper requesting funding for a project under PSOPs.

PSOPs works with numerous domestic partners to implement its mandate, including: the Department of National Defence, the Canadian Armed Forces, Public Safety Canada, the Royal Canadian Mounted Police, the Department of Justice Canada, Correctional Service Canada, and other Government of Canada experts.

2. Observations and recommendations

This section sets out key findings and observations, divided into four general themes: Program Governance and Oversight, Risk Management, Program Delivery, and Monitoring and Reporting. Recommendations are provided, where appropriate. Details related to the audit approach are included in Appendix A.

2.1 Program governance and oversight

Governance committees play an important role in overseeing program delivery and ensuring effective decision-making. Accountabilities, roles and responsibilities also need to be clearly defined, communicated and exercised to avoid duplication and inefficiencies in program delivery and oversight.

The PSOPs governance structure includes two boards:

The mandates, accountabilities, and roles and responsibilities are clearly defined and communicated. Program staff also confirmed that their accountabilities, roles and responsibilities were clearly defined and communicated to them. In addition, PSOPs Strategy and its business process define each division’s accountabilities as well as individual roles and responsibilities.

A review of meeting minutes and agendas of both governance bodies demonstrated that discussions were held on PSOPs’ strategy, program policy issues, reorganization of the organizational structure, and determination of priority countries. However, meeting occurrences and record of decisions were not consistently maintained. As such, the extent of oversight exercised by these two oversight bodies could not be adequately examined to ensure full implementation of PSOPs’ objectives and strategies.

Recommendation 1

The Assistant Deputy Minister of International Security (IFM) should require PSOPs to systematically document and track decisions of its governance bodies in order to demonstrate effective oversight exercised over the implementation of its mandate, objectives, and strategies.

2.2 Risk management

PSOPs operates in volatile and challenging environments where violence, corruption, and high crime rates are prevalent. Since results are more difficult to achieve and measure in this context, the Program must accept a certain degree of risk and have an agreed level of risk tolerance.

The PSOPs Risk Management Framework was established to identify, assess and mitigate, and monitor program risks. It provides details on the governance and accountabilities related to risk management within the Program. It also describes how to assess risks and establish requirements regarding the payment terms, the level of approval required, the type of arrangement, and monitoring and reporting for each risk category and risk level.

The Risk Management Framework is incorporated into the PSOPs Performance Indicator Profile, which is based on the key program risks outlined in the PSOPs 2018 Treasury Board Submission. In addition, the PSOPs Strategy includes a section on risks and risks responses at a program-level aiming to help programs address key operational risks (Political, Security, Recipient Capacity, and Reputational risks) for the PSOPs’ Performance Information Profile.

A PSOPs Risk Management Guide is also available, as a complement to the Risk Management Framework, to provide additional guidance at project-level for project officers. The Guide describes the risk-related steps required to manage risk through each project phase.

In 2016, after Financial Resource Planning (SWP) raised concerns about PSOPs’ risk management practices, the Program committed to monitor project-level risk management practices. The Strategic Planning and Coordination Division (IRC) then started to conduct an annual compliance “spot check” exercise. This spot check exercise consists of reviewing a sample of project files from the previous fiscal year to assess compliance against the requirements of the Risk Management Guide. The resulting report describes the findings and makes recommendations to reinforce areas of improvement and feeds into the process of updating PSOPs’ Risk Management Guide and other risk management documents, as appropriate. The Strategic Planning and Coordination Division (IRC) conducted annual spot check exercises in 2017, 2018, and 2020.

However, an examination of 20 sampled project files identified inconsistencies with the requirements set in the program risk documentation:

The observations provided in this section are similar to the results of the annual spot check. For instance, the 2020 spot check exercise recommended that Deputy Directors should carefully review all project risks identified to ensure in-depth analysis of risk responses and review all risks in the fiduciary risk category to ensure they are completed correctly, with fulsome descriptions and documentation of the required recipient. In addition, the 2018 spot check recommended that project officers use the PSOPs Risk Management Guide more extensively. Finally, the last spot check exercise reiterated many findings from the first assessment conducted in 2017.

Recommendation 2

The Assistant Deputy Minister of International Security (IFM) should:

2.3 Program delivery

Key elements, such as resources, procedures, guidelines, and tools are important to support the delivery of PSOPs in a timely, effective, and consistent manner. Without these key elements, the Program may not be able to achieve its objectives.

Human Resources Capacity

In order to deliver projects in an effective and efficient manner, PSOPs management needs to maintain the appropriate human resources capacity, which means the right number of employees with the required qualifications. In recent years, PSOPs experienced challenges to fill all its positions with qualified people. As of January 3, 2020, PSOPs had 27 vacant positions out of 86. However, the PSOPs Strategy has a section on talent management acknowledging the current situation and the Program undertook a mobility planning exercise to plan for future needs. Not having the appropriate level of full-time equivalents may have negative impacts on staff and its ability to deliver quality service/program in a consistent manner.

Program Business Process

The Program developed and implemented a business process to guide project officers throughout the life cycle of a project. Project officers are expected to adhere to this guidance so that all projects are processed in a standardized manner and align with PSOPs’ objectives.

Project officers are expected to complete specific steps such as:

Based on the review of the 17 sampled projects out of 20 that the Program funded through the unsolicited mechanism, project officers did not fulfill all the listed requirements. For instance:

If project officers do not comply with the business process requirements and exercise due diligence, some projects may not meet PSOPs’ objectives.

Timeliness of project delivery

PSOPs defines itself as a rapid-response program that purposely carries out a distinct business process that takes into account the need to ensure the agility, flexibility, and higher risk tolerance required for timely and catalytic interventions in conflict prevention and stabilization in fragile and conflict-affected states. It is therefore important for the Program to measure its response time to ensure efficiency and effectiveness of project delivery. The Program did not measure timeliness of project delivery.

The audit examined 239 PSOPs projects covering the 2016-2017 to 2019-2020 fiscal years to determine if it was possible to measure timeliness for these projects. The audit identified key process steps and analyzed the overall average length of time between these key steps.

The key process step which appeared to have taken the longest time to complete was between the Project Accountability Team signatures in the Management Summary of Intent and the Assistant Deputy Minister’s signature in the Approval Memorandum. On average, it took around 3.8 months between those two points. A more detailed analysis would be required to explain the length of time between key process steps and reasons for potential delays.

The audit also examined potential impacts certain variables had on the timeliness of project delivery, including financial instruments (contribution versus grant), recipient types, nature of the project, and fiscal year. There was no significant differences when comparing average time between process steps based on these variables. Again, further analysis would be required to identify other possible factors that affect timeliness.

Measuring the timeliness of a response would provide PSOPs with the ability to understand and better manage project implementation through identification of process stranglehold to resolve them and improve strategic planning to determine appropriate timing to launch projects.  Furthermore, if the recipient obtains funding in a timely manner, it would improve the achievement of the program’s objectives.

Recommendation 3

The Assistant Deputy Minister of International Security (IFM) should:

2.4 Monitoring and reporting

It is important that project officers monitor projects closely to ensure that they align with PSOPs’ mandate and Government of Canada priorities throughout their life cycle, the results achieved meet program objectives, and the recipient spent the allocated funds appropriately in compliance with the terms and conditions of the funding agreement. PSOPs senior management also needs to receive the most complete, accurate, and up-to-date information in order to make informed decisions to ensure that PSOPs fulfills its mandate and meets its objectives.

Monitoring

Almost all of the sampled projects were aligned with PSOPs’ mandate and all of them included monitoring mechanisms in the funding agreement. However, there is insufficient evidence demonstrating that project officers monitored project activities. In addition, some key financial documents were also missing from the electronic files, which could prevent project officers from exercising proper financial due diligence.

Nineteen (19) of the 20 sampled projects aligned with the Program’s mandate. The only exception was politically driven, which is beyond the Program’s control. As for the funding agreements, all of them included monitoring mechanisms to enable project officers to monitor project activities. Nineteen (19) of the 20 funding agreements reviewed indicated the frequency and content of the reports that the recipient needed to provide during the project life cycle as well as the conditions of payment with the supporting documentation to be provided. The remaining funding agreement did not require the provision of financial reports.

Based on the review of the 19 sampled projects that required reports, all the required reports were in the electronic files but there were insufficient evidence to determine if and how project officers reviewed these reports. For 12 projects, the project officer had documented its review of financial and narrative reports. However, the only evidence of review on file was clarification emails between program officers and recipients. For the remaining seven (7) projects, the project officer did not document its review at all. It should be noted that neither the PSOPs’ Terms and Conditions nor the business process include formal requirements to document the review of reports. In order to strengthen monitoring practices, the project officer’s review of financial and narrative reports could be more systematically documented. If project officers do not document their review of narrative and financial reports, they cannot clearly demonstrate that the recipients achieved PSOPs’ objectives and spent the allocated funds as required by the funding agreement.

In addition to the aforementioned reports, the recipient also has to provide a completed payment request, including a cash flow statement outlining how funds are going to be used, to receive payments. For four (4) of the 20 sampled projects, the project file did not include a cash flow statement. If project officers did not systematically save cash flow statements in their electronic file, it is difficult to assess whether payments were made as planned and for the intended purposes.

Reporting

The Performance Information Profile is the tool supporting senior management in coordinating program performance information requirements. The Performance Information Profile outlines the outputs, outcomes, and indicators used to measure, manage against, and report on the Program’s performance. The Program’s Performance Information Profile provides a performance measurement framework to measure and assess performance against expected results and articulates how PSOPs programming implements departmental priorities and action areas identified in the Feminist International Assistance Policy.

As per departmental international assistance annual reporting requirements, the Program must complete Management Summary Reports. The Management Summary Reports are used to provide outcomes information to meet several reporting requirements, such as the Report on Canada’s International Assistance, and support senior management’s decision-making. As such, project officers report on project results using the standard report template and data from reports provided by recipients.

At the time of the audit, the most recent Management Summary Reports were for 2018-2019. Fourteen (14) of the 20 sampled projects required a Management Summary Report but five (5) projects did not have one. For the remaining nine (9) projects, three (3) had full and complete performance information while six (6) only had minimal information. If project officers do not fully complete the required reports, the quality of the information for decision-making will be incomplete and senior management will not have full information and be able to exercise appropriate oversight over how funds are used to achieve program and departmental objectives.

Recommendation 4

The Assistant Deputy Minister of International Security (IFM) should put measures in place to:

3. Conclusion

An effective management control framework has been established for the Peace and Stabilization Operations Program. A few areas for improvement were identified to further improve the effectiveness of the framework such as:

Appendix A: About the audit

Objective

The objective of this audit was to determine whether an effective management control framework had been implemented for the Peace and Stabilization Operations Program to support the achievement of the Program’s objectives.

Scope

This audit examined PSOPs’ management control framework, including program planning and funding, project delivery and monitoring, and performance measurement and reporting activities. The audit focused on the last three fiscal years (2017-2018 to 2019-2020). However, to gain a more complete understanding of the subject matter of the audit, relevant material outside this period was also analyzed, most notably projects that started in 2016-2017 and were still active during that period. The audit focused on the activities of the Programing Division (IRG) and the Strategic Planning and Coordination Division (IRC), more specifically programming activities and the support provided to project officers. Interviews were conducted and documentation was reviewed up to and including September 2020.

Criteria

The criteria were developed following the completion of the detailed risk assessment and considered the audit criteria related to the Management Accountability Framework developed by the Office of Comptroller General of the Treasury Board Secretariat. The audit criteria were discussed and agreed upon with the auditees. The detailed criteria are presented as follows.

Audit Criteria are reasonable and attainable expectations against which compliance, the adequacy of controls and overall performance are assessed. These audit criteria are based on acts and regulations, policy, guidelines, generally recognized industry norms, results of previous audits or other criteria developed in consultation with Program management. The following criteria were assessed during this audit and form the basis for developing audit observations and recommendations.

Met – the audit evidence sufficiently supports the audit criteria’s expectations as being met (for example, appropriate controls found (and are commensurate with the risk) and they are operating effectively).

Partially met – the audit evidence mostly supports the audit criteria’s expectations but improvements are required – (for example, some controls in place and some are operating effectively – recommendations made)

Not met – the audit evidence is insufficient to support the audit criteria’s expectations – (for example, controls not in place or not operating effectively – risk exposure is high - recommendations made – other action taken as required)

CriteriaMet / Partially Met / Not Met
1. The Program has established an effective governance structure to manage its operations.Partially Met
1.1 The Program has established governance committees to oversee programming and support effective decision-making.Partially Met
1.2 Accountabilities, roles and responsibilities of program divisions are clearly defined, communicated and exercised.Met
2. The Program has established a risk management framework to identify, assess, mitigate, and monitor program and project risks throughout their life cycle.Partially met
3. The Program has resources, procedures, guidelines, and tools in place to support the delivery of the program in a timely, effective, and consistent manner.Partially Met
3.1 The Program maintains sufficient capacity to ensure timely and effective program delivery.Met
3.2 The Program has controls to ensure that procedures, guidelines, and tools are used in a consistent manner.Partially Met
4. The Program has controls to ensure that projects are delivered and monitored in accordance with program objectives and are in compliance with project agreements, terms and conditions, and applicable policies.Partially met
4.1 The Program ensures that the programming and funding processes are designed to support its objectives and the Government of Canada’s priorities.Met
4.2 The Program monitors projects throughout their lifecycle to ensure that they are delivered in compliance with their project agreements, program’s terms and conditions, and applicable policies.Partially met
5. The Program’s performance management framework supports informed decision-making.Partially Met
5.1 The Program collects, records and analyzes financial and non-financial information to measure program results.Partially Met
5.2 The Program reports financial and non-financial information to support informed decision-making.Partially Met

Approach and Methodology

The audit was conducted in conformity with the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing and with the Treasury Board Policy and Directive on Internal Audit. These standards require that the audit be planned and performed in such a way as to obtain reasonable assurance that the audit objective was achieved. 

To conclude on the above criteria, the following methods were used to gather evidence:

The audit selected a sample of 20 projects (including five (5) grants and 15 contributions) that were active within the last three fiscal years (2017-2018, 2018-2019, and 2019-2020) to assess whether the Program met the audit criteria. However, it should be noted that due to the COVID-19 pandemic, the audit did not have access to departmental facilities where the Program stores its hard copy files. Therefore, the audit cannot comment on the structure, content, and relevance of these hard copy files.

See Appendix C for the list of sampled projects.

Appendix B: Management action plan

Audit recommendationManagement responseManagement action planArea responsibleExpected completion date (Month and year)
1. The Assistant Deputy Minister of International Security (IFM) should require PSOPs to systematically document and track decisions of its governance bodies in order to demonstrate effective oversight exercised over the implementation of its mandate, objectives, and strategiesManagement agrees with the recommendation.1.1 Designate a division to act as the secretariat for the PSOPs governance bodies; this secretariat will plan meetings and systematically document and track decisions to ensure that oversight is effectively exercised. The secretariat will ensure that a designated note taker is assigned for each meeting with the responsibility to keep minutes and save all relevant documentation (agenda, records of decision) in the appropriate Infobank folder.ADM of International SecurityNovember 2020

2. The Assistant Deputy Minister of International Security (IFM) should:

  • Establish measures to improve and better document program compliance with the PSOPs Risk Management Guide; and
  • Implement the recommendations formulated in the spot check exercises and monitor their effectiveness.
Management agrees with the recommendation.2.1 The recommendations of the PSOPs Program audit, as well as the annual PSOPs risk spot check exercise (formally known as the Risk Management Compliance Assessment) will be implemented by undertaking measures such as updating the PSOPs Risk Management Guide, adjusting the tools and templates that document compliance, and revising training for project officers as appropriate. These measures will include appropriate oversight to ensure PSOPs is documenting the assessment and monitoring of project risks per guidelines.ADM of International SecurityJune 2021
2.2 The annual PSOPs risk spot check exercise will be expanded to monitor the effectiveness of measures taken to improve the PSOPs risk management practices.June 2021

3. The Assistant Deputy Minister of International Security (IFM) should:

  • Establish measures to improve and better document program compliance with the PSOPs business process; and
  • Develop the capacity to measure and monitor the timeliness of project funding implementation to ensure efficiency and effectiveness of project delivery.
Management agrees with the recommendation.3.1 Establish an annual PSOPs business process spot check exercise, modeled on the annual PSOPs risk spot check, that will monitor compliance of project officers with the PSOPs business process; findings of the spot check will inform continuous updates to PSOPs tools, business process guidance, training, learning and other measures as appropriate to improve compliance. These measures will include appropriate oversight to ensure PSOPs is documenting the completion of all required steps of the business process per guidelines.ADM of International SecurityApril 2021
3.2 Functionality for tracking “key dates” will be built into existing and future project management systems (such as the Security and Stability Project Management Tool (SSPMT) Application) to ensure that PSOPs has the capacity to measure the timeliness of project funding implementation. PSOPs will also monitor this data as part of the annual spot check process and recommend adjustments to business processes as needed to address any key deficiencies impacting efficient program delivery.June 2021

4. The Assistant Deputy Minister of International Security (IFM) should put measures in place to:

  • Document project files, including monitoring activities, in a complete, consistent, and effective manner; and
  • Properly review and report performance information as per departmental requirements.
Management agrees with the recommendation.4.1 Guidance for monitoring and reporting will be updated in the PSOPs Business Process Chapters to ensure that project officers have clear instructions on how to manage and monitor projects and document project files. These changes will include a requirement for officers to explicitly document their review of project reports.ADM of International SecurityMay 2021
4.2 Compliance with these new monitoring and reporting practices will be included in the new annual PSOPs Business Process spot check exercise described in 3.1 (above). PSOPs will also continue to monitor the quality of project-level performance reporting when reviewing officer’s MSR+ reports, as part of the Annual Reporting Exercise.May 2021

Appendix C: Projects selected as part of the sample (20)

Country/ThematicName of the projectRecipientType
Mali (and Niger, Burkina Faso)Arms and Ammunition Management for More Stability in the Sahel RegionMine Advisory Group MAGContribution
MaliStabilize Mali Through the Truth, Justice and Reconciliation CommissionAvocats sans frontièresContribution
MaliSupport to MINUSMA Trust Fund-MaliUN MultidimensionalGrant
ColombiaIncreasing national and local capacity for the implementation of the prospective peace agreement in ColombiaInternational Organization for Migration (IOM)Contribution
ColombiaPeace Process in Colombia: Building Confidence in Transitional JusticeLWBC - Lawyers Without Borders CanadaContribution
ColombiaOrganization of American States' MissionOAS - Organization of American StatesContribution
Ukraine Police Training Assistance ProjectAgriteam Canada Consulting LimitedContribution
UkraineFunds for the 2016-2017 Italy EarthquakesCanadian Red CrossGrant
UkraineBridging the Information Gap Between Government and Non-Government Controlled Regions of UkraineInternational Republican Institute (IRI)Contribution
HaïtiImproving Security in Haiti through Relationship Building in the CommunityMercy Corps – International NGOContribution
Middle-East: SyriaCivil Defence (The White Helmets) in SyriaStitching Mayday Rescue FoundationContribution
Middle-East: IraqExplosive Hazard Clearance in Mosul DistrictSwiss Foundation for Mine ActionContribution
Middle-East: LebanonEnhancing community security and access to Justice in Lebanese host communitiesUNDPGrant
Middle-East: YemenPromoting Women’s Inclusion in Peace and Stabilization in YemenSearch for Common GroundContribution
Middle-East: IraqCommunity Policing in Liberated Areas of IraqInternational Organization for Migration (IOM)Grant
Thematic - Asia: Peaceful Pluralism, Diversity and Human RightsBuilding a Culture of Peaceful Pluralism in Myanmar and Sri LankaInternews NetworkContribution
Thematic - Asia: Women Peace and SecurityWomen Peacebuilders' Network on the Korean PeninsulaNobel Women's InitiativeContribution
Thematic – Global: Peace Operations, Conflict Prevention and MediationMediation Rapid ResponseCentre for Humanitarian Dialogue (HD)Contribution
Thematic – Syria: Protection of Civilians and Transitional JusticeERW Clearance Southern De-Escalation Zone SyriaStichting Mayday Rescue FoundationContribution
Thematic – Global: Peace Operations, Conflict Prevention and MediationUnited Nations Peacebuilding FundUnited Nations Peacebuilding FundGrant
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