For the purposes of resource integration between public sector and private sector, encouragement of purchasing green products and participating environmental protection activities, leading the public to live a sustainable lifestyle, expansion of the green consumer market, and promotion of the green economy, Green Point Collection Program (“the Program”) was officially launched by the Environmental Protection Administration (“EPA”) in December 2015. So far, the preliminary achievements have been obtained. As of November 29, 2020, 547,548 members registered with the Program and a number of well-known merchants joined the Program as the designated institutions. Through the implementation of the Program, the key factors which affect the effectiveness of the Program have been identified, including the participation of actors from different industries, collaboration between public sector and private sector, the enhancement in number of member and the designated institutions. Given that the members registered with the Program, designated institutions and relevant transactions have significantly increased, it was necessary to review and adjust the supervision and inspection mechanism of the Program and to ensure the continuous implementation of such supervision and inspection so as to reduce the risk and issues related to the financial settlement operation or regulations and to enhance the protection and to consolidate the trust of all stakeholders, such as consumers. Given the considerations abovementioned, the Project for Supervision and Inspection of Green Point Collection Program (“Project”) was proposed.
A. Audit and Supervision
Regarding the audit and supervision, the Project team has performed the tasks according to the “Operation Procedures for Management of Supervision and Audit of Green Point Collection Program” to review whether there is any discrepancy between the plan of Program and the actual performance.
a. Cash Flow Audit
Regarding audit of cash flow, the Project team verified the monthly transaction data of the designated institutions, and separately conducted the detailed list of capital changes issued by the trust institution, sampled 20% of the total transaction amount of the current expenditure and the 25% of the designated institutions, which actually request funds, of the current period. The result shows that the remittance amount and remittance date of the trust institution are consistent with the remittance amount and remittance date stated in the bank's batch remittance schedule, and the payment made to the designated institutions generally complies with the “Operation Procedures for Management of Supervision and Audit of Green Point Collection Program”.
b. Information Audit
Regarding information audit, the Project team conducted information audit on a monthly basis. The Project team filed the result report and recommendation based on the performance review of the information security management, information process and system operation and the external system interfacing of Green Point Collection Program Platform. The Project team assisted the Green Point Collection Program Application to pass the information Security Testing and obtain the test certificate.
B. Review of the legal framework
Regarding the maintenance of legal work, in addition to assisting the EPA to revise the “Operation Rule of the Subsidy of the Green Point Collection Program”, this Project also assists the EPA to review and revise above 10 copies of contracts or relevant documents, including the format of the visit report and the contract of the special agency of the Program, etc. Otherwise, the Project also made suggestions to the EPA on the protection of the rights and interests of members of the Program, including addition the notice of personal information protection, the solution to the inconsistent of the present of product in APP and the actual product available in the stores, and the handling the problem of the failure of the special agency to issue raffle tickets and abnormal membership registration. This Project also assists in reviewing the legality of the content of the publicity of various activities.
C. Improving of the Policy
This project mainly handles the impact assessment of the cooperation between the AMOT Association and the “Traceable Restaurant” on the EPA, and provides a template of inter-agency cooperation memorandum as a basis for negotiating cooperation. For the cooperation part of the electronic ticket data transfer, this Project chooses EasyCard Corp. to sign the contract and pay the data processing fee. Combined with other platform cooperation programs, the point charity donation program has been officially launched. This Project has completed the legal analysis of the independent operation of the Program and the pre-operation planning, and completed the revision of relevant documents according to the reviewing opinions.