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Update Record

DateUpdaterSummaryApprover
October 15, 2025Godfrey NoelOriginal DraftCEO

SOP Details

Business Function
Financial Management Policy
Relevant Teams
Finance, Operations
Original Author
Grants and Project Manager
Date Created
July 11, 2025
Original Approver
CEO
Current Version
1.0 — October 15, 2025

Purpose and Scope

This Financial Management Policy establishes the framework governing all financial operations, controls, and reporting processes for Kilimora CLG. The policy ensures transparent resource utilization, accountability to stakeholders including donors and investors, regulatory compliance with Kenyan law, and protection of organizational assets.

This framework applies to all employees, contractors, board members, and partners involved in financial transactions or resource management on behalf of the organization. It covers budgeting, expenditure authorization, financial reporting, audit processes, and internal controls designed to prevent fraud, mismanagement, and non-compliance with donor requirements.

Standards Alignment
This policy aligns with International Financial Reporting Standards, Kenya Companies Act requirements, donor guidelines including Global Resilience Partnership standards, and best practices for nonprofit and social enterprise financial management.

Kilimora CLG operates a cloud-based accounting system using QuickBooks Online Enterprise Edition providing real-time financial tracking, multi-currency management, and grant-specific cost allocation capabilities. All financial transactions are recorded on an accrual basis — recognizing revenue when earned and expenses when incurred regardless of cash movement timing.

01
Separate Cost Centres
Individual cost centres for each project enabling transparent tracking of restricted funds. No cross-subsidization between projects without explicit donor authorization.
02
Segregated Bank Accounts
Separate operating accounts for general funds and restricted project accounts held with Standard Bank Kenya. Online banking with dual authorization for all transactions above set thresholds.
03
Role-Based Access
Finance Manager: admin access and approval authority. Accounting staff: transaction entry only. Project managers: read-only budget visibility. No single user has end-to-end control.

Financial data is backed up daily to secure cloud storage. Some accounts are maintained in US Dollars matching primary funding currencies to reduce foreign exchange risk. Real-time dashboards accessible to project managers show budget utilization percentages, remaining balances, and expenditure trends.

Annual organizational budgets are developed through participatory processes engaging executive leadership, project managers, and the board finance committee. Budget development begins in October preceding the fiscal year with revenue projections based on confirmed grants, investor commitments, and conservative commercial revenue forecasts.

Budget Revision Thresholds

Reallocation TypeThresholdAuthorization RequiredDonor Notification
Within-category reallocationUp to 10%Finance Manager + CEONot required
Within-category reallocationOver 10%CEO + BoardAdvance written approval
Between major categoriesAny amountCEO + BoardAdvance written approval

All budget amendments are documented through formal budget revision memoranda maintaining audit trails. Project managers receive monthly budget reports showing expenditures to date, remaining balances, projected expenditures, and variance explanations for categories exceeding 5% deviation from planned spending rates.

Monthly Budget Review
The Finance Manager convenes monthly budget review meetings with project managers to address concerns and plan corrective actions for projects showing concerning spending patterns.

All expenditures require documented authorization following approval hierarchies based on transaction values. No payment may be processed without the required supporting documentation and approval signatures.

Authorization Hierarchy

AmountRequired Approver(s)Level
Below $500Project Manager — verifies budget availability and necessityLevel 1
$500 – $2,000Project Manager + Finance ManagerLevel 2
$2,000 – $5,000Project Manager + Finance Manager + CEOLevel 3
Above $5,000CEO + Board Finance Committee (capital expenditure)Level 4

Required Supporting Documentation

  • Original supplier invoice showing itemized charges
  • Delivery confirmation or service completion verification
  • Budget code indicating proper expenditure allocation
  • All required approval signatures per authorization hierarchy

Disbursement Methods

Bank Transfers
Primary method. All transfers require dual authorization — Finance Manager initiates, CEO or designated signatory approves via online banking. Amounts above $5,000 require both CEO and Board Chairperson.
Mobile Money
Permitted for amounts below $200 where bank transfers prove impractical or for populations without bank accounts. Transaction confirmations retained as payment evidence.
Petty Cash
Maximum fund of $300. No single transaction to exceed $50. May not be used for personal loans or salary advances. Monthly surprise counts by Finance Manager. No replenishment without receipts totaling withdrawal.

Payment terms with suppliers specify net 30 days from invoice receipt. Early payment discounts exceeding 2% are pursued when cash flow permits. Aged payables reports reviewed monthly.

Robust internal controls prevent fraud, error, and asset misappropriation while ensuring financial information accuracy. Segregation of duties is the foundational control principle — no single individual has complete control over any financial transaction lifecycle.

A
Finance Officer
Records transactions. Has no approval authority and cannot process payments independently. Performs monthly bank reconciliations for Finance Manager review.
B
Finance Manager
Approves expenditures and initiates bank transfers. Does not maintain physical custody of checkbooks or have sole online banking access. Reviews all reconciliations.
C
CEO
Provides secondary payment authorization only. Does not process accounting entries or perform reconciliations. Approves final reconciliations after Finance Manager review.

Asset Controls

All assets exceeding $500 individual value are tagged with identification numbers and recorded in asset registers noting acquisition date, cost, location, and responsible custodian. Annual physical asset verifications compare actual assets against register records.

System Access Controls

  • Passwords: minimum 12 characters, mixed case, numbers, special characters, mandatory change every 90 days
  • Quarterly user access reviews — permissions removed immediately for departed staff
  • Computing equipment requires password protection, encryption, and automatic timeout
  • Financial records stored in locked cabinets; electronic records in encrypted cloud storage
Unreconciled Items
Any reconciling items outstanding beyond 60 days trigger formal investigation procedures — including supplier contact, bank inquiry, and potential audit committee escalation if fraud indicators emerge.

Monthly financial statements are prepared within 15 days of month-end providing timely information for management decision-making and variance analysis. All reports are distributed to CEO, project managers, and board finance committee with narrative commentary explaining significant variances.

Standard Monthly Reports

Balance Sheet
Showing assets, liabilities, and equity positions as at month-end. Reviewed against prior month and annual budget.
Monthly
Income Statement
Comparing revenue and expenses against budget with variance percentages. Narrative commentary required for variances exceeding 5%.
Monthly
Cash Flow Statement
Tracking sources and uses of funds. Enables cash flow forecasting and early identification of liquidity concerns.
Monthly
Grant Expenditure Reports
Showing spending against each restricted fund allocation. Individually tailored to each donor's format, schedule, and content specifications.
Monthly + Donor-specific

Quarterly reports include trend analysis, ratio analysis, grant utilization analysis, and revenue pipeline projections. Annual audited financial statements are filed with donors, the Registrar of Companies, and made available to all stakeholders demonstrating transparency and accountability.

Donor Report Quality Review
All donor reports undergo internal quality review by project managers and Finance Manager before CEO approval and submission. Submission deadlines are tracked through calendar alerts with preparation initiated sufficiently in advance.

Annual external audits are conducted by independent CPAs registered with the Institute of Certified Public Accountants of Kenya (ICPAK) and meeting donor eligibility requirements. Auditor selection follows competitive procurement processes with at least three qualified firms evaluated on technical qualifications, audit approach, cost, and independence.

Audit Calendar

T-60 days
Finance Manager begins preparation — account reconciliation, documentation organization, prior audit recommendation status assessment, internal control updates.
T-30 days
Pre-audit meetings with auditors clarify expectations and establish communication protocols. Workspace, documentation access, and staff availability confirmed.
Fieldwork
Typically two weeks. Daily debriefs with auditors identify emerging issues. Management provides written representations confirming financial statement assertions.
Draft Review
Management reviews draft reports, provides additional information, corrects factual errors. Written management response letters address findings with timelines and responsible parties.
Board Presentation
Final reports presented to board finance committee and full board with auditors in attendance. Reports distributed to donors and filed with regulatory authorities.

Audit recommendations are tracked through implementation registers. Repeat findings receive heightened scrutiny with board-level discussion. External auditor rotation occurs every five years maintaining independence and bringing fresh perspectives.

Zero Tolerance Policy
Fraud, corruption, and financial misconduct result in immediate employment termination and legal prosecution where evidence warrants. This covers theft, embezzlement, falsification of records, conflict of interest violations, bribery, and unauthorized use of organizational assets for personal benefit.

Whistleblower Mechanisms

Confidential reporting channels include: direct communication with CEO or Board Chairperson, an anonymous hotline maintained by a third-party service provider, and written communication to the Board Audit Committee. Retaliation against whistleblowers is strictly prohibited. Reports are investigated promptly with findings documented.

Preventive Controls

  • Segregation of duties across all financial transaction lifecycles
  • Mandatory vacations for staff in sensitive financial positions
  • Surprise audits of high-risk areas (cash handling, procurement, payroll, expense reimbursements)
  • Vendor verification procedures confirming legitimacy before payment processing

Conflict of Interest

Annual disclosures required from all staff and board members documenting relationships with vendors, competitors, or other organizations creating potential conflicts. Procurement processes require competitive bidding and prohibit awards to entities where staff or board members hold financial interests without full board disclosure and approval.

Investigation Procedures

Suspected fraud triggers immediate investigation by CEO or external investigators for matters involving senior management. Confirmed fraud results in asset recovery efforts including insurance claims, civil litigation, or criminal prosecution depending on circumstances.

Grant management procedures ensure compliance with donor requirements throughout award lifecycles — from proposal submission through closeout. All grant-specific compliance requirements are documented in files maintained by the Finance Manager including original award agreements, approved budgets, reporting schedules, and procurement requirements.

Cost Allocation Principles

All costs charged to grants must be allowable, allocable, reasonable, and consistently applied:

Direct Costs
Costs benefiting a single project are charged entirely to that project. Examples: dedicated project staff, field equipment, direct beneficiary services.
Shared Costs
Costs benefiting multiple projects are allocated using documented methodologies: staff time percentages for salary, square footage for facilities, headcount for administrative support.
Indirect Costs
Where applicable, charged at negotiated indirect cost rates per award agreements. Allocation methodologies reviewed annually as organizational activities evolve.

Time and Effort Reporting

Staff working on multiple projects or splitting time between grant and non-grant activities complete monthly timesheets with supervisor review and approval. After-the-fact adjustments are permitted when actual time distribution differs materially from budgeted allocations, documented through Finance Manager-approved payroll journals.

Grant Closeout

Closeout begins 60 days before award end dates. Final financial reports reconcile total expenditures against approved budgets. Unexpended funds are returned to donors or approved for carryover where permitted. Grant records are retained per donor requirements, typically three to seven years.

This Financial Management Policy undergoes annual review by the Finance Manager and CEO assessing continued adequacy, compliance with regulatory changes, and incorporation of lessons learned from audit findings or operational experience.

Amendment Process

1
Proposal & Circulation
Proposed amendments circulated to board members at least 14 days before approval meetings allowing adequate review time. Includes staff feedback, regulatory comparisons, and peer organization benchmarking.
2
Board Finance Committee
Finance committee recommendation required before full board vote. Approval documented through board resolutions noting effective dates and superseded provisions.
3
Distribution & Training
Updated policy distributed to all staff. Training provided on material changes affecting daily operations. Emergency amendments by CEO are permitted pending board ratification at next scheduled meeting.
Questions & Emergency Guidance
For guidance on whether circumstances constitute genuine emergencies warranting expedited procedures, or for any question about the application of this policy, contact the organization at hello@kilimora.africa.
Finance Team — Kilimora CLG
Baraza Media Lab, Keystone Park, 95 Riverside Drive, Nairobi, Kenya