Article 1 – Purpose

The Internal Control Guidelines of the Turkey Journalists’ Union (TGS) define the purpose, objectives, components, principles, and participants necessary for the effective functioning of an internal control system.

Article 2 – Scope

These Guidelines have been prepared to ensure that activities are carried out effectively, economically, and efficiently in compliance with the TGS Charter, TGS Regulations, TGS policies, and applicable legislation; to safeguard assets and resources; to ensure that accounting records are maintained accurately and completely; and to ensure the timely and reliable production of financial and managerial information.

The target audience of the Internal Control Guidelines consists of the TGS Executive Board and employees, as well as TGS Branch executives and employees. The Guidelines also define the roles and responsibilities of personnel at all levels of TGS and non-staff individuals in achieving internal control objectives, as well as the methods by which TGS monitors and evaluates the effectiveness of internal control.

Prepared in February 2024 to allow for revision over time in line with changing conditions and needs, these Guidelines shall be reviewed annually.

Article 3 – Principles

TGS internal control is defined as a process designed to provide reasonable assurance regarding the achievement of objectives in the following categories, as influenced by the governing body, management, or other personnel of TGS:

• Effectiveness and Efficiency of Operations – These relate to the effectiveness and efficiency of program/project and operational management aimed at achieving TGS objectives, including programmatic and operational performance goals and the safeguarding of assets against loss.
• Reporting Objectives – These relate to internal and external financial and non-financial reporting and include reliability, timeliness, transparency, and other requirements set by regulators.
• Compliance Objectives – These relate to compliance with the laws and regulations to which TGS is subject, including the TGS Charter and Regulations, TGS Policy Documents, and decisions and directives of the TGS General Assembly and Executive Board.

Article 4 – Internal Control Implementation Method

Internal control, as internationally recognized, is a system designed to provide reasonable assurance for an organization to achieve its objectives. TGS has adopted the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Internal Control – Integrated Framework (“COSO Framework”), which is the most widely recognized model for implementing internal control.

Under the COSO Framework, internal control aims to ensure compliance of organizational activities with legislation, reliability of financial and managerial reporting, effectiveness and efficiency of operations, and safeguarding of assets.

This system includes five components, which serve as a tool for organizing, implementing, and evaluating the essential elements and principles of an effective internal control system:
(i) a strong control environment;
(ii) active risk assessment;
(iii) selective deployment of control activities;
(iv) effective and timely information and communication; and
(v) continuous and periodic monitoring activities.

These five components are supported by nineteen principles.

Two critical foundations are required for the implementation of internal control:

• TGS Board Members and Employees: Individuals with clearly defined objectives, authorities, roles, and responsibilities; acting in accordance with the highest standards of efficiency, competence, and integrity; receiving regular training and performance feedback; and having access to open communication channels for reporting internal control issues.
• Processes: Processes must (a) be clearly defined; (b) reduce risk through the selective application of preventive, detective, and corrective controls; (c) be regularly monitored in terms of efficiency and effectiveness (including cost-effectiveness); and (d) be continuously improved through implementation experience and audit and evaluation findings.

Article 5 – Components of the Internal Control Framework

Component 1: Control Environment

The Control Environment comprises the set of standards, processes, and structures that provide the basis for carrying out internal control across TGS. It includes setting the tone at the top regarding the importance of internal control and expected standards of conduct. It forms the foundation for all other components of internal control.
The principles supporting the Control Environment component are as follows:

1. Integrity and Ethical Values: TGS demonstrates commitment to integrity and ethical values and has established standards of ethical conduct. TGS encourages its employees to perform their duties with integrity.
2. Board Oversight: The Executive Board has adopted a supportive attitude toward internal control, and there is an Audit Board independent from management that oversees the development and implementation of internal control.
3. Structure, Authority, and Responsibility: An organizational structure, including reporting lines, assignment of responsibilities, and delegation of authority, is defined and clearly communicated to employees.
4. Human Resources Policies and Practices: Policies and procedures are established to recruit competent individuals, contribute to employee development, retain qualified staff, and evaluate performance in order to achieve TGS objectives.
5. Accountability: Policies and procedures are established to hold individuals accountable for their internal control responsibilities, including through delegation of authority, in achieving objectives.

Component 2: Risk Assessment

TGS has identified risks related to achieving its objectives by taking into account internal weaknesses and external factors.
The principles supporting the Risk Assessment component are as follows:

1. Specification of Objectives: The strategic direction and priorities of TGS have been determined.
2. Risk Identification: Risks that may impede the achievement of objectives across TGS are identified as a basis for determining how risks should be managed, including acceptance, avoidance, mitigation, or sharing of risks.
3. Risk Monitoring: Significant internal and external changes that may affect risk are identified and analyzed.

Component 3: Control Activities

Control activities are actions established through policies and procedures that help ensure that management directives to mitigate risks to the achievement of objectives are carried out. Control activities are performed at all levels of TGS and at various stages of business processes. Effective implementation of preventive and detective controls enables timely intervention.
The principles supporting the Control Activities component are as follows:

1. Selection and Development of Control Activities: Control activities that contribute to managing risks at acceptable levels are selected and developed with consideration of the operational environment. Activities and financial decisions and transactions are documented in writing and communicated to employees.
2. Segregation of Duties: Duties related to the authorization, execution, recording, and review of activities and financial decisions and transactions are distributed among personnel to reduce the risks of error, omission, irregularity, and fraud.
3. Policies and Procedures: Control procedures integrated into daily operations are developed to ensure continuity of business processes.
4. General Controls over Information Systems: General control activities over information systems are selected, developed, and evaluated to support TGS in achieving its objectives.

Component 4: Information and Communication

This component includes identifying, obtaining, or generating, and using relevant and quality information from both internal and external sources to support the functioning of other components of internal control. It also includes communicating necessary information in a form and timeframe that enable management and employees to fulfill their responsibilities.
The principles supporting the Information and Communication component are as follows:

1. Information and Reporting: Relevant and quality information is obtained or generated to support the functioning of internal controls, decision-making, oversight, and monitoring.
2. Records and Filing: TGS shall maintain an up-to-date system for recording, classifying, and filing all business and transactions, including all incoming and outgoing documents. Necessary measures for the protection of personal data are taken within the records and filing system.
3. Internal Communication: An effective and efficient internal communication system exists to ensure that employees have the information they need to perform their duties and to support the functioning of internal control.
4. Reporting of Errors, Irregularities, and Fraud: Methods are established to ensure that errors, irregularities, and fraud are reported in a structured manner.
5. External Communication: An effective and efficient external communication system exists to obtain necessary externally sourced information and to provide relevant and quality information to external stakeholders—such as contributors, partners, management, and oversight bodies—in response to requirements and expectations regarding matters affecting the functioning of internal control.

Component 5: Monitoring

Monitoring involves evaluating whether each of the five components of internal control is present and functioning. This is accomplished through ongoing monitoring activities, separate evaluations, or a combination of both.
The principles supporting the Monitoring component are as follows:

1. Ongoing and/or Separate Evaluations: Ongoing and/or separate evaluations are selected, developed, and performed to ascertain whether each component of internal control embedded within business processes is functioning effectively.
2. Reporting Internal Control Deficiencies: Deficiencies in the functioning of internal control are systematically evaluated and reported to those responsible for taking corrective action. Appropriate corrective actions to remedy reported deficiencies are implemented in a timely manner.

Article 6 – Oversight Body and Process

Article 6.1 – TGS Internal Control Scheme

Article 6.2 – Description of Operations:
The Internal Control mechanism of the Turkey Journalists’ Union (TGS) operates as follows:

Union and project personnel inform the Secretary General on a weekly basis of the activities to be carried out during that week. In addition, on a monthly basis, they prepare unit-specific report formats and submit them to the Secretary General.

The Secretary General presents monthly activity reports, and the Treasurer General presents monthly financial reports, to the agenda of the Executive Board meetings held on a monthly basis. Every six months, the Headquarters Audit Board audits all activities and financial expenditures of the Union.