Audit of the Indigenous Art Collection

Internal Audit Report
Prepared by: Audit and Assurance Services Branch
November 2024

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Table of contents

Acronyms

CCI
Canadian Conservation Institute
CIRNAC
Crown-Indigenous Relations and Northern Affairs Canada
Collection
Indigenous Art Collection
IAC
Indigenous Art Centre
PSPC
Public Services and Procurement Canada
TB
Treasury Board of Canada

Executive Summary

Background

Established in 1965, the Indigenous Art Centre (IAC) supports the acquisition, preservation, protection, and promotion of contemporary Canadian Indigenous Art. The IAC oversees the Indigenous Art Collection (Collection), a significant federal heritage collection consisting of 5,176 works valued at approximately $14.4 million and represents a diverse range of art forms from prominent, mid-career, and emerging First Nations, Métis, and Inuit artists.

In 2022, the IAC began relocating the Collection to a temporary Public Services and Procurement Canada (PSPC) storage facility located within the National Capital Region (NCR) as the previous storage facility was going through renovations. In addition to the PSPC storage facility, the IAC stores a portion of the Collection at third party storage facilities owned by private sector vendors.

As part of its roles and responsibilities to protect, preserve, and promote Indigenous Art within the Collection, the IAC is expected to adhere to a various requirements set out through its initial program authority granted by the Government in 1990, as well as the Treasury Board (TB) Policy on Planning and Management of Investments, Directive on the Management of Material, and criteria set forth through Heritage Canada's Moveable Cultural Property Program.

Objective and Scope

The audit objective was to assess the adequacy of the management control framework in place to acquire, preserve, protect, promote, and de-accessFootnote 1 and/or dispose of the art pieces held within the IAC.

The scope of the audit covered the management control framework in place within the Collection that support the acquisition, preservation, protection, and promotion of contemporary Canadian Indigenous Art. Specifically, the audit examined the assignment of roles, responsibilities, accountabilities, and the oversight and governance mechanisms of the Collection. Additionally, the audit examined the processes and procedures in place to measure the achievement of the IAC objectives as well as the processes in place to inform funding decisions.

The audit covered the period from April 1, 2019, to August 31, 2024, for controls relating to acquisition and loans transactions on sample basis. Additionally, the audit performed on site activities at a temporary storage facility in June 2024 and at a third-party art storage facility in August 2024 to provide assurance related to the physical and environmental controls in place. The other third-party storage was excluded from the scope of the audit due to the low dollar value/relatively small portion of works stored there.

Findings and Conclusion

Overall, the audit found that the Department has implemented partial components of a management control framework to support activities related to the acquisition, preservation, promotion, de-accession, and disposition of Indigenous art within the Collection. Within the IAC, roles and responsibilities have been assigned to operate the Collection with systems in place to support the recordkeeping of art pieces. Additionally, the setup of the temporary storage facility addressed some prior concerns related to preservation and protection that were identified through inspections of the prior storage space. The IAC have recently established emergency management and integrated pest management plans.

While some components of the management control framework were in place, the audit observed several opportunities for improvement. Specifically, the audit observed that the IAC's key policy instruments remain in draft or were outdated. There was also a lack of clarity in oversight roles and responsibilities and limited reporting into senior management on IAC activities. The audit also observed that a portion of the Collection is being stored at a third-party storage facility owned and managed by a vendor due to space limitations in the temporary storage location, however no contract was in place to manage and oversee the services received and ensure that the Collection is being safeguarded in accordance with IAC's requirements.

The audit also observed that the Department does not have an up-to-date plan for sustaining the Collection over its life-cycle (planning and acquisition through to the de-accession of the artworks held within the Collection) nor were there processes in place to identify and estimate holistic costs required to sustain operations in compliance with all its requirements.

Additionally, the audit observed opportunities to strength its internal controls to manage the Collection, including proper retention of documentation to demonstrate the proper function of its physical security, environmental, and recordkeeping controls.

Recommendations

The audit has the following recommendations:

  1. The Corporate Secretary should ensure that its policy instruments for the management of the Indigenous Art Collection are updated, approved, and implemented with clearly defined roles and responsibilities for protection, preservation, and promotion activities in accordance with the TB Directive on Material Management and acceptable standards for the care of assets with heritage value.
  2. The Corporate Secretary should review the continued need to outsource additional storage space over immediate and longer-term timelines and ensure that an appropriate contractual framework be put in place to manage risks related to third party storage of the Indigenous Art Collection.
  3. The Corporate Secretary should implement monitoring and oversight processes to ensure that appropriate levels of senior management are aware of matters regarding the management of the Indigenous Art Collection, including adherence to its approved policy instruments.
  4. The Corporate Secretary should:
    1. Perform a baseline costing analysis to identify the levels of effort and associated costs for implementing and complying with current acceptable standards regarding protection, preservation, and promotion requirements over the life cycle of the art pieces within the Indigenous Art Collection and use it for budgeting purposes; and
    2. Implement processes to periodically update cost analysis.
  5. The Corporate Secretary should ensure that physical security, environmental, and recordkeeping controls are suitably designed and are operating in accordance with its policy instruments and acceptable standards for the care of assets with heritage value, and that sufficient documentation is retained to demonstrate that controls are properly implemented and effectively operating.

Additional Considerations

As the Department considers its options to invest resources to address the opportunities for improvement noted throughout this report, it should also consider the extent to which the Indigenous Art Collection is best suited to remain under the purview of Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC). These considerations should be made in consultation with the IAC's key stakeholders.

Statement of Conformance

The audit conforms with the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing and the Government of Canada's Policy on Internal Audit, as supported by the results of the Quality Assurance and Improvement Program.

Management's Response

Management is in agreement with the findings, has accepted the recommendations included in the report, and has developed a management action plan to address them. The management action plan has been integrated into this report.

1. Context

About the Indigenous Art Collection

The Indigenous Art Centre (IAC) was created in 1965 to support the creation, preservation, and promotion of contemporary Canadian Indigenous Art. Through the IAC, Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) is entrusted with the care, development, and promotion of the Indigenous Art Collection (the Collection), one of the most important collections of contemporary Indigenous art in Canada. It is also a federal heritage collection and carries forward the legacy of contemporary Indigenous art in Canada.

In 1990, the IAC was granted a program authority to fund a program for the acquisition of Indigenous Art for the purpose of displays, exhibitions and loan in support of promoting an emerging art form, as well as a maintenance program to preserve the Collection. Through its program, the IAC aims to support CIRNAC's mandate by creating a visual awareness of Indigenous people, their history, and current issues. The IAC achieves its mandate through various acquisition programs and promotion of artworks in displays, exhibitions, and publications, and external art lending programs.

In 2022, the Collection began to be relocated to a Public Services and Procurement Canada (PSPC) storage facility located within the National Capital Region (NCR) due to the renovations set to occur at the Collection's previous storage facility. The Collection's storage within the PSPC storage facility is not permanent, and as of August 2024, the relocation of the Collection was ongoing. In addition to the PSPC temporary storage facility, the IAC stores a portion of the Collection at third party storage facilities owned by private sector vendors.

The Collection consisted of 5,176 works, with a reported total collection value of approximately $14.4 MillionFootnote 2. The Collection includes regional representation from prominent, mid-career, and emerging First Nations, Métis, and Inuit artists, and spans a number of art media forms.

Appendix B provides a timeline of key events of the Program.

Overview of Funding

Funding is provided to the Collection through A-Base funding (Annual Based), which has remained relatively stable with no substantive increases since the initial program authority was granted in 1990. The Collection may receive additional funding through funding requests in certain situations such as when the Collection needed to be transferred to a new storage location. Table 1 below includes total annual expenditures for the Collection throughout the in-scope audit period.

Table 1: Indigenous Art Collection Expenditures
Category 2018-19 2019-20 2020-21 2021-22 2022-23 2023-24
Salary $331,557 $519,991 $608,971 $672,909 $602,582 $752,214
Operations and Maintenance $818,850 $417,677 $1,359,295 $249,173 $639,589 $407,875
Total $1,150,407 $937,668 $1,968,266 $922,082 $1,242,171 $1,160,089

Departmental Roles and Responsibilities

The IAC is within CIRNAC's Corporate Secretariat and is tasked with various activities involved in the management of the Collection including acquiring, documenting, preserving, promoting and de-accessing art pieces (refer to Appendix C for additional detail).

  • Acquisition: Artwork acquired through the transfer of ownership.
  • Recordkeeping: Artwork is documented and catalogued using museum collections standards.
  • Preservation & Conservation: Ongoing monitoring and maintenance of the Collection using physical and environmental controls.
  • Promotion: Loaning of artwork for display and exhibition.
  • De-accession and Disposal: Transferred to other institutions or disposition through destructionFootnote 3.

Additionally, the Chief Finances, Results and Delivery Officer (CFRDO) within Indigenous Services Canada (ISC) provides several supporting services to CIRNAC through a service level agreement (SLA), including material and asset management, real property management, and security and emergency services.

As part of its roles and responsibilities to protect, preserve, and promote Indigenous Art within the Collection, the IAC is expected to adhere to various requirements set out through its initial program authority granted by the Government in 1990, as well as the Treasury Board (TB) Policy on Planning and Management of Investments, Directive on the Management of Material, and criteria set forth through Heritage Canada's Moveable Cultural Property Program.

2. About the Audit

The Audit of the Indigenous Art Collection was included in the Crown-Indigenous Relations and Northern Affairs Canada approved 2022-2023 to 2023-2024 Risk-Based Audit Plan.

2.1 Why It Is Important

The audit was identified as a priority because of several risks noted by the Department. In 2019, a need to eliminate the threat of damage to the Collection was identified following Public Services and Procurement Canada (PSPC's) announcement of Les Terrasses de la Chaudière (LTDLC) complex renovations, and as such, the Department moved the Collection to a temporary storage facility. The Department is currently in the process of identifying and relocating the collection to a permanent location.

As part of a fraud risk assessment performed by the Department, key risks were identified related to the completeness of the Indigenous Art Collection inventory and physical security controls in place to safeguard the Collection, both during and after the relocation to the temporary storage facility. Mishandling of culturally important art pieces held within the Collection poses a reputational risk and could adversely impact the Department's relationship with Indigenous stakeholders.

Assurance in this area can help address risks that the Collection is not being appropriately preserved, protected, and promoted in a manner consistent with relevant policies and standards for the preservation, protection, and promotion of assets of heritage value.

2.2 Audit Objective

The audit objective was to assess the adequacy of the management control framework in place to acquire, preserve, protect, promote, de-access and dispose of the art pieces held within the Indigenous Art Collection. Specifically, the audit will provide assurance that:

  • Governance and oversight mechanisms are implemented to ensure the Collection is being managed in accordance with Treasury Board of Canada (TB) policies and departmental directives and that roles, responsibilities, and accountabilities are defined and effectively carried out;
  • Adequate processes are implemented to support the determination of costs required to sustain operations related to acquisition, preservation, protection, promotion, de-accession, and disposal of art pieces; and
  • Effective key controls are implemented to support the acquisition, preservation, protection, recordkeeping, promotion, de-accession and disposal of art pieces over their lifecycle in accordance with TB policies and Departmental directives.

2.3 Audit Scope

The scope of the audit covered the management control framework in place within the Collection that supports the acquisition, preservation, protection, and promotion of contemporary Canadian Indigenous Art. Specifically, the audit examined the assignment of roles, responsibilities, accountabilities, and the oversight and governance mechanisms of the Collection. The audit examined the processes in place to determine the estimated costs to sustain operations related to the various activities throughout the lifecycle management of the Collection. The audit also examined the processes in place to inform funding decisions. Additionally, the effectiveness of the controls currently in place to acquire, preserve (includes the environmental controls), protect (includes the physical security controls), promote, de-access and dispose of the art pieces held within the Collection was assessed. The audit also examined the management control frameworks, including the processes and procedures in place to measure the achievement of the IAC objectives.

The audit covered the period from April 1, 2019, to August 31, 2024, for controls relating to acquisition and loans transactions on a sample basis. Additionally, the audit performed on-site activities at the temporary storage facility in June 2024 which held 3,985 artworks valued at approximately $11M and at a third-party art storage facility in August 2024 which held 930 artworks valued at approximately $2.2M to provide assurance related to the physical and environmental controls in place. The audit scope excluded performing inspections at one of third storage location, which at the time of the audit held ten (10) art pieces with total value under $200k and also excluded inspections at the Vault which included 44 artworks valued at $10K. These locations were excluded due to the relatively low number of art pieces and their valueFootnote 4.

As part of the audit, a sample of art pieces was selected based on location, type, and value among other factors to verify the existence, noticeable signs of damage, and accuracy of the record keeping system (Mimsy XG).

2.4 Audit Approach and Methodology

The audit was conducted in accordance with the requirements of the TB Policy on Internal Audit and followed the Institute of Internal Auditors International Professional Practices Framework. The audit examined sufficient, relevant evidence and obtained sufficient information to provide a reasonable level of assurance in support of the audit conclusion.

The audit fieldwork was performed from October 2023 to September 2024 and consisted of three phases: planning, conduct and reporting. The main audit techniques used included:

  • Inquiry of Management;
  • Inspection of relevant documents;
  • Physical observations of sample of art pieces within the collection stored at temporary storage and third-party storage locations;
  • Walkthrough of physical security and environmental controls in place at temporary storage and third-party storage facilities; and
  • Testing sample of acquisition and loan transactions.

The audit criteria used to perform the audit can be found in Appendix A.

3. Key Findings and Recommendations

3.1 Governance and Oversight Mechanisms

Criteria 1: Effective governance and oversight mechanisms are implemented to ensure the Collection is being managed in accordance with Treasury Board (TB) policies and Departmental directives.

Background

In 1990, a program authority decision was received from the TB with regards to the acquisition of Indigenous Art and the ongoing maintenance and preservation of the Collection. Within the decision, key requirements were identified applicable to the management of the Collection which included but were not limited to:

  • The independent evaluation of the condition of the Collection on an annual basis;
  • Maintenance and storage of artworks are based on acceptable Museum/Gallery Standards; and
  • Works of art are stored in a risk-free environmentally controlled room which has been certified by the Canadian Conservation Institute (CCI).

Furthermore, the TB Directive on the Management of Material expects departments to have a senior designated official responsible for identifying and protecting all assets that have heritage value, including Indigenous artifacts and assets that have cultural significance to Canadians.

Additional requirements were outlined by the Department of Canadian Heritage (PCH) under the Movable Cultural Property Grants Program. PCH provides a Category A designation within the Movable Cultural Property Program to facilities of organizations that are able to demonstrate that they have the capacity to properly care for and preserve over the long-term cultural property. By receiving this designation, organizations are able to collect objects of outstanding significance and national importance. An additional benefit to receiving the Category A designation is that this assures donors of art pieces of the credibility and standards of the facility storing the artwork. To receive the designation, a technical assessment of the organization's facilities must be performed by the CCI related to the facilities management, fire safety, and security measures. PCH defines assessment criteria that organizations are assessed against to receive the Category A designation, which includes but is not limited to:

  • Policies/Plans: Should have comprehensive and up-to-date written policies, plans, and procedures that demonstrate the organization's capacity to manage, preserve and ensure the safety of the cultural property in its collection. Policy elements include document or clauses pertaining to acquisitions, documentation/collection management, care of collections, deaccessioning, exhibitions, and loans.
  • Governance Structure: Organizations should be able to demonstrate a good governance structure, stable management, and sound financial practices over a two-year period.
  • Facilities: Must demonstrate that their facility provides storage for and access to certified cultural property within a controlled environment. Must have a system to monitor and control environmental conditions year-round, must have a 24/7 monitored security alarm system, and must have a 24/7 monitored detection and fire alarm system.

The IAC has been designated as a Category A by the Department of Canadian Heritage (PCH) through the Movable Cultural Property Grants Program.

To ensure that applicable requirements are adhered to, the audit expected there to be a governance structure with clearly established authorities, roles, and responsibilities for preserving/promoting the Collection. Furthermore, the audit expected there to be an oversight mechanism at appropriate levels of management that receives information pertaining to the functioning of the Collection including its compliance with requirements.

Risk

There is a risk that effective governance and oversight over the activities to acquire, preserve, protect, promote, de-access and dispose of the art pieces held within the Collection over their lifecycle may not be in place.

Finding

The audit found that the Department has partially implemented governance and oversight mechanisms to ensure the Collection is being managed in accordance with relevant TB policies and departmental directives. However, opportunities for improvement related to the following three areas were observed:

  1. Departmental policy instruments in place to preserve, protect and promote the Collection;
  2. Outsource arrangements with third party storage facilities; and
  3. Oversight of the Collection.
Departmental Policy Instruments in place to Preserve, Protect and Promote the Collection

The audit observed that the roles and responsibilities of key personnel involved in the operational management of the Collection have been defined in regard to the acquisition, preservation, record-keeping, promotion, de-accession, and disposal of art pieces. This included the roles and responsibilities of the Director, Registrar, and Coordinator positions within the IAC, as well as the Juried Art Committee (JAC). Additionally, the audit observed that the IAC has an established Emergency Response Management Plan, as well as an Integrated Pest Management Plan for the temporary storage facility of the Collection.

However, gaps were observed in relation to meeting the requirements applicable to the Collection. Through inquiries with management, it was confirmed that an independent evaluation of the condition of the Collection on an annual basis had not been performed, which was stated a requirement in the initial program authority. Additionally, while the audit observed that museum/gallery standards such as the guidelines produced by the Association of Art Museum Directors and the Canadian Museum Association are referenced within IAC policy instruments, the audit did not observe the documentation and identification of the specific requirements and guidelines that are being applied to and met by the IAC.

The roles and responsibilities noted above are documented and defined within the "IAC Collection Management Policy and Procedures" document which has been identified as a draft version developed in January 2022.The previous iteration of the policy from 2009 was noted to be in draft as well. The last approved policy instrument pertaining to the Collection was noted by management to be from 1990. Additionally, a multi-year art collection asset conservation plan for the preservation and maintenance of movable assets throughout their life cycle was developed covering the period of 2013 to 2018, however the audit team did not observe a updated version of the current plan in place.

The audit also observed unclear roles and responsibilities related to follow-up actions to take in the event of unaccounted for art pieces. For example, through a report generated by the IAC at the time of the audit, the audit observed that 132 art pieces were identified as "works not accounted for". The audit was informed that art pieces noted as unaccounted for include pieces where the last known location of the artwork is known but it is unable to be recovered. In addition, the audit was informed that some of these artworks were considered missing. While the roles and responsibilities in regard to the de-accession and disposal of lost art pieces have been defined within the draft policy instruments of the Collection, the policy framework for timely recovery of unaccounted for or missing art pieces was unclear. Up to date policy instruments with clear roles and responsibilities for implementing requirements for the protection, preservation, and promotion of the Collection are essential for ensuring that the Department fulfils its mandate to oversee the development and maintenance of Indigenous art held in its care. Failing to fulfil key requirements can erode trust bestowed upon it by Indigenous Artists and also negatively impact the Collection's designated status through the PCH Movable Cultural Property Program.

Outsource Arrangements with Third-Party Storage Facilities

During the audit period, it was noted that the Collection was primarily stored at two locations. The first storage location is the temporary storage facility located in a Public Services and Procurement Canada (PSPC) site due to major renovations occurring throughout the exterior and interior of Les Terrasses de la Chaudière (LTDLC). The other storage location is a third-party storage facility that is used due to capacity constraints within the temporary storage facility. It was noted that off-site storage facilities have been used to store pieces held within the Collection dating back to 2013, and management noted that previously over 2,100 artworks had been stored off-site. As of April 2024, the audit observed that 3,985 artworks valued at about $11M was stored at the temporary storage facility whereas 930 artworks valued at about $2.2M were stored at a third-party storage facility. The remaining artworks held within the Collection were noted to be on loan, stored in facilities out of scope for the purposes of the audit, or not accounted for (discussed under Section 3.3).

It was noted that the temporary PSPC storage facility received a Category A storage facility designation from the Department of Canadian Heritage in July 2024 following a technical assessment performed by CCI. This was a renewal of the designation received for the storage location used to store the Collection prior to completing its move in 2022. The prior review performed by the CCI was performed on the previous storage location of the Collection in 2013.

While the temporary PSPC storage facility has received Category A designation, the audit did not observe evidence of any inspection having been performed to demonstrate that the third-party storage facility is able to store and preserve art pieces adequately. This did not align with requirements outlined within the initial program authority that required all works of art to be "stored in a risk-free environmentally controlled room which has been certified by the Canadian Conservation Institute (CCI)".

The audit observed that there has not been a contract in place between the third-party storage facility and the Crown throughout the audit scope period. Without a contract in place, the Department does not have a formal mechanism to ensure that the third-party storage facility is in compliance with its various requirements. Furthermore, the storage services are paid through a Department-issued acquisition card. Per the Departmental Directive on the Use of Acquisition Cards, acquisition cards must not be used for services that have a security requirement or have intellectual property considerations. Given that artworks are subject to copyright elements, this may be viewed as intellectual property considerations. Additionally, the third-party storage facility used to store pieces held within the Collection is required to physically secure the pieces of the Collection. Due to these factors, it appears that the use of Acquisition Card for the purposes acquiring services to store artwork would not be appropriate. While requested, the audit did not receive evidence that an exemption was provided to the IAC for this use.

Use of the third party without a contract in place limits the ability to ensure that the Collection is being stored in a manner consistent with its requirements and ensure value for money for the services received.

Oversight of the Collection

During the audit, it was observed that oversight over the Collection was to be performed by the Director of the IAC. This was noted through the existence of reporting lines in place within the IAC to facilitate the daily operational activities supporting the ongoing preservation and protection of the Collection. Additionally, the IAC has established regular weekly meetings and structured communication to facilitate timely issue resolution and have capabilities in place to track key operational performance indicators related to the day-to-day management of the Collection through dashboards that are generated from Mimsy XG.

While it was observed that reporting lines are in place up to the Director of the IAC, the audit team did not observe a clear assignment or designation of a senior official that is accountable to the Deputy Minister for the management of materiel including assets of heritage value, which is required per the TB Directive on the Management of Material. Additionally, while an SLA exists between Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC) CFRDO and Indigenous Services Canada (ISC) CFRDO, roles and responsibilities specific to the management and oversight over the Collection were not clearly defined within the document.

Without a documented and regularly reviewed governance framework with clear assignment of oversight roles and responsibilities, including the role of ISC CFRDO and a senior designated official within CIRNAC, there is a heightened risk of non-compliance with the Department's policies. This lack of oversight impacts the organization's ability to effectively monitor and manage the Collection and ensure that it adheres to its requirements to remain consistent with its program authority and maintain its designated status.

Recommendations

Recommendation 1: The Corporate Secretary should ensure that its policy instruments for the management of the Indigenous Art Collection are updated, approved, and implemented with clearly defined roles and responsibilities for protection, preservation, and promotion activities in accordance with the TB Directive on Material Management and acceptable standards for the care of assets with heritage value.

Recommendation 2: The Corporate Secretary should review the continued need to outsource additional storage space over immediate and longer-term timelines and ensure that an appropriate contractual framework be put in place to manage risks related to third party storage of the Indigenous Art Collection.

Recommendation 3: The Corporate Secretary should implement monitoring and oversight processes to ensure that appropriate levels of senior management are aware of matters regarding the management of the Indigenous Art Collection, including adherence to its approved policy instruments.

3.2 Processes for Determining Costs Required to Lifecycle Artwork Within the Collection

Criteria 2: Adequate processes are implemented to support the determination of costs required to sustain operations related to the acquisition, preservation, protection, promotion, de-accession and disposal of art pieces.

Background

Lifecycle costs include expenditures required to maintain an asset or initiative from its initial inception, through to the end of its life. A costing exercise includes the use of a process to estimate the resources (e.g. human resources, material, financial, etc.) that will be consumed over the lifecycle of assetsFootnote 5.

The IAC is expected to comply with relevant TB policy instruments, departmental policies and procedures, and other requirements related to the lifecycle management of the Indigenous art held in the Collection. The TB Directive on the Management of Materiel states that material management decisions are based on an assessment of full life-cycle costs. Additionally, as part of its Category A designation status held through the Department of Canadian Heritage Movable Cultural Property Program, the IAC is expected to maintain sufficient capacity for the long term preservation of the Collection.

Accordingly, the audit expected there to be adequate processes implemented to support the determination of costs required to sustain IAC operations related to the adequate acquisition, preservation, protection, promotion, de-accession, and disposal of art pieces.

Risks

There is a risk that adequate processes for estimating the costs required to acquire, preserve, protect, promote, de-access and dispose of art pieces and for informing funding decisions regarding the Collection may not be in place, impacting the Department's ability to consistently meet requirements entrusted upon it for safeguarding the Collection.

Findings

The audit observed that the Department has performed some costing exercises throughout various points of time since the inception of the IAC. For example, a baseline costing analysis was performed in 1990 as part of the establishment of a program authority for the IAC. At the time, the estimated costs to sustain IAC operations were approximately $316,000 a year supported by 10 full time equivalents (FTEs) which included the costs associated with the acquisition, promotion, and maintenance of the Collection. The most recent costing analysis was performed in FY2019-20 and projected approximately $2.5M a year, supported by approximately 12 FTEs. The costing analysis was performed for the purposes of receiving additional funding for the IAC as the funding being received was no longer adequate to support the program, which put at the Department at risk in its ability to fulfill its mandate to acquire and properly care for the Indigenous Art Collection. The most recent FTE count as of January 2024, consisted of 11 FTEs, two of which were vacant, and three casual employees.

Additionally, as part of the Department's regular annual budgeting process, the IAC prepares its operational forecasts for O&M and salary expenditures. The annual budgeting process also considers some planned activities such as expected loans, materials required for preservation, and costs associated with the National Acquisition Program.

While a costing analysis was performed in FY2019-20, IAC management could not confirm whether the costing analysis was formally submitted for approval. Additionally, the audit observed that some activities required to sustain operations in accordance with relevant policies and requirements were excluded from the analysis. For example, as per its initial program authority decision received from the TB regarding the Collection, the condition of the Collection is expected to be independently evaluated on an annual basis. However, expected costs associated with these evaluations were not included in the observed costing exercise. Another activity that appeared to be excluded from the analysis included the physical asset verification and reconciliation of the verification results with the Collection's records, which was identified as a requirement in the TB Directive on the Management of Materiel.

Additionally, processes to support lifecycle costing exercises were not documented.

Understanding the costs associated with the lifecycle management of the Collection is critical to ensure the preservation, protection, and promotion for future generations. Proper cost planning enables the proper maintenance and protection of Indigenous art within the Collection, accounting for both current needs and long-term preservation. This understanding helps balance financial resources with the Collection's heritage value, preventing neglect or loss due to insufficient funding or planning.

Recommendation

Recommendation 4:

The Corporate Secretary should:

  1. Perform a baseline costing analysis to identify the levels of effort and associated costs for implementing and complying with current acceptable standards regarding protection, preservation, and promotion requirements over the life cycle of the art pieces within the Indigenous Art Collection and use it for budgeting purposes; and
  2. Implement processes to periodically update cost analysis.

3.3 Internal Controls Over the Preservation, Protection, and Promotion of the Collection

Criteria 3: Effective key controls are implemented to support the acquisition, preservation, protection, recordkeeping, promotion, de-accession and disposal of art pieces over their lifecycle in accordance with TB policies and Departmental directives.

Background

The management of the Collection is expected to comply with relevant TB policy instruments, which state that materiel is managed using a life-cycle approach. Life-cycle management is defined to include the planning, acquisition, use and maintenance, and disposal of assets.Footnote 6

To mitigate risk of loss, damage, and deterioration of Indigenous art within the Collection, and to ensure requirements to preservation, protection, and promotion, the audit expected there to be appropriate internal controls in place. Specifically, the audit expected there to be internal controls in place related to:

  • Acquisition of Indigenous Art;
  • Physical and environmental controls for protection and preservation;
  • Promotion of the Collection;
  • Recordkeeping; and
  • De-accession/disposition of artworks held within the Collection.

The audit also expected the control activities to be documented and implemented through approved standard operating procedures. Furthermore, it was expected that sufficient documentation would be maintained to demonstrate that controls are operating as intended.

Risk

There is a risk that effective processes and key controls to support acquisition, preservation, protection, recordkeeping, promotion, de-accession and disposal of the art pieces held within the Collection may not be in place, which increases risk of lost or damaged pieces.

Findings

Acquisition

The audit observed that a process has been defined to acquire artworks to be added to the Collection which includes specific criteria that serve as a guideline to identify artworks and the documentation that is to be retained to support acquisitions.

However, the audit did not observe standard operating procedures to be in place that reflect the activities and steps to be performed to appropriately acquire artworks in accordance with the policies and procedures that have been defined.

Additionally, the audit conducted sample testing on 38 artworks that were acquired through the identified methods of acquisitions during the in-scope period. While the audit team noted that there were no exceptions for artworks acquired through the National Acquisition Programs, the audit team did not receive documentation to support that the art pieces acquired through Direct Acquisitions and Donations met both the acquisition criteria as well as provided justification as to why the artwork was selected to be part of the Collection.

The lack of standard operating procedures for the acquisition of artworks creates a risk of inconsistent decision-making, potential non-compliance with organizational policies, and inadequate documentation to support the acquisition of artworks. Additionally, without appropriate documentation in place to support acquisitions, there is a risk that acquired artworks do not meet the defined acquisition criteria and may not align with the Collection's objectives.

Physical Security and Environmental Controls Related to the Protection and Preservation of the Collection

The audit observed that standard operating procedures related to the physical security controls within the temporary storage facility have been documented. Additionally, the audit team confirmed through site visits of the temporary storage facility and the third-party storage facility that access to the Collection at both facilities is restricted, temperature and humidity controls are in place, and that 24-hour monitoring and motion detection systems are in place. The audit also observed that several of the issues raised in the 2013 facility inspection performed by Canadian Conservation Institute (CCI) on the previous location had been addressed through the set up at the temporary storage facility.

However, at the time of the audit, it was noted that functioning security cameras were not yet in place within the temporary storage facility. Furthermore, it was noted that while monitoring and motion detection systems are in place at the third-party storage facility, the IAC does not have access to these systems and does not receive notifications relating to security breaches.

Additionally, the audit team requested and received maintenance records for the vault located in the temporary storage facility, however records related to regular maintenance of heating, ventilating, and air conditioning (HVAC) systems were incomplete. The audit was informed that the maintenance records are the responsibility the PSPC property manager. While the maintenance of HVAC equipment is not under the responsibility of the IAC, its effective functioning impacts the protection and preservation of the Collection. As an example, in March 2023, a water leak was caused by a failure in the HVAC plumbing within the Collection storage room which affected three unglazed paintings.

Without the ability to monitor the Collection, there is an increased risk of theft and security breaches related to the Collection going undetected by the Department. Additionally, by having limited control over the facility and maintenance of HVAC equipment used to preserve the Collection, there is a risk of further instances occurring where artworks held within the Collection are damaged due to equipment failures.

Promotion of Artworks

The audit observed that the IAC has a process in place that includes criteria that borrowers must meet in order to be approved for loans. As part of the audit procedures, the audit team randomly selected nine (9) artworks within the Collection that have been loaned during the in-scope audit period, to validate if they had been appropriately loaned based on the defined procedures. The audit team did not note any discrepancies in the sampled loans.

While the policies and procedures specific to the process in place to loan artworks within the Collection have been defined, the audit did not observe standard operating procedures to be in place that reflect the activities and steps to be performed to appropriately promote and loan artworks within the Collection.

Recordkeeping

The audit observed that the information requirements for each record within the records management system and the responsibilities of key stakeholders in maintaining the records of the Collection were defined. Additionally, it was noted that standard operating procedures for updating the records of the Collection were observed to be in place.

As part of the site visits of the temporary storage facility and the third-party storage facility, the audit team conducted an inventory check comprising of validating the location of art pieces as stated in the Mimsy XG database. The audit team pre-selected 51 random samples within the database and physically inspected the pieces on the vault floor during the site visit in order to validate the existence of the art pieces held within the Collection and noted no discrepancies. Additionally, the audit team randomly selected an additional 51 samples from the vault floor to the Mimsy XG database to validate the completeness and accuracy of the database and no discrepancies were noted.

However, it was noted that while the IAC performs ad-hoc physical inspections of the pieces held within the Collection, no documentation to support the inspections was observed to be in place. Additionally, the audit observed that there was an inspection conducted on the Collection during the move to the temporary storage facility, however no documentation was observed to be in place to reflect the results of that inspection.

The lack of retaining appropriate documentation to support the performance of physical inspections of the Collection may lead to reduced accountability and transparency, compliance with policy requirements, and operational integrity.

De-Accession of Artworks

Through discussions held with the IAC, it was confirmed that the IAC had not de-accessed any artworks held within the Collection. For an art piece to be de-accessed and disposed of, specific criteria must be met including but not limited to the written proposal which contains the appropriate documentation and recommended means of disposal, as well as the Director of the IAC receiving approval from the Deputy Minister of the Department. Due to the de-accession and disposal of artworks having not occurred, no gaps were identified within the de-accession and disposal process.

Recommendation

Recommendation 5: The Corporate Secretary should ensure that physical security, environmental, and recordkeeping controls are suitably designed and are operating in accordance with its policy instruments and acceptable standards for the care of assets with heritage value, and that sufficient documentation is retained to demonstrate that controls are properly implemented and effectively operating.  

4. Conclusion

The audit found that the Department has implemented partial components of a management control framework to support activities related to the acquisition, preservation, promotion, de-accession, and disposition of Indigenous art within the Collection. Within the IAC, roles and responsibilities have been assigned to operate the Collection with systems in place to support the recordkeeping of art pieces. Additionally, the setup of the temporary storage facility addressed some prior concerns related to preservation and protection that were identified through inspections of the prior storage space. The IAC has also recently established emergency management and integrated pest management plans.

While some components of the management control framework were in place, the audit observed several opportunities for improvement. Specifically, the audit observed that the IAC's key policy instruments remained in draft or were outdated. There was also a lack of clarity in oversight roles and responsibilities and limited reporting into senior management on IAC activities was observed. The audit also observed that a portion of the Collection is being stored at a third-party storage facility owned and managed by a private vendor due to space limitations in the temporary storage location, however no contract was in place to manage and oversee the services received and ensure that the Collection is being safeguarded in accordance with IAC's requirements.

The audit also observed that the Department does not have an up-to-date plan for sustaining the Collection over its life cycle nor were there processes in place to identify and estimate holistic costs required to sustain operations in compliance with all of its requirements.

Additionally, the audit observed opportunities to strengthen its internal controls to manage the Collection, including proper retention of documentation to demonstrate the proper function of its physical security, environmental, and recordkeeping controls. To help ensure that it continues to fulfil its mandate to acquire and properly care for the Collection, the Department should strengthen its governance by addressing noted gaps in existing policy instruments, and its management of private service providers, as well as to clarify oversight roles and responsibilities to ensure appropriate levels of senior management are kept apprised on IAC operations. The Department should also ensure there are appropriate plans to implement and maintain required activities across the Collection lifecycle with visibility into the costs of doing so. Finally, the Department should ensure that its physical security, environmental, and recordkeeping controls are functioning as intended and that it retains sufficient documentation to demonstrate their effectiveness.

Additional Considerations

As the Department considers its options to invest resources to address the opportunities for improvement noted throughout this report, it should also consider the extent to which the Indigenous Art Collection is best suited to remain under the purview of Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC). These considerations should be made in consultation with the IAC's key stakeholders.

5. Management Response and Action Plan

Recommendations Management Response / Actions Responsible Manager (Title) Planned Implementation Date

Recommendation 1

The Corporate Secretary should ensure that its policy instruments for the management of the Indigenous Art Collection are updated, approved, and implemented with clearly defined roles and responsibilities for protection, preservation, and promotion activities in accordance with the Treasury Board of Canada (TB) Directive on Material Management and acceptable standards for the care of assets with heritage value.

Management Response / Actions

The Indigenous Art Centre (IAC) is in the process of updating and reviewing the policy instruments to ensure that they are aligned with United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), the Truth and Reconciliation Commission of Canada (TRC) Calls to Action, Missing and Murdered Indigenous Women and Girls (MMIWG) report and the New Frameworks for the Management of Procurement, Material and Fleet which was launched in February 2024.

Responsible Manager (Title)

Corporate Secretary, with support from the Manager, IAC

Planned Implementation Date

March 31, 2025

Recommendation 2

The Corporate Secretary should review the continued need to outsource additional storage space over immediate and longer-term timelines and ensure that an appropriate contractual framework be put in place to manage risks related to third party storage of the Indigenous Art Collection.

Management Response / Actions

The process to establish a contract for third party storage is under way and expected to be implemented by the end of the fiscal year. Additional storage space will continue to be outsourced until an alternate facility is identified.

The Department is currently working with Public Services and Procurement Canada (PSPC) to develop a plan for new space to be completed by 2027, when the Temporary Storage Facility lease expires.

Responsible Manager (Title)

Manager of IAC with contracting team, PSPC and Accommodations

Planned Implementation Date

March 31, 2025 for contract

New Space end of FY 2027-28

Recommendation 3

The Corporate Secretary should implement monitoring and oversight processes to ensure that appropriate levels of senior management are aware of matters regarding the management of the Indigenous Art Collection, including adherence to its approved policy instruments.

Management Response / Actions

The IAC will continue its review of internal process and to make improvements to existing documentation, including updating and documenting relevant procedures and processes.

Responsible Manager (Title)

Corporate Secretary, with support from the Manager, IAC

Planned Implementation Date

March 31, 2025

Recommendation 4

The Corporate Secretary should:

  1. Perform a baseline costing analysis to identify the levels of effort and associated costs for implementing and complying with current acceptable standards regarding protection, preservation, and promotion requirements over the life cycle of the art pieces within the Indigenous Art Collection and use it for budgeting purposes; and
  2. Implement processes to periodically update cost analysis.

Management Response / Actions

  1. A baseline cost analysis to identify the levels of effort and associated costs for implementing the IAC's mandate will be completed to inform the budget for fiscal year 2025-2026.
  2. Ongoing periodic costing analysis will conform with industry standards.

Responsible Manager (Title)

Manager of IAC

Planned Implementation Date

March 31, 2025

Recommendation 5

The Corporate Secretary should ensure that physical security, environmental, and recordkeeping controls are suitably designed and are operating in accordance with its policy instruments and acceptable standards for the care of assets with heritage value, and that sufficient documentation is retained to demonstrate that controls are properly implemented and effectively operating.

Management Response / Actions

  1. Updates to the IAC policy instruments will be updated and approved this fiscal year.
  2. Documentation will be retained, and mechanisms to record-keep oral traditions from Indigenous Peoples will be explored and utilized.

Responsible Manager (Title)

Manager of IAC

Planned Implementation Date

March 31, 2025

Appendix A: Audit Criteria

To ensure an appropriate level of assurance to meet the audit objectives, the following audit criteria were developed to address the objectives.

Audit Criteria

  1. Effective governance and oversight mechanisms are implemented to ensure the Collection is being managed in accordance with Treasury Board (TB) policies and Departmental directives.
    • 1.1 A clear and effective governance structure with defined accountabilities, roles and responsibilities is documented, communicated and effectively carried out.
    • 1.2 An oversight mechanism is designed and implemented to ensure that applicable policies and requirements are adhered to.
    • 1.3 Adequate performance information and reports are communicated with those charged with governance over the Collection to inform decision making.
  2. Adequate processes are implemented to support the determination of costs required to sustain operations related to the acquisition, preservation, protection, promotion, de-accession and disposal of art pieces.
    • 2.1 An established approach for the Collection to determine the estimated costs to appropriately acquire, preserve, protect, promote, de-access and dispose of art pieces is defined, in place and functioning.
    • 2.2 Estimated costs and forecasts are used to inform the decision-making approach over the Collection.
  3. Effective key controls are implemented to support the acquisition, preservation, protection, recordkeeping, promotion, de-accession and disposal of art pieces over their lifecycle in accordance with TB policies and Departmental directives.
    • 3.1 Controls related to the acquisition of art pieces are documented, implemented, and operating effectively.
    • 3.2 Environmental and physical security controls for preserving and protecting the Collection are documented, implemented, and operating effectively.
    • 3.3 Controls related to inventory records management are documented, implemented, and operating effectively to appropriately maintain the art pieces' records over their lifecycle.
    • 3.4 Controls are documented, implemented, and operating effectively to ensure the IAC is supporting the promotion of contemporary Canadian Indigenous Art.
    • 3.5 Controls with regards to the de-accession and disposal of art pieces within the Collection are designed, documented, implemented, and operating effectively.

Appendix B: Indigenous Art Collection Key Events

Figure 1 below provides a high-level timeline of key events dating back to the creation of the Collection.

Figure 1: Timeline of Indigenous Art Collection Key Events
Chart showing a timeline of Indigenous Art Collection Key Events
Text alternative for Figure 1: Timeline of Indigenous Art Collection Key Events

Figure one provides a high-level timeline of key events dating back to the creation of the Collection.

In 1965, the Indigenous Art Center was created to support the creation, preservation and promotion of contemporary Canadian Indigenous Art.

In 1982, an independent analysis of the condition of the Department's Indigenous Art Collection was performed. The report found that the art pieces were in good condition.

In 1990, Treasury Board decided to fund a program for the acquisition of Indigenous Art and the on-going maintenance program for the preservation of the Indigenous Art Collection.

In 2013, a Threat Risk Assessment was performed on the storage location of the Indigenous Art Collection. Recommendation to relocate the Collection to a new storage location was received.

In 2019, a need to eliminate the threat of damage to the Collection was identified following Public Service Procurement Canada's (PSPC) announcement of the LTDLC complect renovations.

In 2022, the Indigenous Art began its relocation to a new storage facility.

Appendix C: Activities of the Indigenous Art Centre

The IAC is under the umbrella of Corporate Secretariat, Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC), and is tasked with various activities including acquiring, documenting, preserving, promoting and de-accessing art pieces. Figure 2 below provides an overview of the main activities related to the management of the Collection:

Figure 2: Overview of Indigenous Art Collection Lifecyle
Text boxes describing overview of Indigenous Art Collection Lifecyle
Text alternative for Figure 2: Overview of Indigenous Art Collection Lifecyle

Figure 2 below provides an overview of the main activities related to the management of the Collection:

Acquisition: Art pieces within the Indigenous Art Collection are acquired through the transfer of ownership (purchases, gifts, bequests and donations). Specific acquisition criteria are followed by the acquisition mechanism (Juried Committee, Direct Acquisition and Donations). Refer to Appendix B and C for further details.

Cataloguing and Documentations: Art pieces held within the Indigenous Art Collection are documented and catalogued using museums collections standards. Various data inputs are collection and maintained for each pieces including the artwork type, tittle, maker/artist, community tribal or group affiliation, among others.

Preservation & Conservation: Preservation and conservation or art pieces includes ongoing monitoring and maintenance such as ensuring adequate storage (e.g, humidity and temperature control), physical safeguarding, and monitoring of the art pieces conditions.

Promotion: Art pieces are available to be loaned for display and exhibition to internal, national and regional art and cultural institutions. The Indigenous Art Center also promotes Art pieces through exhibitions in the Indigenous Art Gallery, located in the CIRNAC Headquarters Building lobby at 10 Wellington Street, Gatineau, Québec.

De-accession & Disposal: Art pieces de-accession and disposal decisions must be researched, documented by specialists, and approved by the Deputy Minister. De-accession/disposal methods include transfer to other collections/institutions or destruction. To date, no formal de-accession of art pieces held within the IAC has occurred.

Appendix D: Strategic Considerations for the Future of the Indigenous Art Collection

Although not included in the scope of the audit, the audit team had discussions throughout the audit related to the future of the Indigenous Art Collection (Collection). We have heard from management that since the late 1970s, public opinion on the Indigenous Art Center (IAC) has been mixed – from artists who feel the heritage art collection is entrusted to the Department, to Indigenous organizations who would prefer the collection be led by Indigenous Peoples. The Indigenous Art Center's mandate is often not well known in the public environment. In addition, per the initial Program Authority Decision in 1990, a long-term goal of the Collection was for the Department to turn over the Collection and the responsibility of its ongoing maintenance to an appropriate Indigenous Organization. Since then, management has acknowledged that there have been instances where Organizations have expressed interest in acquiring portions of the Collection, however management has chosen not to pursue these opportunities as Indigenous stakeholders have expressed their desire that the Collection must be kept as a whole. Through the years, senior government officials have requested that Crown-Indigenous Relations and Northern Affairs Canada (CIRNAC)'s IAC explore avenues for possible divesting and repurposing of the collection.

The Department should carefully weigh the strategic and operational implications related to the continued stewardship of the Indigenous Art Collection within the mandate of Crown-Indigenous Relations and Northern Affairs Canada. As identified in this audit, several factors impact the Collection's long-term sustainability, efficient management, and alignment with departmental priorities.

1. Evaluating Governance and Stewardship

A central question for the Department is whether CIRNAC remains the most suitable entity to oversee the Collection. Since its establishment in 1965, the Indigenous Art Centre has played a pivotal role in acquiring, preserving, and promoting Indigenous art, creating a visual legacy significant to Indigenous communities and Canada's cultural heritage. However, shifting governance frameworks, evolving cultural preservation standards, and increased complexity in managing heritage assets indicate that a re-evaluation should perhaps be considered. In assessing this, CIRNAC must balance the Collection's cultural and symbolic significance with the practical demands of resource allocation, compliance with heritage asset regulations, and stakeholder expectations.

2. Stakeholder Engagement and Partnerships

The Department may engage in active dialogue with key stakeholders, including Indigenous artists, communities, cultural organizations, other departments and agencies with related mandates, and policy experts. Effective consultation is essential to understand the cultural and social values attached to the Collection, ensuring any decision respects the principles of co-development, reconciliation, and cultural sovereignty. This engagement should aim to explore potential collaborations or transfer opportunities in accordance with current devolution efforts that could benefit both the Collection and CIRNAC's broader reconciliation goals. It may also include evaluating partnerships with heritage organizations better equipped to manage and promote large-scale art collections.

3. Financial and Logistical Considerations

The operational challenges outlined in this report, such as reliance on third-party storage facilities without appropriate contractual arrangements and a lack of comprehensive cost analysis, highlight the need for strategic financial planning. The Department should analyze the long-term financial implications of maintaining the Collection. This should include evaluating costs associated with acquiring a permanent, environmentally controlled facility versus potential efficiencies from transferring the Collection to another entity. A detailed cost-benefit analysis could support informed decision-making, ensuring public resources are used efficiently while safeguarding cultural assets.

4. Cultural Responsibility and Risk Management

Maintaining cultural artifacts comes with an inherent responsibility to ensure their protection and promotion in ways that honor their origins. The risks identified in the audit, such as gaps in physical security and environmental controls, underscore the urgency of addressing these findings. CIRNAC should consider whether the current governance structure and resources are adequate to manage these risks or if reallocation of responsibility to another party, such as a specialized cultural institution, might be more appropriate. Additionally, sustaining the Collection's cultural integrity must remain a guiding principle, with a focus on preserving Indigenous knowledge systems and practices.

5. Alignment with CIRNAC's Core Mandate

The Department's broader focus on advancing relationships with Indigenous peoples raises the question of how best to integrate the management of the Collection into its reconciliation efforts. While CIRNAC has been a steward of the Collection, future plans should ensure that managing cultural assets does not divert focus from its core responsibilities in rights recognition and self-determination. This consideration involves exploring if external management could better serve both the Collection and CIRNAC's strategic priorities.

However, it should be noted that the heritage art collection has been classified as a Heritage Movable Asset due to its significant historical, artistic, scientific, or cultural value. Unlike regular movable assets, which depreciate over time and are used for economic benefits, heritage assets are preserved for their cultural significance and often appreciate in value. They are protected by various national and international laws, such as the United Nations Educational, Scientific and Cultural Organization (UNESCO) 1970 Convention and Canada's Cultural Property Export and Import Act, ensuring their preservation against theft, illegal trade, and destruction for future generations.

When transferring heritage assets to another department, organization, or agency, several key considerations must be taken into account to ensure proper handling and preservation:

  • Legal and Regulatory Compliance: Ensure adherence to the TBS heritage Moveable Assets policy, national and international laws, such as the UNESCO 1970 Convention, and formalize transfer agreements outlining responsibilities and restrictions.
  • Documentation and Provenance: Maintain detailed records of the asset's provenance, condition, and any restorations, and update inventory records to ensure accurate tracking.
  • Preservation and Conservation: Conduct thorough condition assessments before transfer and ensure proper handling and transport to prevent damage and their facility is suitable for the preservation of the art works.
  • Institutional Capacity: Assess the receiving entity's capability to care for the asset, including their expertise and resources, and provide necessary training and support.
  • Ethical Considerations: Respect the cultural significance of the asset, ensuring the transfer process is transparent and culturally sensitive. Inform all 900 Indigenous artists or their estates about any transfer.

Summary

As the Department currently considers its options to invest resources to address the opportunities for improvement noted throughout this report, it should also consider the extent to which the Indigenous Art Collection is best suited to remain under the purview of CIRNAC. These considerations should be made in consultation with the IAC's key stakeholders.

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