The Controller becomes aware of potential transactions that may have accounting and disclosure ramifications, from her role as a member of executive manegement or from Segment Finance and Accounting officers and staff seeking guidance on matters that come to their attention.

Owner

	Name	Description	Type
	Controller		Role

The Treasurer, Controller, Director of Accounting and Assistant Controller receive for their review and determination of any accounting recognition, reporting, and disclosure issues for all commercial contracts, labor agreements, leases, material purchase and sale agreements, benefit plan amendments, employment contracts, severance agreements, any debt agreement, i.e. mortgages, indentures, covenants, etc., committee meeting minutes, that are being sent to the Company’s Central Files. This procedural control provides a final opportunity to detect transactions that were previously unknown to them, or may not have been fully completed at the time of earlier intervention, for accounting and disclosure purposes. (FR-501.2)

Test Plan Description

Select major agreements that have occurred during the year and review for controller Department review.

Risks

	Name	Description	Type
	Transactions with accounting or disclosure issues may not re recognized because they have been overlooked by an accounting expert		Risk

Control Objectives

	Name	Description	Type
	Normal and routine contracts, agreements, purchase agreements, sales agreements, minutes, etc. may reflect transactions that have accounting recognition and disclosure issues associated with them. Such matters should be reviewed and considered to ensure that accounting is complete, and all disclosures are made	FR-501.2	Control Objective

Owner

	Name	Description	Type
	Controller		Role

Performed By

	Name	Description	Type
	Controller		Role

Testing Owner

	Name	Description	Type
	Financial Analyst		Role

The Controller in consultation with the Treasurer and Director of Accounting will assess the facts and circumstances of the particular event or transaction so that the appropriate accounting guidance can be identified and applied. This process entails technical accounting research, a thorough understanding of the facts and circumstances through discussions with affected segment operations and accounting personel, to come to a conclusion as to the applicable guidance and the appropriate application of such guidance.

Owner

	Name	Description	Type
	Controller		Role

The Controller in consultation with the CFO, also considers whether an event or transaction has, or may require SEC reporting in the form of an 8 K. She will validate such a requirement when necessary with external SEC counsel.

Owner

	Name	Description	Type
	Controller		Role

The Controller also utilizes professional accounting expertise when necessary to discuss the selection of appropriate accounting guidance, its application to the current transactions facts & circumstances, and to identify other perspectives through the eyes of an objective third party.

Owner

	Name	Description	Type
	Controller		Role

The Controller will prepare an accounting memorandum when necessary that identifies the matter, cites the appropriate accounting guidance for the transaction, and recommends the appropriate recognition, reporting , and disclosures.

Owner

	Name	Description	Type
	Controller		Role

The Treasurer and CFO will review and consider the recommendation, and approve a final plan for the recognition, reporting, and disclosure of such events. The management executive and Board audit committees will be apprised of such transactions and their impact on the Company. (FR-501.3)

Test Plan Description

Review new accounting implementations, guidance, etc. for CFO review.

Risks

	Name	Description	Type
	Accounting recommendations could be implemented without approval, management may not be aware of the event or the accounting solution, and facts not known to the Controller could alter the recommendation		Risk

Control Objectives

	Name	Description	Type
	Recommendations on accounting solutions for transactions that have received the attention of the Controller, are reviewed by the CFO	FR-501.3	Control Objective

Owner

	Name	Description	Type
	CFO		Role
	Treasurer		Role

Performed By

	Name	Description	Type
	Board of Directors		Group
	CFO		Role
	Controller		Role

The Controller will prepare a schedule, timeline, and specific instructions for the accounting staff responsible for the initial and ongoing accounting for the specific events or transactions and will incorporate such required accounting and disclosures into quarterly and year end 10 Q & K filings preparation planning, as well as ensure that the MD & A accurately and completely discloses and describes such significant events. (FR-501.4)

Test Plan Description

Review new accounting implementations, guidance, etc. for directives on implementation, scheduling, etc.

Risks

	Name	Description	Type
	New guidance may not be completely, accurately, or efficiently applied as there is inadequate planning		Risk

Control Objectives

	Name	Description	Type
	Application of new accounting guidance occurs proactively, is scheduled, well planned, and all those involved in the process are identified, trained and sufficiently advised as to what their roles. responsibilities, and deliverables are	FR-501.4	Control Objective

Owner

	Name	Description	Type
	Controller		Role

Performed By

	Name	Description	Type
	Financial Analyst		Role

The Controller from her vantage point as chief accounting officer and Corporate Secretary, has knowledge of who significant shareholders are and those considered to be affiliates, and in the course of review of significant events, transactions, proposed transactions, can identify for possible disclosure purposes those individuals or firms that would be considered as related parties. (FR-501.5)

Test Plan Description

Review work done to identify related parties.

Risks

	Name	Description	Type
	Transactions involving individuals or parties that are related by definition are not identified or reported		Risk

Control Objectives

	Name	Description	Type
	To ensure that related party transactions are properly identified, reviewed, and assessed for disclosure purposes	FR-501.5	Control Objective

Owner

	Name	Description	Type
	Controller		Role