Corrective Action Plans

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Finding Number: 2024-006 Planned Corrective Action: AMHA will require staff to follow all requirements set forth in 24 CFR 982 regarding income documentation such as obtaining third party verification and documenting the file as to why it was not available, related to annual income, assets, expenses...
Finding Number: 2024-006 Planned Corrective Action: AMHA will require staff to follow all requirements set forth in 24 CFR 982 regarding income documentation such as obtaining third party verification and documenting the file as to why it was not available, related to annual income, assets, expenses, etc. Staff will be instructed to double check calculations before inputting the information into the computer/50058 and to check to make sure calculations are accurate prior to adding the 50058 for submission. AMHA will continue to send staff to the appropriate training courses and AMHA has contracted with Nelrod for online training and will ensure this also includes EIV training courses. AMHA staff will conduct quality control on the files at random. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director
Finding Number: 2024-005 Planned Corrective Action: The Housing Authority has contracted with the Nelrod Company a national technical consulting firm specializing in Federal Assisted Housing Programs to perform our rent reasonableness determinations. Anticipated Completion Date: 6/11/2026 Responsibl...
Finding Number: 2024-005 Planned Corrective Action: The Housing Authority has contracted with the Nelrod Company a national technical consulting firm specializing in Federal Assisted Housing Programs to perform our rent reasonableness determinations. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director
Finding Number: 2024-004 Planned Corrective Action: The Housing Authority along with Leggins Casterline & Company LLC accounting will continue working to rectify the accounting issues resulting from the former Executive Director and have all submissions done in a timely manner. Anticipated Completio...
Finding Number: 2024-004 Planned Corrective Action: The Housing Authority along with Leggins Casterline & Company LLC accounting will continue working to rectify the accounting issues resulting from the former Executive Director and have all submissions done in a timely manner. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director
Finding Number: 2024-003 Planned Corrective Action: Housing Quality Standards are now done internally by the Executive Director and the authority has one dedicated staff member monitoring and they assure a re-inspection is automatically scheduled and notice sent to landlord and tenant. Anticipated C...
Finding Number: 2024-003 Planned Corrective Action: Housing Quality Standards are now done internally by the Executive Director and the authority has one dedicated staff member monitoring and they assure a re-inspection is automatically scheduled and notice sent to landlord and tenant. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director
Management has implemented a formal procedure to ensure that future Single Audits are completed and submitted within the required timeframe. This procedure includes the following actions: First Quarter (January – March): The Purchasing Unit will initiate the procurement process for the independent a...
Management has implemented a formal procedure to ensure that future Single Audits are completed and submitted within the required timeframe. This procedure includes the following actions: First Quarter (January – March): The Purchasing Unit will initiate the procurement process for the independent auditors, in coordination with the Fiscal Manager, while year-end closing activities are being completed, to ensure timely engagement of audit services. Second Quarter (April – June): Once the auditor is engaged, the program will initiate the audit engagement and provide the required documentation in accordance with the established audit schedule.
FINDING 2024-003 Criteria: Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Audit Recommendation: We recommend that the Organization 1) maintains timely and accur...
FINDING 2024-003 Criteria: Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Audit Recommendation: We recommend that the Organization 1) maintains timely and accurate recording of disbursements in its job-costing system and 2) regularly request grant funds based on amounts expended as report in the Organization’s job-costing system. Auditee Response: UICSL revised its job costing system to better comply with these requirements and had overlap from previous programs/grants within its old QuickBooks Accounting system. UICSL now has a credit card tracking system by class code, ensures an invoice is allocated, and has focused on reimbursement method invoicing. Corrective Action Plan: Invoices and transactions will not be processed without approval and proper coding. Prior grant personnel and leadership are no longer within the organization. Monthly and quarterly invoices are sent according to each grant / contract agreement will be enforced by the GDCM and DFO in compliance with 2 CFR section 200.305(b). UICL is in active good status with all its current grantors, specifically Indian Health Servies (IHS). Person Responsible: Som Chivukula, Finance Director; Matt Poss, Executive Director Timeline: UICSL removing QuickBooks and switching to Oracle NetSuite in 2025/2026. Scheduling monthly check-ins and expenditure reports reviewed with department leads upon hiring of new Finance Director. All invoices reviewed with grant/project leads and logged appropriately. Staff accountant hired in late 2024 to help provide additional checks but also ensure UICSL focuses on reimbursement (post-expense).
FINDING 2024-002 Criteria: Recipients of federal awards must follow the costs principles set out at 2 CFR section 200.430 to substantiate compensation and other purchases charged to a federal program. “Charges to Federal awards for salaries and wages must be based on records that accurately reflect ...
FINDING 2024-002 Criteria: Recipients of federal awards must follow the costs principles set out at 2 CFR section 200.430 to substantiate compensation and other purchases charged to a federal program. “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: …(iii) reasonable reflect the total activity for which the employee is compensated by the non-Federal entity” 2 CFR section 200.430(i). The Organization’s processes did not maintain sufficient documentation of the approval of the activity of each employee or the purchase of goods/services. Audit Recommendation: We recommend the Organization ensure it 1) maintains records of each employee’s activity and 2) monitors compliance with the job-costing system implemented. Auditee Response: Organization believes that prior leadership and lack of supervision allowed paychecks to be approved without the proper flow. FY24 Turnover was roughly 75% in leadership and 60% across the organization. Corrective Action Plan: UICSL moved away to Paycom early 2024 to better help account for Labor Allocation and Grant Codes. With Paycom, employees are automated to each program and there is a designated reporting function allowing us to review what is assigned. UICSL going into 2025 has better defined leadership and Directors for each division so there are clearly defined approvers and supervisors for each purchase and transaction – leadership turnover was high. Person Responsible: Som Chivukula, Finance Director; Matt Poss, Executive Director; Eva Leyer, Human Resources Manager Timeline: UICSL filled all leadership positions by mid-2025 and went through two organizational restructures, creating more mid-level management. This will help ensure compliance with FY25 Audit.
To prevent recurrence, management has implemented the following permanent corrective measurers: 1.) Centralized Compliance Calendar: A Finance Compliance Calendar has been established within the City's operational system. All statutory and grant related deadlines are programmed with automated alerts...
To prevent recurrence, management has implemented the following permanent corrective measurers: 1.) Centralized Compliance Calendar: A Finance Compliance Calendar has been established within the City's operational system. All statutory and grant related deadlines are programmed with automated alerts issued three weeks in advance. Written approval from the Commissioner is required for any deviation. 2.) Dedicated Department email: A staff-independent email account (finance@mechanicvilleny.gov) has been established to maintain continuity and ensure traceability of all compliance correspondence and filings. 3.) Two-tier Review Process : Effective immediately, all federal reimbursement claims undergo a two-level review - initial preparation by program staff followed by certification by the Deputy Commissioner prior to submission.
To prevent recurrence, management has implemented the following permanent corrective measurers: 1.) Centralized Compliance Calendar: A Finance Compliance Calendar has been established within the City's operational system. All statutory and grant related deadlines are programmed with automated alerts...
To prevent recurrence, management has implemented the following permanent corrective measurers: 1.) Centralized Compliance Calendar: A Finance Compliance Calendar has been established within the City's operational system. All statutory and grant related deadlines are programmed with automated alerts issued three weeks in advance. Written approval from the Commissioner is required for any deviation. 2.) Dedicated Department email: A staff-independent email account (finance@mechanicvilleny.gov) has been established to maintain continuity and ensure traceability of all compliance correspondence and filings. 3.) Two-tier Review Process : Effective immediately, all federal reimbursement claims undergo a two-level review - initial preparation by program staff followed by certification by the Deputy Commissioner prior to submission.
The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the recommendation that all financial reporting and submission requirements and deadlines required by federal and state regulation be adhered to for future periods. The...
The management of Clayton County Community Services Authority, Inc. has reviewed the above referenced finding and fully agrees with the recommendation that all financial reporting and submission requirements and deadlines required by federal and state regulation be adhered to for future periods. The organization will work diligently with the audit firm to complete the fiscacl year 2025 audit. With the completion of the fiscal year 2024 audit, the organization and audit firm immediately began the preparation for fiscal year 2025. The subsequent year's audits have been prioritized and will be completed and submitted as soon as possible in order to bring the organization current and in compliance with this finding. The anticipated timeline for the completion of the fiscal year 2025 audit is August 31, 2026. With the completion of the FY2025 audit, the agency will be in full compliance with the Annual Audit requirements as set forth by federal and state regulations. This will bring the agency into full compliance for this finding.
Management concurs with the findings. Delays in the completion of the year-end financial close process, audit preparation, and related reporting requirements contributed to the untimely submission. Management recognizes the importance of timely compliance with federal reporting requirements and is c...
Management concurs with the findings. Delays in the completion of the year-end financial close process, audit preparation, and related reporting requirements contributed to the untimely submission. Management recognizes the importance of timely compliance with federal reporting requirements and is committed to strengthening procedures to ensure future submissions are completed within the prescribed deadlines. Corrective Action Plan: • Develop a comprehensive audit and reporting timeline and checklist that identifies key milestones for year-end closing, financial statement preparation, audit fieldwork, management review, and Federal Audit Clearinghouse submission. • Establish internal deadlines that precede regulatory due dates to allow adequate time for review, corrections, and final submission. • Strengthen coordination between finance personnel and external auditors through periodic planning meetings and status updates throughout the audit process. Contact person – Maura McCauley, CEO and Mindy Wade, Board Treasurer Date corrections were implemented – June 2026 and ongoing
Management concurs with the findings. During the fiscal year, turnover in key finance leadership positions impacted on the continuity of accounting operations and reduced the effectiveness of established financial close and reconciliation processes. • Strengthened financial leadership and oversight ...
Management concurs with the findings. During the fiscal year, turnover in key finance leadership positions impacted on the continuity of accounting operations and reduced the effectiveness of established financial close and reconciliation processes. • Strengthened financial leadership and oversight by elevating the lead finance position to a Chief Financial Officer role and recruiting a highly qualified finance executive. • Filled critical finance and accounting positions to enhance internal controls, improve accountability, and ensure adequate operational oversight. • Documenting and formalizing month-end and year-end close procedures, including detailed reconciliation requirements and review responsibilities. • Implementing standardized account reconciliation templates and review sign-off procedures for all significant balance sheet accounts. • Cross-training accounting personnel and maintaining written process documentation to reduce operational risks associated with staff turnover.
Management concurs with the findings. Due to staffing transitions and competing priorities during the year-end close process, certain accounting adjustments were not identified and recorded until audit fieldwork commenced. While the adjustments were subsequently recorded and reflected in the final f...
Management concurs with the findings. Due to staffing transitions and competing priorities during the year-end close process, certain accounting adjustments were not identified and recorded until audit fieldwork commenced. While the adjustments were subsequently recorded and reflected in the final financial statements, management recognizes that all significant year-end adjustments should be identified, reviewed, and posted prior to the start of the audit. Management will strengthen year-end financial reporting procedures to ensure all material adjustments are identified and recorded before audit fieldwork begins. Specific actions include: • Developing and implementing a comprehensive year-end closing checklist that includes all required reconciliations, accruals, estimates, and financial statement review procedures. • Establishing formal timelines for completion and review of year-end account reconciliations and adjusting journal entries.
Management's Response: Management has hired a Director of Grants & Impact Funding that will be responsible for submitting the grant expenditure reports.
Management's Response: Management has hired a Director of Grants & Impact Funding that will be responsible for submitting the grant expenditure reports.
Management's Response: Management agrees with the finding and will implement procedures to ensure compliance with Uniform Guidance.
Management's Response: Management agrees with the finding and will implement procedures to ensure compliance with Uniform Guidance.
Finding #2024-005 – Lack of Written Grant Procedures over Federal Programs Criteria: Under Federal Uniform Guidance, all non-Federal subrecipient entities must establish and maintain written policies and procedures over Federal programs. Written grant procedures are required in the areas of verifyin...
Finding #2024-005 – Lack of Written Grant Procedures over Federal Programs Criteria: Under Federal Uniform Guidance, all non-Federal subrecipient entities must establish and maintain written policies and procedures over Federal programs. Written grant procedures are required in the areas of verifying allowable costs, cash management, and conflicts of interest, while procurement, subrecipient monitoring, and reporting procedures should also be included. Condition: During their audit procedures, the auditors noted that the City did not have comprehensive written grant procedures governing key compliance areas. Cause: The City’s management has relied on informal practices and institutional knowledge rather than formulating a grant procedures manual. Effect: Without written procedures, there is an increased risk of noncompliance with Uniform Guidance, including improper cost charging, non-compliant procurement, untimely drawdowns or cash on hand, inadequate subrecipient oversight, and ineffective internal controls. This exposes the City to the risk of questioned costs, potential repayment of federal funds, audit findings, and other possible impacts. Recommendation: The auditors recommend that the City develop, approve, and implement a consolidated Federal grant procedures manual. The procedures should not be a replication of the Federal requirements but instead step-by-step processes that are necessary to be in compliance with the Federal guidelines. Response: The City will begin the process of drafting and approving a Federal grant procedures manual in order to be in compliance with Federal requirements going forward.
Finding #2024-001 – Material Audit Adjustments Criteria: Proper financial closing and year-end reconciliation procedures should be in place to identify and adjust the financial records to ensure the financial statements are fairly stated. Condition: The auditors proposed audit adjustments that, if n...
Finding #2024-001 – Material Audit Adjustments Criteria: Proper financial closing and year-end reconciliation procedures should be in place to identify and adjust the financial records to ensure the financial statements are fairly stated. Condition: The auditors proposed audit adjustments that, if not made, would have resulted in the financial statements being materially misstated. Cause: Financial information was not recorded in a timely manner and material adjustments were needed in order to correct various transactions. Effect: The City’s system of internal control may not prevent, detect, or correct misstatements in the financial statements. Financial reports generated by the accounting system may not provide an accurate reflection of the City’s financial position or activities. Not reconciling accounts on a timely basis could lead to errors or other problems not being recognized and resolved. Recommendation: The auditors recommend that policies and procedures should be implemented to ensure account balances are properly recorded and reconciled in a timely manner. Response: The City acknowledges their responsibility for the financial statements and recording of the current year activity. Going forward, the City will work toward verifying that all activity is completely and accurately recorded in the financial records and reflected on the financial statements.
The Association agrees with this finding and is in the process of setting up this procedure. The Association also feels that hiring a CFO will provide additional oversight over this calculation and posting of journal entries for indirect costs. Once the procedures have been set up and implemented th...
The Association agrees with this finding and is in the process of setting up this procedure. The Association also feels that hiring a CFO will provide additional oversight over this calculation and posting of journal entries for indirect costs. Once the procedures have been set up and implemented the Association believes it will be in a much better position to attain accurate financial reporting.
Type: Significant Deficiency Corrective Actions: - Establish compliance calendar and tracking system. - Assign responsibility and require supervisory review. - Monitor reporting timelines. Responsible Parties: Chief Executive Officer and Chief Financial Officer
Type: Significant Deficiency Corrective Actions: - Establish compliance calendar and tracking system. - Assign responsibility and require supervisory review. - Monitor reporting timelines. Responsible Parties: Chief Executive Officer and Chief Financial Officer
Type: Material Weakness in Internal Control Over Compliance Corrective Actions: - Ensure complete documentation is obtained and retained. - Implement monitoring and periodic reviews. - Provide staff training. Responsible Parties: Chief Executive Officer and Chief Financial Officer
Type: Material Weakness in Internal Control Over Compliance Corrective Actions: - Ensure complete documentation is obtained and retained. - Implement monitoring and periodic reviews. - Provide staff training. Responsible Parties: Chief Executive Officer and Chief Financial Officer
Type: Material Weakness in Internal Control Over Compliance Corrective Actions: - Implement reconciliation of each drawdown to actual expenditures. - Require detailed supporting documentation. - Establish supervisory approval process. Responsible Parties: Chief Executive Officer and Chief Financial ...
Type: Material Weakness in Internal Control Over Compliance Corrective Actions: - Implement reconciliation of each drawdown to actual expenditures. - Require detailed supporting documentation. - Establish supervisory approval process. Responsible Parties: Chief Executive Officer and Chief Financial Officer
Views of Responsible Officials and Planned Corrective Action While the Organization understood the prior year finding (2023-006) and current year renumbered recommendation (2024-006), the Organization notes the corrective actions that have been implemented, The Organization notes the following exist...
Views of Responsible Officials and Planned Corrective Action While the Organization understood the prior year finding (2023-006) and current year renumbered recommendation (2024-006), the Organization notes the corrective actions that have been implemented, The Organization notes the following existing internal control practices, as it relates to cash management subsequent policy and process development and implementation, and the additional controls to be implemented: A. System, Process & Review Controls In Practice. 1. System Controls. The Organization operates in an environment in which system, process & review controls of the United States Department of Health and Human Services (HHS) are practiced in processing cash (draw) transactions in both the Electronic Handbook (EHB) and Payment Management System (PMS) systems, operated by HHS. Only the director of administrative operations and the CEO have system access to the EHB and PMS systems. 2. Process & Review Controls – EHB & PMS. Cash management requests (aka federal draws) are computed by, and entered into the EHB, including the Organization’s justification of the expenditure, by the director of administrative operations, including the CEO on the approval request. The propriety of the cash draw is reviewed by the HHS assigned grants management specialist; and inquiry action, if needed, documented by e-mail from the grants management specialist; and approval documented in the EHB. Once the draw is approved, the director of administrative operations enters information into the PMS, noting that the CEO, is the authorized organization representative (AOR). The grants management specialist must then approve the draw request once more in the PMS system before a PMS representative approves the draw request. 3. Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls include review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds – Additional Information and Statistics, Native Hawaiian Health Program (Fund 007V), and Native Hawaiian Health Scholarship Program (Fund 017V). B. Internal Control Environment Policy Establishment – July 2025. In July 2025, the Organization developed the following cash management related policies and related procedures: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. C. Additional Process & Review Controls – March 2026. Beginning March 2026, for federal draws, process and review internal controls will be implemented, via the chief of staff’s review of the director of administrative operations cash management analyses, federal grant receivable composition, reconciliation and related federal grant revenue computations, prior to any director of administrative operations and chief executive officer action in EHB and PMS, respectively. The current practices of the Organization, to the present period of the report dated June 17, 2026, is consistent with such developed policies.
Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), §200.334, requiring “Fina...
Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), §200.334, requiring “Financial records, supporting documents, statistical records, and all other non-Federal records must be retained for a period of three years from the date of submission of the final expenditure report…”, and recommendation made. The Organization further refers to the corrective action plan of Finding No. 2024-002: Subrecipient Monitoring, which describes the Organization’s implemented changes re: Subrecipient Monitoring and Management, Retroactive Subrecipient Portfolio Risk Assessment and Correction(s), and Subrecipient Policies and Procedures. Contractor Performance Collection and Substantiation – November 2024 The Organization has incorporated specific review procedures to ensure the timely collection and substantiation of contractor performance deliverables (e.g., products, goods, services, activities, reports), consistent with the terms and conditions of the contract. The current practices of the Organization, from the above date, to the present period of the report dated June 17, 2026, is consistent with such developed procedures.
Views of Responsible Officials and Planned Corrective Action The Organization concurred with the prior year (2023-004) and current year renumbered recommendation (2024-004), acknowledging that the unexpected resignation of the former independent auditor (January 2023), and the domino effect of a del...
Views of Responsible Officials and Planned Corrective Action The Organization concurred with the prior year (2023-004) and current year renumbered recommendation (2024-004), acknowledging that the unexpected resignation of the former independent auditor (January 2023), and the domino effect of a delay in securing a new independent auditor (April 2023) continue to challenge the Organization, however, the Organization notes the status and progress of the following single audits: • June 30, 2022, filed in the Federal Audit Clearinghouse (FAC) in February 2025. • June 30, 2023, filed in the FAC in March 2026. • June 30, 2024, final review by Board in progress, projected filing in the FAC in June 2026. • June 30, 2025, engagement field work in progress with projected filing date no later than September 2026. • June 30, 2026, engagement letter signed with scheduled field work to commence after the June 30, 2025, audit FAC filing; projected to be completed with related FAC filing, no later than March 2027. The Organization notes the corrective actions that have been implemented, regarding internal controls to ensure compliance with the Uniform Guidance with respect to the submission deadline of single audit reports and the Data Collection Form: A. Internal Controls in Practice Since Inception of New Auditor Engagement – April 2023. As noted in the prior year corrective action response, the Organization established internal compliance controls related to the timely submission of single audit reports. Such process and review controls are implemented by the director of administrative operations, chief of staff (since December 2024), and chief executive officer; and subsequently communicated to the Board finance sub-committee and full Board, including the documented Board action(s) taken (e.g., Board agenda, minutes). B. Financial Policies and Procedures – May 2025. By May 2025, the Organization completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. Note the internal control policy of the Organization documents process and review controls, which were already in practice, applying to the timely filing of single audit reports. The current practices of the Organization, to the present period of the report dated June 17, 2026 is consistent with established process and review controls for timely submission of single audit reports.
Views of Responsible Officials and Corrective Action While the Organization concurred with the prior year (2023-003) and current year renumbered recommendation (2024-003), the Organization notes the corrective actions that have been implemented, specifically related to the incorporation of the procu...
Views of Responsible Officials and Corrective Action While the Organization concurred with the prior year (2023-003) and current year renumbered recommendation (2024-003), the Organization notes the corrective actions that have been implemented, specifically related to the incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h); and development of a comprehensive Health Resources & Services Administration (HRSA) group of related policies and procedures. A. Financial Policies – May 2025. While the Organization initially prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024, by May 2025, the Organization completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Simultaneous to the policy work described above, several processes to guide and align procurement practices, throughout the Organization, was initiated, including the use of MTPF, Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal, and to date implementation of the processes continue. C. HRSA Policies – July 2025. By July 2025, the Organization developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. In August 2025, the Board was provided policies developed within the Organization’s policy framework, including the above policies. The current practices of the Organization, to the present period of the report dated June 17, 2026, is consistent with such developed policies.
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