Corrective Action Plan:
The Corporation will enhance internal control procedures to ensure that all cash disbursements
are reviewed and approved by management before issuance. The procedure will involve:
1. Voucher Review Protocol:
A checklist will be created to ensure that all disbursements are accompanied by
documented approvals. This checklist will include verification of the approval by both
management and legal counsel when necessary.
2. Management Approval:
Disbursements, particularly those over $500,000, will require formal sign-off from the Chief
Executive Officer and review by the Legal Department.
3. Training & Compliance:
Staff will be trained on the updated process, and compliance will be regularly reviewed by
the internal audit team. A report on adherence to these new procedures will be made
available to the Board quarterly.
4. Verification of Prior Disbursement:
Regarding the specific instance cited, management will review the process followed to
verify that the review by Albanese and LDC counsel, as referenced in the email, was
correctly documented. If this was indeed the case, a follow-up with the auditors will be
initiated to clarify the discrepancy.
Responsible Individual:
Joseph Ninomiya - Chief Executive Officer
Planned Date of Implementation:
October 15, 2024