The purpose of this policy is to establish procedures for ensuring the continued integrity of a company’s internal controls system. Companies experience periodic personnel and process changes, which result in changes to business processes and to who is responsible for the ownership and execution of internal controls.

This policy is designed to ensure timely transition of internal control responsibilities and continued and ongoing execution of key controls. Moreover, this policy ensures that the company’s internal control documentation is maintained throughout the year to reflect the actual controls that are in place and that individuals are responsible for the execution of such controls.