The objective of this policy is to summarize management’s approach to plan, organize, execute, document and support its assessment of the effectiveness of the company and its subsidiaries' internal controls over financial reporting.

Controls that are significant generally include: controls over initiating, authorizing, recording, processing and reporting significant accounts, disclosures and related assertions embodied in the financial statements; controls over the selection and application of accounting policies that are in conformity with generally accepted accounting principles; anti-fraud programs and controls; and controls, including information technology general controls, on which other significant controls are dependent.