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Internal Control Plan

               Introduction

               Every organization, be it governmental, for profit, or not-for-profit, exists to achieve some
               purpose or goal. CSCS’s goals are outlined in its Mission Statement that assures Members
               receive the  benefit of continuously  available goods and  services at the lowest sustainable
               delivered prices, and coordinate with the Brands in their on-going development and innovation

               in support and promotion of their Concepts. Internal control is a coordinated set of policies
               and procedures for sustaining these goals over the long term.

               This document presents the internal control plan for CSCS. The internal control plan
               addresses the establishment and implementation of proper controls for business processes
               of the Co-op and how mechanisms have been established to safeguard the organization’s
               assets and ensure proper use of resources. The format employed for this document follows
               the guidelines recommended by Committee of Sponsoring Organizations of the Treadway
               Commission (COSO), Internal Control – Integrated Framework, December 2011.


               CSCS team members have assessed known risks for business processes, developed controls
               to minimize those risks, and developed a plan that will formally monitor the internal control
               plan. This plan will be modified and updated based upon any findings in subsequent reviews.

               The following sections will discuss each component of CSCS’s internal control plan including:
               Control Environment, Risk Assessment, Control Activities, Monitoring, and Information and
               Communication.
               Internal Control: Overview

               The Committee of Sponsoring Organizations of the Treadway  Commission (COSO), is
               sponsored and  funded by five  main professional accounting associations and institutes;
               American Institute of Certified Public Accountants (AICPA), American Accounting
               Association (AAA), Financial Executives International (FEI), The Institute of Internal
               Auditors (IIA) and The Institute of Management Accountants (IMA).

               The COSO framework defines internal control as a process, affected by an entity’s board of
               directors, management and other personnel, designed to provide reasonable assurance
               regarding the achievement of objectives in the following categories:

                         •    Effectiveness and efficiency of operations
                         •    Reliability of financial reporting
                         •    Compliance with applicable laws and regulations

               COSO has established  a common  definition of internal controls, standards, and  criteria
               against which companies and organizations can assess their control systems. According to
               COSO, a comprehensive framework of internal control consists of the following five
               interrelated components.

               1. Control Environment: This is the foundation for all other components of internal control
               encompassing such factors as integrity and ethical values, commitment to competence,
               boards of  directors  and audit committee participation, management’s philosophy and


               Centralized Supply Chain Services, LLC.                                                 Page 5
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