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Internal Control Plan


                       each Associate to identify goals, objectives, and expectations for the year. Associates
                       use the document to understand their key accomplishments.

               Annex D outlines control matrices for functional areas which show key controls that address
               specific risks.

               Monitoring

               Monitoring is the process that assesses the quality of internal control performance over time
               and taking actions as  necessary to ensure it continues to address the risks of the
               organization. Monitoring is effective when it leads to the identification and correction of
               control weaknesses before they materially affect the achievement of the organization’s
               objectives. Monitoring is a cost-effective approach to providing timely information about the
               continued effectiveness of an internal control system. As such, effective monitoring is a net
               benefit to organizations and their stakeholders. Effective and efficient monitoring is best
               achieved by:

                   1.  Establishing a foundation for monitoring, including a proper tone at the top,
                       organizational structure and a baseline  understanding of internal control
                       effectiveness
                   2.  Designing and executing monitoring procedures that seek to evaluate "persuasive"
                       information about "key controls" addressing "meaningful risks" to  organizational
                       objectives
                   3.  Assessing results and reporting them to appropriate parties

               CSCS internal control program, including this document, will be reviewed annually with the
               Boards’ Audit & Finance Committee. The Co-op communicates risk policies to employees and
               external business partners on an ongoing basis. The executive team constantly reviews the
               status of risks, losses and major control breaches.

               Besides reviewing the results of the annual internal control audit with the Audit & Finance
               Committee, ad hoc reviews will be conducted for certain functional areas such as compliance
               reviews on various contracts to determine any gap that needs to be addressed. Annex E
               provides samples of Internal Control Questionnaires utilized by CSCS’s Compliance Team.
               Information and Communication

               Information and communication are the identification, capture, exchange of information in
               a form and time frame that enable people to carry out their responsibilities, and are essential
               to effecting control.

               CSCS currently uses an integrated supply chain management system provided by a third
               party supplier. The web-based solution enables CSCS to:

                   •  Manage data on brand products, operators, restaurants, vendors, contracts, and
                       distribution partners,
                   •  Connect with distribution partners to update daily inventory information, purchase
                       orders, and sales to restaurants,

               Centralized Supply Chain Services, LLC.                                                 Page 8
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