20091013UWI to Staff 11, 14.pdf

[phone]
[phone] (Fax)
Via Hand Delivery
Jean Jewell, Secreta
Idao Public Utities Commssion
472 W. Washigton St.
Boise, Idao 83720
McDevitt & Miller LLP
Lawyers RECEIVED
420 W. Bannock St,"fi OCT 13 PH l: 38
P.o. Box 2564-831U'f
Boise, Idaho 83702, lDAJiO P!~¡:;L
UTiLITIeS CO¡j\l,~
October 13,2009
Re: Case No. UWI-W-09-01
General Rate Case Filing
Dear Ms. Jewell:
Enclosed for fig, please fid thee (3) copies of United Water Idaho's Fifth Response to
Commssion Staffs First Production Request No.'s 11 and 14.
Kidly retu a fie staped copy to me.
DJM/hh
End.
Very Truy Yours,
McDevitt & Mier IL
Wu~
Chas. F. McDevitt
Dean J. (Joe) Miler
ORl.GlNAL
RECi: fì.'" - ,,-
Dean J. Miler (lSB No. 1968)
McDEVITT & MILLER LLP
420 West Banock Street
P.O. Box 2564-83701
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
joe(imcdevitt -miler. com
in09 OCT 13 PM I: 39
Attorneys for United Water Idaho Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
INTHE MATTER OF THE APPLICATION OF )
UNITED WATER IDAHO INC., FOR )
AUTHORITY TO INCREASE ITS RATES AND ~
CHARGES FOR WATER SERVICE IN THE )STATE OF IDAHO )
)
CASE NO. UW-W-09-01
UNTED WATER IDAHO INC'S
FIFTH RESPONSE TO
COMMISSION STAFF'S FIRST
PRODUCTION REQUEST
United Water Idaho Inc, ("United Water") by and though its undersigned attorneys,
hereby submits its Fift Response to the Commission Stas First Production Request No.'s 11
and 14.
DATED ths \s day of October, 2009.
Jsi:mC.
Dean J. Miler
McDevitt & Miler LLP
420 West Banock
Boise, Idao 83702
P: 208.343.7500
F: 208.336.6912
Attorney for United Water
UNITED WATER IDAHO INC'S FIFTH RESPONSE TO COMMISSION STAFF'S FIT
PRODUCTION REQUESTS- 1
CERTIFICATE OF SERVICE
I hereby certify that on the ,,~ day of October, 2009, I caused to be served, via the
methodes) indicated below, tre an~~ect copies of the foregoing document, upon:
Jean Jewell, Secreta
Idaho Public Utilties Commission
472 West Washington Street
P.O. Box 83720
Boise,ID 83720-0074
jjewell(ipuc.state.id. us
Hand Delivered
U.S. Mail
Fax
Fed. Express
Email
K..
~..
~..ù
UNITED WATER IDAHO INC'S FIFTH RESPONSE TO COMMISSION STAFF'S FIRT
PRODUCTION REQUESTS- 2
I .
:
i
UNTED WATER IDAHO INC.
CASE UWI-W-09-01 2009 OCT 13 PH l= 41
FIRST PRODUCTION REQUEST OF THE COMMISSII~~i~rMlUI;5JJ(~
U IILlTH"S r(H'ü,Ut,c:¡t");.¡-- v '.... ~I,. "l. O"'J~. \;¡ l'
RECEiVFn
Preparer: An Koesterer-Director of Internal Audit
Sponsoring Witness: Kevin Doherty
REQUEST NO. 11:
Please provide a descriptive list of all reports, letters, and memoranda prepared by the
Company's Internal Audit (or similar) staff in 2006 to date which documents areas reviewed by
them. Please have the documents available for on-site review at UWI offces. Please include
with your response any reports that document reviews of procedures that affect UWI even if
UWI was not the specific focus of the review (such as corporate processes).
RESPONSE NO. 11:
The descriptive list of all report/letters and or memoranda prepared by Internal Audit requested
is shown below. Please refer to the attched reports for reviews of procedures.
Internal Audit Reports issued between 2006 to 2009:
2006:
· United Water New York-Distrbution and Maintenance
· United Water Connecticut-Ethcs Review
· United Water New Jersey-Distrbution and Maintenance
2007:
· UWNJ-Misuse of Procurement Card (Personal Charges)
. Follow-up Audit of United Water New York-Distrbution and Maintenance
· Audit of Employee Travel and Reimbursable Expenses
· 2006 Sarbanes-Oxley 302 Review
. Audit of United Water Laurel, Mississippi
~ Audit of United Water New Jersey Distrbution and Maintenance and Asset Accounting
Processes
2008:
. United Water Camden
. United Water-West Basin, Californa
. United Water-Avalon, Californa
. United Water-Burban, Californa
. United Water-Banng, Californa
. United Water Springfield
· United Water Pennsylvania-Transmission, Distrbution/aintenance, Constrction and
Asset Accounting
· United Water Gar-Gas Card Theft Investigation
· 2007 Sarbanes-Oxley Section 302 Process
2009:
. American Leasing Review
· United Water New Rochelle and United Water Westchester-Transmission and
Distrbution and Asset Accounting
. United Water Holyoke
· United Water Arkansas-Revenue Cycle
. United Water Connecticut
. Sarbanes-Oxley 302 Report
. Corporate Procurement Card (P-Card) Follow-up Audit
. United Water New Jersey-Transmission, Distrbution/aitenance, Constrction and
Asset Accounting Follow-up Audit
. United Water Spnngfield
Other Internal Audit Projects (Reports not issued):
. INCOME Review and Testing (Sarbanes-Oxley Section 404 Testing):
United Water Idaho is included in scope of testing as of 2009.
. Anua Confict of Interest Statement Mailng (no conficts reported for United Water
Idaho)
. Mazs External Audit Year-end support (600 hours)
o~( United Watero .svez
2006
SARBANES-OXLEY
SECTION 302
REVIEW REPORT
May 18, 2007
UNITED WATER
200 Old Hook Road, Harrington Park, NJ 07640
Tel: [phone]. Fax: [phone]
Ann.Koesterer~unitedwater.com
o~~o United Water..'-ez..
ANN KOESTERER
Director of Intrnal Audit
Date:May 18,2007
From:An Koesterer
To:Tony Harding
cc:R. Iacullo
JC. Goldman
E. Imparato
R. Gerber
X. Boulat
A. Trujilo
C. Wall
D. Cole
M. Trousseau
Ernst and Young: D. Glina
M.Nagy
Audit Committee: Ed Bar, Chairman
Jean Marc Boursier
L. Codey
SUBJECT:AUDIT REPORT:
2006 SARANS-OXLEY SECTION 302 REVIW
Every year, Internal Audit pedorms a Sarbanes-Oxley Section 302 review to ensure
United Water's disclosure controls are adequate and fuctionig as intended. Attached is
the Audit Report for the 2006 Sarbanes-Oxley Section 302 review. The report provides
an opinion regarding the adequacy of disclosure controls, as well as recommendations for
improvements.
If you have any questions, do not hesitate to contact me. Th you for the assistace
provided to Internal Audit durg ths review.
UNTED WATER
AUDIT REPORT:
2006 SARANS-OXLEY SECTION 302
REVIW
TABLE OF CONTENTS
PAGE
BACKGROUN
OBJECTIVS AN SCOPE
CONCLUSION
1
1
2
ISSUES AND RECOMMNDA nONS:
1. The Information Technology Reportg Line Should Be Reevaluated For The 3
Contract Services Segment.
2. Management Should Consider Establishing A Corporate Ethics Training Program. 3
BACKGROUN
In 2002, the SEC adopted new legislation known as the Sarbanes-Oxley Act. The SEC's
main objective in creating ths act was to improve corporate governance and oversight, as
well as to requie increased accountability of senior management for reporting and
disclosing corporate financial results and data. The Sarbanes-Oxley Act applies to all
"issuers" (publicly traded companes) who are mandatory reporting companes.
Although United Water is not a publicly held company, our parent, Suez, is publicly held
and traded on the New York Stock Exchange and is therefore required to comply with the
Sarbanes-Oxley Act. As par of Suez's compliance process, and in order to support Suez'
certification under the Sarbanes-Oxley Act, Suez requested that its subsidiares comply
with certn aspects of the Act, specifically Section 302. Section 302 relates to corporate
responsibility for finacial reporting and requires the CEO and CFO to certify to reports
submitted to the SEC. Ths certification includes the acknowledgement that the
certifying officers have reviewed the report and, based on their knowledge, are not
aware of any untre statement of material fact. It also requies the offcers to
acknowledge that they are responsible for establishig and maitag internal controls
and that these controls have been designed properly, have been evaluated, and are
effective.
To comply with the Act, Suez requied its subsidiares to attest to a similar certification
that they were requied to make. In response to Suez' request, United Water developed a
process/strctue for United Water tht would enable us to comply with Section 302 of
the Sarbanes-Oxley Act on an on-going anual basis.
OBJECTIVS AN SCOPE:
In order to support United Water's CEO and CFO certifications, United Water developed
an approach, simlar to Suez's approach, to provide assurance that United Water's
disclosure controls and procedures were in place and fuctioning to ensure that financial
and non-financial information communcated to Suez through the SAFIRE package was
complete and accurate. This process was intially designed and implemented in 2003 and
has been executed each year, thereafter.
A 4-level certification structue/process was developed for United Water that required
certification at all four levels of management. It is a layered approach, in which one layer
relies upon the certification from the previous layer. For example: the Segment Finance
Director provided a certification to the Segment COO and the Segment COO and Finance
Director provided certifcations to the Drafer of SAFIRE. The Drafer of SAFIRE then
provided a certification to the Reviewer of SAFIR who, in retu, provided a
certification to the CFO and CEO. Ultiately, the CEO and CFO.received certifications
from all of the aforementioned areas, as well as from the Vice-Presidents of key M&S
areas, such as Legal, Tax, Procurement and Human Resources.
In order to support the certification process, the four levels of management were
interviewed. The purose of these interviews was to document the key disclosure controls
1
for their areas of control. Each year, these interviews are reviewed and updated.
Additionaly, a disclosure control questionnaire, which was intended to gather inight
into potential risks, mitigatig controls, management concerns, and key disclosure
controls, was completed/updated by the interviewees for each area reviewed. Each
member interviewed was requied to complete ths questionne, which is also updated
anually. The objective of the intervews and questionnaie process was to identify and
document key disclosure controls thoughout the organation and to determne whether
these controls are adequate. Where disclosure controls were noted to be deficient,
appropriate recommendations were made to strengten controls. Ths exercise was also
used as an opportty to not only strengten disclosure controls, but also to improve
other internal controls and processes, where applicable. Additionally, disclosure control
recommendations from the previous year were followed-up to ensure prior
recommendations were implemented.
Before the CEO and CFO provides their certifications, the United Water Disclosure
Commttee meets, in order to discuss the Sarbanes 302 fidings and recommendations
and to review management's certifications to ensure that all disclosures that should be
made to Suez have been properly disclosed.
CONCLUSION
In our opinion, the disclosure controls and procedures throughout United Water appear to
be more than adequate to ensure that financial and non-financial inormation
communcated to Suez though the SAFIRE package are both complete and accurate.
Although there were no signficant disclosure control weakesses noted durg our
review, there were a few opportties noted that could fuer enhance disclosure
controls.
2
ISSUES AN RECOMMNDATIONS:
1. The Information Technology Reportg Line Should Be Reevaluated For The
Contract Services Segment.
The curent corporate strctue for Inormation Technology (IT) needs to be reevaluated.
The Contract Servces segment IT group has no formal reporting line to Corporate IT.
The reporting lines should be reviewed to determine whether a dotted-line of reporting
should be implemented from the Contract Services to Corporate IT, to ensure corporate
IT policies and procedures are being followed in the Contrt Servces segment.
Additionally, a monthy reportng should be established, in order to report signficant
issues to Corporate IT. There should also be an emergency reportg procedure from
Contract Operations IT to Corporate IT, which should be utilized if specific criteria are
met.
Recommendation:
Management should review the curent IT reporting strctue to determne whether a
formal dotted line of reportng should be established between the Contract Services
segment IT group and Corporate IT. Formalized monthy reportg should also be
developed.
Management Response:
A dotted-line of reporting will be established from the Contract Servces segment IT to
Corporate IT.
Ths dotted-line is to ensure that:
~ United Water IT policies and procedures are being followed for UW systems
~ A reporting is developed and used (monthy report, emergency procedure, etc...),
~ We can leverage all our experience across United Water.
Practically, Lar Patterson will coordinate the Contract Servces segment IT for the
above puroses and will have a dotted-line of reporting to the IS Security & Quality
Assurance Director at Corporate IT, Gar Clark. Ths wi be communcated to the
Corporate and Contract Services stctues before the end of May 2007.
2. A Corporate Ethics Training Program Should Be Considered.
Management should consider developing a formalized Corporate Ethcs trning program.
Although there has been increased communcation thoughout the Company regarding
the Ethcs Commttee and the Ethcs hotline, there is no formal Ethcs traing program
curently in place for United Water employees. A traig program could benefit the
Company by makng employees more aware of what is considered acceptable ethcal
behavior and what is considered an ethics violation that would warant reportng. The
3
trainig could also aid in providing gudance to an employee regarding how to proceed
when faced with a potential ethcs issue, and how to report such issues.
Recommendation:
Management should consider implementing a formalized Ethcs trainig program to be
utilized throughout United Water.
Management Response:
Management agrees that the introduction of a more formal ethcs traig program would
be beneficial. To that end, United Water and Suez Environment are working with
Transparency Interntional ("TI"), the leading internationa. non-governental
organzation devoted to combating corrption. As par of ths collaboration with TI,
United Water is performing a self assessment of its ethcs related policies and controls,
parcularly with respect to fighting against corrption. We are interviewig senior
executives and managers to assess the risk of corrption in our businesses. Our Code of
Ethics and practices will be modified as necessar to reflect the fidings of our self
assessment. It is likely that recommendations with respect to ethcs traig wil result
from ths review.
On April 27, 2007, Suez held a Business Ethcs traing session with approximately 25 of
our managers in the Legal, Human Resources, Intern Audit, Procurement, Finance and
Engieerig areas. The value of ths program is being assessed for puroses of rollng out
similar programs for operational and fuctional managers across United Water. It will be
important that senior managers are traied on ethcs related issues to enable them to push
ethcs training down lower in the organzation.
As United Water does not have an Ethcs Deparent, we need to look at cost effcient
means to implement traig programs. For instance, we will exame the use of
computer learng programs on important ethcs topics. We believe such programs
provide an opportty to reach many employees at a reasonable cost.
4
o~( United Watero .svez
AUDIT OF THE
CORPORATE
PROCUREMENT CARD
PROCESS
February 6, 2007
UNITED WATER
200 Old Hook Road, Harrington Park, NJ 07640
Tel: [phone] . Fax: [phone]
Ann.Koesterer~unitedwater.com
o~~ United Water..'-ez"
ANN KOESTERER
Director of Internal Audit
Date: Februar 6, 2007
To: Joel Tache
From: An Koesterer
Distnbution: A. Harding
X. Boulat
R. Iacullo
JC Goldman
W. Hil
M.McKoy
M. Gennar
M.Onojeta
M. DiVincenzo
Ernst and Young: D. Glink
M.Nagy
Audit Committee: E. Bar, Chaian
L. Codey
Jean Marc Boursier
Subject:Audit Report -Corporate Procurement Card Process
Please find atthed, the audit report for the Corporate Procurement Card Process. If you
have any questions, do not hesitate to contat me.
Th you for the assistace provided to Internal Audit durng our review.
UNTED WATER
INTERNAL AUDIT DEPARTMNT
AUDIT REPORT
AUDIT OF CORPORATE PROCURMENT CAR PROCESS
TABLE OF CONTENTS
PAGE
EXECUTIV SUMRY:
(Icludes Background, Objectives, Scope and Conclusion)
1,2,3
AUDIT ISSUES AN RECOMMNDATIONS:
1. The P-Card Program Lacks Ownership, Oversight and Adequate Resources. 4
2. The Approval Process, Required To Obta A P-Card, Needs To Be Revised. 5
3. Lack of Supervisors !Manager's Review and Approval ofP-Card Statements 7
And Purchases.
4. P-Card Purchases Are Being Made In Violation ofP-Card Policy. 9
P-CAR MEMO-ACTION PLAN (Prepared by Management):12
EXECUT SUMY
The United Water Corporate Procurement Card (p-card) was fist introduced in 1997 as a
more effcient method of purchaing low cost items. Corporate savigs are realized with
the use ofP-cards because it reduces the volume of purchae orders and check payments
to be processed for small transactions. Mastercard, though Mellon Ban was selected as
the provider of United Water's P-card service. As of November 2006, there were 551
active P-cards issued companywde, with the majority of cards held in United Water
Idaho, United Water New Jersey and varous United Water Pennylvana locations
(reguated and contract services). From the time the P-card program began in 1997, tota
companywide P-card purchases have increased from $55,000 in 1997 to approximately
$2.0 millon in 2006.
The objective of our audit was to review the Corporate Procurement Card program to
determe whether the curent process is adequately controlled and is fuctionig as
intended. The process was reviewed to ensure tht purchases being made by P-card
holders are with company policy guidelines, are adequately supported with receipts and
are being properly reviewed and approved by the P-cardholder's supervisor. Our review
covered P-card purchase activity for the first eight months of 2006.
The adstration of the United Water P-card program is fragmented. It is handled both
centrally, in Procurement, as well as decentrally at the business unt leveL. The issuace
of P-cards, the reconciliation of individua monthy P-card statements to the consolidated
P-card statement, maitag records, and remitting payments to Mellon Ban are
fuctions that are centralized in the Procurement Deparent. Authorization and approval
of P-card applications, maintang purchae records and receipts of purchaes,
monitorig the use of the P-card, and approving the cadholder's statements are fuctions
tht are handled at the business unt level by an individua's business unt
supervisor/manager.
In order to obta a P-card, an employee must complete a P-card application with their
Supervisor's wrtten authorization. Once the application is received in Procurement, a P-
card is issued to the applicant with the P-card agreement, which outlines the policies and
procedures. The P-card applicant is requied to read the policies and procedures, sign the
agreement and retu it to Procurement.
P-card statements are, essentially, credit card statements. Each individua P-cardholder
receives a monthy individua statement, which should be remitted, with the supporting
receipts, to jheir supervisor/manager for approvaL. The receipts are to be retained by the
P-cardholder and the approved statements are to be forwarded to Procurement to be
processed for payment. The consolidated P-card statement is paid prior to receiving the
individua statements, to ensure that the bil is paid timely. The reconcilation of the
approved individual statements to the consolidated statement is performed, afer the fact,
by Procurement.
1
In performing our review, it was noted tht the United Water Procurement Card (P-card)
program is not fuctionig as intended. Although there are comprehensive policies and
procedures in place to guide the purchase and approval of goods with the use of a P-card,
there is no one fuly responsible for the entire process and for ensurg that these policies
and procedures are being followed. As a result, there were many process deficiencies and
P-card violations noted durg our review. For example, many P-card holders are makng
purchases tht are not withi company P-card policy gudelines, such as meals, gas,
computer equipment and grocery store purchases. The P-card policies and procedures
statement, which P-cardholders were requied to sign before receiving their P-card,
specifically states that these tyes of purchaes are not allowed, however P-cardholders
continue to make these purchaes. There are also many cases in which P-cardholder's
individua statements of purchases are not being approved by their supervisor/manager.
Additionaly, when requested, may P-card holders either did not have receipts, or did
not have adequate receipts, to support their purchases.
The curent P-card process signficantly lacks adequate controls. In order for the P-card
to be an effective purchasing tool for United Water, the process needs to be strengtened.
Mangement needs to redesign the P-card process and establish a tre centralized
ownership for the program, which will provide adequate oversight and enforcement.
Maagement should also ensure that suffcient resources are dedicated to the program to
ensure that it is properly admstered.
Additionally, the number of P-cards issued is excessive and should be reduced. The
responsibilty for authorizing and approving P-card applications is placed too low at the
supervisor/manager leveL. The list of employees that are curently holding P-cards needs
to be reevaluated by a higher level of management and only employees that try require
the card should be authorized as a P-cardholder.
2
Distribution ofP-cards by Business Unit and Location
% ofTotalP-
Business Unit Locations P-cards cardsUWBoise107 19%
UWPA P A All Locations 73 13%
UWJ Hackensack & Hawort 52 9%
UWAR Pine Bluf 49 9%
UWM&S HP & Oradell 48 9%
UW Clemmons, Durham,Durham, Clemmons etc
Hydro 24 4%
UWFL Jacksonvile 20 4%
UWE Wilmington 20 4%
UWN West Nyack 19 3%UW New Rochelle 13 2%
UW Stonington Pawcatuck 12 2%UW Wakefield 11 2%
UWS Glyn County Saint Simons Is 10 2%
UW Sprigfield Agawam 10 2%
UW Milwaukee Milwaukee 9 2%
UWO Owego 7 1%
UW Killingly Danielson 6 1%
UW Jersey City Jersey City 5 1%
UWIndy Indianapolis & Gar 5 1%
UWCamden Camden 5 1%
Others 46 9%
Total 551 100%
3
AUDIT ISSUES AN RECOMMNDATIONS:
1. The P-Card Program Lacks Ownership, Oversight and Adequate Resources.
The company P-card process lacks ownership, accountability and oversight, as a
result of its curent strctue. Curently, the responsibility for adstering the P-
card program is split and responsibilities for the program are assigned to varous
lower level employees. The admstration of the P-card process is assigned to two
Procurement Clerks who have had little success in enforcing the policies. Although
the P-card policy provides the Adminstrators (Clerks) with the authority to cancel an
individua's P-card for non-compliance or purchase violations, the Admistrators
very rarely utilize ths authority. The lack of enforcement is maiy due to the
Admstrators not feeling that they have the adequate power or authority to enforce
the policies of the P-card, because of their lower level management status. Also, the
two Administrators have other ful time duties withn the Procurement Deparent
and do not have sufcient resources to properly admister the program.
Additionally, the responsibility for monitoring P-card spending is delegated to the
supervisor or manager of the P-cardholder, however, in many cases, the
supervisors/mangers are not reviewing the statements and charges. Due to the lack
of oversight over the process, there are many P-card invoices/statements being paid
without adequate approval.
Recommendation:
The P-card process should be redesigned with accountabilty for the process assigned
to a specific individua or deparent and clear policies and procedures must be
enforced. Adequate resources should be provided to the individual or deparent
charged with the admstration of the P-card in order to provide adequate oversight
for the entie program. The selected owner of the process should also be at a higher
level of management in order to effectively enforce the policies and procedures,
including termnating P-cards if a P-cardholder does not comply with the policies and
procedures of the P-card program.
Enforcement of the P-card policies and procedures is key for the P-card program to be
successfuL. The following are additional steps that should be taen by the
Admnistrator to aid in the enforcement of the P-card policies:
. The Admnistrator of the P-card program should be trackig P-card violations
in a database.
. A stadad form should be developed by the Admnistrator, which can be used
to notify the appropriate management if there is a P-card violation for an
individual. For example, if a Supervsor/Manager has not approved one of
4
their employee's P-card statements, a "non-compliance" memo should be sent
to the P-cardholder's supervisor, with a copy to the General Manager. If there
is a secnd violation for ths P-cardholder, the P-card should be cancelled.
Management's Response:
The United Water Purchasing card is a useful tool to purchase and pay for low cost
materials and services, thereby elimintig the cost of purchase processing and
reducing the number of checks processed for lower dollar transactions. It is agreed
that ths program lacks ownership, oversight and accountabilty. Whle the policy and
procedures are clearly outlined for each individua, these policies have been
overlooked by many users and their supervisors.
Management agrees that for the United Water Purchasing card to be used effectively,
tighter controls must be put in place. Therefore, the Procurement Deparent will
have the responsibilty for admstration of the P-card and enforcing the policies and
procedures.
It should also be noted that while Procurement wil be responsible for admistration
and enforcement, the cardholder will ultimately be accountable for their expenditues
and their respective supervisors and managers responsible for overseeing and
approvig their charges in a timely fashion.
In order to tighten controls on enforcement, Management agrees that additional steps
must be taen which include the Adminstrator maitaining a database of users, their
supervisors, and any violations of policy, along with the development of a new "non-
compliance" form which will be sent should non-compliance exist.
Please refer to the attched memo for fuer details on the action plan.
2. The Approval Process, Required To Obtain A P-Card, Needs To Be Revised.
In order to obtain a P-Card, the applicant must submit a completed application to
Procurement, which has been authorized by the applicant's supervisor. Once an
approved application is received in Procurement, Procurement sends a P-Card to the
applicant with a P-Card agreement, which includes the P-Card policies and
procedures. The agreement is to be signed by the applicant and retued to
Procurement, where the agreement is then filed.
In performg our review, Audit noted that approximately 40% of our sample (36 out
of 90) ofP-cardholder's applications were not on file in Procurement. Audit followed
up on a few of the missing applications from our sample to determe whether an
application was ever submitted. According to several of the P-cardholders with the
missing applications, they were given the P-card many years ago and did not recall
5
completing an application. Audit also noted that one P-card applicant, selected from
our sample, had approved his own application.
In addition to the deficient application process, signed P-card agreements are not
always being retued by the cardholders/applicants afer the applicants have received
their P-cards. Consequently, there is no assurance tht cardholders understood and
intended to comply with the policy. Also, the P-cardholder's supervisor is not always
listed on the P-card statement, which makes it diffcult for Procurement to follow up
with the cardholder's supervisor.
Audit also noted that there are an excessive number of P-cards for many business
unts. P-cards should be provided to only those individuas tht have a valid business
need and should not be arbitrarly distrbuted. Curently, the authorization level
requied to obta a P-card is at the supervisory level, however, ths does not appear
to be an adequate level of authorization. Audit's review has indicated that there are
many supervisors that are not using good judgment when authorizing cards for their
employees. Generally, a majority of supervisors are authorizing cards to employees
upon request, without determng whether the individuals trly have a valid business
purose for having a P-card.
Recommendation:
Management needs to reevaluate the curent approval process requied for an
individua to obta a P-card. The curent procedure requires the authorization of a
supervsor, however, ths procedure needs to be revised to require a higher level of
authorization, such as a General Manager.
Additionally, the curent list of P-cardholders should be reviewed by a higher level of
management, such as the General Manager, to ensure only individuas with a valid
business need have a card. Those individuas having P-cards, which are deemed to be
unecessar, should have their cards cancelled.
The following are additiona procedural changes that should be implemented:
. All approved P-card applications should be maintaied by the Admstrator
and should be filed centrally.
. The procedure, in which Procurement sends an approved applicant a P-card
with an ageement acknowledgement form, should be revised. Procurement
should send the agreement to the approved applicant fist, and should not send
the P-card until a signed agreement is retued.
. Once the P-card process has been reorganzed and the policies and procedures
have been updated, a revised policies and procedures manual should be sent to
all P-cardholders with a requirement for the P-cardholder to read the manual
6
and sign an updated acknowledgement form, which requies the P-cardholder
to comply with all P-card policies and procedures.
. A database should be developed and maintaed of all P-Card users, indicating
whether an approved application has been received, a signed policies and
procedures agreement is on file, list the curent manager/supervisor of the
cardholder, as well as detals of restrctions on the card (dollar value and
usage tye). Ths database can also be used to record whether there have been
any policy violations by the cardholder.
. The P-cardholder's supervsor/manager should be included on the P-card
statement.
Management's Response:
Mangement agrees tht all active purchasing cards, their credit limits and buying
restrctions be reviewed by Procurement in conjunction with Operations and EMT.
Once the cardholder database is updated, the new policy and procedures will be sent
to every approved cardholder and approvers and a new signed acceptace form will
be required to be submitted to the P-Card Admstrator.
New procedur changes for approval of futue applications will be implemented,
including a requirement for EMT or General Manager's approval and signatue in
addition to the approval and sign-off the cardholder's supervisor. Also, management
agrees with audit's recommendation to require all cardholders and all approvers read
the policy and procedures manual, sign the acceptace form and retu to P-Card
Administrator before receiving their card. In addition, approval will require that all
supervisors/managers print their names, and sign the monthy cardholders' statements.
As indicated previously, a database wil be maintaed by the P-Card Administrator
for all cardholders, approvers and violations.
Please refer to the attched memo for fuer details on the action plan.
3. Lack of Supervisors/Manager's Review and Approval of P-Card Statements
And Purchases.
A signficant number of Supervsors/Managers are not reviewig and approving the
P-card statements of their direct reports. As a result, employees are makg
purchases using the P-card, without proper approval.
Under the curent P-card process, the P-card Administrator pays the consolidated P-
card invoice before approved individual statements are received from P-cardholders.
7
Ths is done to avoid delays in processing the consolidated invoice, which, if paid
late, can result in expensive finance charges. The P-card Admstrtor is supposed
to follow-up and collect the approved individual statements and reconcile them to the
consolidated statement afer the consolidated invoiCe ha been paid, however ths is
not consistently being done. Our review disclosed that many P-cardholders have
never received approval from their supervisors for their purchases, or have not
submitted their individua approved statements to Procurement. Accordig to the P-
card Admnistrator, there have been repeated requests to P-cardholders and/or the P-
cardholder's supervisor for their approved individua statements, however, in many
cases, the cardholders and/or their supervsors never respond. Additionaly, there has
not been any disciplina action taken with cardholders that do not retu an approved
statement.
Audit also Ínade a selection of individua P-card statements tht ha been properly
approved by the cardholder's supervisor, to ensure tht there were proper receipts to
support the approved statements. Audit selected a sample of approved statements and
asked the supervisors and/or cardholders to provide us with the receipts tht
supported the statements. In several cases, supervisors had attempted to obtan
receipts to support the P-card statements, but were not always successfu. The
supervisor's actions indicated tht they had most likely approved the P-card
statements of their direct report, without reviewig the receipts tht supported the
purchases to ensure that they were for valid business purchases.
Recommendation:
Proper approval of P-card charges is essential in ensurg the success of the P-card
program. The supervisor/manager's approval on an individua's statement is the only
approval and oversight that these purchaes receive. If supervsors and managers are
not reviewing their direct reports P-card statements, there is the risk that fraud could
occur and go undetected.
Also, the process whereby the P-card consolidated statement is paid by the
Admstrator prior to receiving the approved individua statements, needs to be
revised. P-cardholders are provided approximately two weeks to have their
individua statements approved and retued to the P-card Adminstrator. Two weeks
appears to be more than ample time for all individual statements to be approved and
retued to the Admstrator before the consolidated statement is required to be paid.
If the Admnistrator has not received all individua statements by the time the
consolidated statement is requied to be paid, the Admstrator should not delay the
payment of the consolidated statement; however, a process needs to be implemented
in which the Admstrator can report those individuals that have not submitted
approved P-card statements. The P-card Admnistrator should develop a stadard
"Non-Compliance" form, which can be used by the Administrator when there is an
issue with a P-cardholders statement or charges. The form should be addressed to the
P-card's supervisor, with a copy to the General Manager. The form should requie a
8
response withn a certn penod of tie, i.e. one week. If a response to the non-
compliance form is not received, P-card pnvileges should be suspended. If ths
sitution occurs twce with the same individua, disciplin action should be taken,
such as cancellng the individua's P-card. The P-card policies and procedures should
be revised to reflect these new procedures.
In addition, although the onginal receipts tht support an individua's P-card
statement are to be retaed at the deparent level along with a .copy of the approved
statement, the P-card manua is not clea regarding ths procedure. Ths procedure
needs to be fuer clarfied in the P-card policy and procedure manua.
Management Response:
Management agrees that the process of proper approval of P-Card charges is essential
to the success of the P-Card program, including the timely receipt of the approved
statements. Audit's recommendation to collect statements with two weeks of receipt
seems reasonable, but that ths should not interfere with payment of the invoice.
Statements not approved withn the time frame will generate a non-compliance notice
tht will be sent to the supervsor and general manager with a new deadline. If there
is no response by then, the card will be automatically suspended. A second
infaction will result in card cancellation.
Keeping onginal receipts at the business unt level and only sending the cardholder
statement to Procurement wil be clearly clarfied in the P-card policy and procedure
manua.
Please refer to the attched memo for fuer details.
4. P-Card Purchases Are Being Made In Violation of P-Card Policy.
The P-card policy is very clear regarding the tye of items tht are allowed to bé
charged on the P-card, as well as those items that are not allowed to be purchased
with a P-card. However, in performg our review, Audit noted that a majonty of the
charges on P-cards are not in compliance with the policy and these charges are being
approved by the cardholder's supervisor.
The followig are examples of charges that are being made on P-cards. These charges
are considered a violation of the P-card policy:
. Travel and entertaient expenses (meals, hotels). These expenses should be
put though the normal travel and entertnment expense process, which is
reimbursed though payrolL.
. Cell phone accessones (blue tooth)
9
· IT equipment such as printers, monitors, etc.
. Fax machies
. Meals, Grocery Store Charges, Dun Donuts
. AOL Service (internet service)
. Gas
. Cameras, DVD players
It was also noted that may purchaes do not have adequate receipts to support the
charges. Credit card receipts, which do not show an itemized account or description
of the purchase, are commonly used as support.
Additionally, accounting distrbution numbers are hard-coded with each P-card and
by not using the cards for its intended purose, purchases will be charged to the
incorrect expense accounts. For example, if an individua's card is hard-coded with
an offce supplies expense number, any purchases that are charged to ths P-card,
such as meals or gas charges, will be incorrectly charged to offce supplies expense.
Recommendation:
Management should ensure compliance with the P-card policy and discipline should
be enforced for violations of the policy.
· Only purchases tht are in compliance with the P-card policy should be approved
for payment.
· Cardholders should be held accountable for purchases that are made which are not
in compliance with P-card policy. P-cards should be taen away from those
individuals that do not observe the policy.
· Supervisors/managers should be responsible for forwarding to the P-card
Administrator, on a timely basis, the original approved monthy statements afer
reviewing them for appropriateness of purchases and adequacy, of supporting
documentation. Supervisors should not approve statements of their direct reports
without reviewig the supporting receipts to ensure that they are valid business
charges. These supporting receipts should also be retaed by the supervisors in
their appropriate deparent.
Management Response
It is the cardholder's responsibility to only purchase with the P-card policy. It is the
cardholder's supervisor or manager's responsibilty to ensure that purchases are for
valid business reasons and to report any violation of this policy to Procurement.
It is the cardholder's responsibilty to attch the appropriate receipts to their monthy
10
sttement and it is the supervisor's or manager's responsibilty to ensure tht all
receipts are collected and to report any violation of this policy to Procurement.
In order to fuer ensure compliance, Procurement and Intern Audit will conduct
radom audits either inquig about the natue of the charges or requestig receipts.
All MCC Codes will be reviewed and a stadadized allowance list will be compiled,
subject to review by the EMT.
Please refer to the atthed memo for fuer details on the action plan.
11
MEMO
FROM: Joel Tache
DATE: 1/9/2007
SUBJECT: P-Card Audit - ACTION PLAN MEMO
The United Water Purchasing card is a useful and cost effective tool to purchase and
pay for low cost expenses, thereby eliminating the cost of purchase processing and
reducing the number of checks processed for lower dollar transactions. As an
example, in 2006 20,276 transactions were processed using PCard for a total
aggregate amount of $2,182,045. However, to be successful a PCard program
requires clear ownership, oversight and accountability and must be strictly controlled
and administered. In this perspective, we suggest to implement immediately the
following recommendation.
1) Roles & responsibilities:
a. The Supply Chain Management (SCM /Procurement) Department will have
the responsibility for administration of the PCard and enforcing the
policies and procedures. Policies and Procedures proposed by SCM must
be approved by the EMT. The Chief Procurement Officer (CPO) & Head of
Supply Chain & BIO, Joel Tache, will take ownership of the Pcard process,
assisted by, Diana McCullough, as Administrator of the PCard program.
b. The Cardholders are responsi ble for:
i. Signing the acknowledgement form.
ii. Using the PCards within the policy guidelines.
iii. Submitting all receipts and back-up to the card approver to ensure
approval in a timely fashion.
c. The Approvers are responsible for:
i. Signing the acknowledgement form for card they approve
ii. Approving the issuance of PCards (w/limits...).
iii. Approving Monthly PCard statements in a timely fashion.
iv. Reporting any usage violation immediately.
v. Maintaining receipts and the original of the approved cardholder
statement as proof of review.
vi. Sending, in a timely fashion, by fax or email (scanned) a copy of
the approved original cardholder statement to PCard Administrator
evidencing the approvaL.
2) All spend types (MCC codes) will be reviewed and approved by the EMT: This will
clearly restrict the use of P-Cards for excluded MCC categories and standardize
12
the use of the cards. Once the list is approved then all cards will be updated
accordingly by the PCard Administrator.
3) The list of current PCards will be reviewed by each GM/PM (including number of
cards, dollar limits, and approvers -see thresholds below). For each individual
cardholder with a combined annual limit greater than $50k, whether with 1 or
several cards, (e.g. $5,000 per month x 12 months = $60,000), the approval of
their respective EMT member will be required. Once the list of cards is approved,
then:
a. All approved cardholders and their respective approvers shall sign the
acknowledgement form sent by Procurement and return it within 5
business days.
b. All cancelled cards shall be mailed back to Procurement within 5 days by
the GM/PM.
4) For future PCard requests, the approval threshold for the cards shall be. based
upon the annual Opex authorization threshold:
All cards with an aggregate Card issuance authorized Monthly statement approved
annual limit by:by:
::$500k CEO EMT member
::$50k EMT member General Manager (Reg)/
Division Manager (CS)
-:$50k General Manager (Reg)/Direct Supervisor
Division Manager (CS)
5) On a monthly basis,
a. All Individual card statement are mailed to the cardholders by Mellon on
approximately the 5th day of the following month
b. All card statements MUST be approved by their Approvers and a copy
must be sent to the PCard Administrator by fax or email (scanned) no later
than the 20th of the month.
i. The Approver shall retain all receipts and back-up documentation
of the approved statements so that they are readily available for
regular random audit.
ii. By approving the statement, the Approver certifies that all
expenses have been incurred for business purposes. In the event
that the Approver uncovers non-business related expenses, the
Approver shall:
1. Immediately notify the PCard administrator of the violation
(the violation will be recorded by Procurement); and,
2. Seek reimbursement from the cardholder within 5 business
days. The reimbursement shall be sent to the PCard
administrator immediately.
3. Disciplinary actions and/or suspension/cancellation of the
card shall be discussed with HR, the CPO, and the related
13
EMT member.
c. All statements not approved by the 20th of the month will be subject to a
violation notice sent via-email by the PCard administrator to the Approvers
of the missing statement.
d. All statements not approved by the 25th of the month will automatically
trigger:
i. The issuance of a 2nd violation notice with copy to the related EMT
member; and,
ii. The suspension of the card until the approval is received.
e. As a card cannot be suspended twice within the same calendar year, a
second violation to meet the deadline of the 25th will result in the
automatic cancellation of the card and notice will be sent to the Approver
and the related EMT member.
f. Each month a schedule shall be prepared by the PCard administrator to:
i. Reconcile the master statement balance with the approved
statements for the period and previous period's statement.
ii. Outline the violations of the months (approvals, PCard usage...)
IIi. Results of random audits performed during the months.
The schedule shall be approved and signed by the CPO before the master
statement is paid.
g. Violations of PCard policy will be not delay payment to Mellon, and
therefore, once the summary invoice is received and reconciled with report
from PVS Net (PCard software), a requisition will be prepared, approved by
the CFO and an ACH wire sent to Mellon by the due date.
h. However, violations of PCard policy may result in disciplinary actions
against the violators.
In addition, Mellon and its software partner will be contacted for ideas on process
improvements, including on-line approval of cardholder's statements.
"I proposal is accepted, the PCard policy will be revised accordingly and, unless
otherwise agreed upon, the target timeline would be to have by the end of Ql:
Approval of Spend type by the EMT
all approval and corrections of the existing cards
all acknowledgement forms for all active cards
New policy, forms and procedures issued
Once the new procedure outline is approved and in place for a couple of months,
we will need to review the adequate level of resources to be dedicated to centrally
administer this critical process.
14
o~: United Watero ..vez
Audit of Employee
Travel and Reimbursable
Expense Process
May 11, 2007
U!\lfTED WATER
200 Old Hook Road, Harrngton Park, NJ 07640
Tel: [phone] . Fax [phone]
Ann.Koesterer~unitedwater.com
oç( United Water-s,-ezo
ANN KOESTERER
Diretor of Internal Audit
Date: May 11, 2007
To: Ed Imparato
From: An Koesterer
Distrbution: A. Hardig
R. Iacullo
JC Goldm
R. Henn .
D. Cole
W. Hil
M.McKoy
M. Genn
M.Onojeta
Ernst and Young: D. Glina
M.Nagy
Audit Committee: E. Bar, Cha
L. Codey
Jean Marc Boursier
Subject:Audit Report -Employee Travel and Reimbursable Expense Process
Please find attched, the audit report for the Employee Travel and Reimbursable Expense
Process. If you have any questions, do not hesitate to contact me.
Th you for the assistace provided to Internal Audit durg our review.
INRNAL AUDIT DEPARTMNT
AUDIT REPORT
AUDIT OF EMPLOYEE TRAVEL AN REIMURABLE EXPENSE PROCESS
TABLE OF CONTNTS
PAGE
EXECUTIV SUMY:
(Icludes Background, Objectives, Scope and Conclusion)
1/2
AUDIT ISSUES AN RECOJ\NDATIONS:
1. Failure To Follow Aiare and Hotel Corporate Policies and Procedures, Results In 3
Duplicate Payments.
2. Varous Deficiencies Noted With The Expense Reportg Process. 4
EXECUTIV SUMY
The United Water Employee Travel and Reimbursable Expense (T &E) process provides
gudace and procedures for employees incurg
business-related travel and/or
entertent expenses. The policy applies to all employees of United Water Inc., its
subsidiares and afliates and is designed to be in compliance with Intern Revenue
Service (IS) gudelines for Business Travel and Entertent Expenses. United
Water's policy is to reimburse employees for all reasonable business-related travel and
entertent expenses tht are formally substtiated and approved, via the employee
expense reportg process. For 2006, United Water's tota Employee Travel and
Reimbursable Expenses was approxiately $2.1 milion.
The . PeopleSoft expense module is the tool tht is to be utize by employees to enter
business expense inormation for reimbursement. In addition to electronicaly submittg
their expense report to their Supervsor for approval, via the PeopleSoft module, the
employee must also prit out an expense summar and atestation page, which the
employee is requied to sign to attest to the valdity of al business expenses submitted.
Origi expense receipts must accompany the attestation page and should be submitted
to and signed by the employee's Supervisor before being sent to Accounts Payable for
retention. Once expenses have been approved in PeopleSoft by the employee's
Supervsor, the employee will receive the reimbursement though payroll.
Accordig to Company policy, employees are requied to purchae ailine tickets though
the approved corporate vendor and the cost of the ailie tickets are to be chaged to the
corporate account, which is maned by Procurement. Al other travel related expenses,
includig hotel and meal expenses, are to be paid by the employee, and the expenses are
to be submitted to the Company for reimbursement though the PeopleSoft employee
payroWexpense module. Most employees use their personal credit card to pay for their
business-related expenses; however, if employees demonstrate a business travel need,
they may obta a company American Express (AMX) Card, with approval from their
supervsing EMT member. . As of March 2007, there were 44 corporate credit. cards
issued companywde.
Objective and Scope:
The objective of our audit was to review the Corporate Employee Travel and
Reimbursable Expenses (T &E) program to determe whether the curent process is
adequate and is fuctionig as intended. The T &E process was reviewed to ensure that
employee expenses, and subsequent reimbursements, are compliant with company policy,
are adequately supported with origial receipts, are being properly reviewed and
approved by the employee's supervisor, and expenses are being documented in
accordance with IR gudelines. Our audit scope consisted of a judgmenta selection and
1
review of 106 expense reports, which was approxiately 2% of the population of 2006
expense reports. Our review disclosed tht 48% of the expense report reviewed
contaed some tye of exception, including attendees not listed on business meals,
recipts not provided to support expenses, expenses not properly itemid on expense
report, and not fig the expense report tiely. Our review also disclosed several
duplicate payments in which an ailie ticket, hotel expenses and a deparenta meal,
were paid twce. The duplicate payments occured becaue the employees did not follow
corporate T &E policies and procedures.
Conclusion:
Based on our review, the United Water Employee Travel and Reimbursable Expenses
(T &E) policy and procedures appears adequate, however the proceSs needs to be bettr
monitored by Supervsors approving their employee's expenses, to ensure they are
compliant with Company policy and procedures. Durg our review, Audit noted
exceptions in which controls, designed to prevent errors and abuse of the process, were
circumvented by employees. These expenses were subsequently approved by Supervsors
who did not seem to be famliar with how employees' business expenses are requied to
be documented and supported.
Management should ensure tht al employees are famar with United Water's T&E
policies and procedures, and should ensure that these policies are reinorced and
strengtened to prevent ths circumvention in the futue. Manement should consider
reissuig the T &E policies and procedures to employees, along with an
acknowledgement form requig tht employees sign the form agreein that they have
read, understand and wi comply with the corporate T &E policies and procedures. By
requig employees to sign an acknowledgement form, there is a greater probabilty that
employees wil tae the tie to read and understad the policies and procedures, which
should help to improve compliance.
2
AUDIT ISSUES AN RECOMMNDATIONS:
1. Failure To Follow Airfare and Hotel Corporate Policies and Procedures, Results
In Duplicate Payments.
The United Water T&E policy requies that employees purchae aifare though the
Company's corporate travel vendor. The policy requies tht al aiare purchaes be
charged to the Company's mater account and should not be charged to an employee's
persona credit card or Corporate American Express card. The trvel policy also states
tht hotel charges are to be made though the corporate travel agent and should be
chaged to an employee's credt card and should be submittd by the employee for
reimbursement.
Durg our review, Audit noted tht aiare in 9% (10 in 106) of the expense reports
reviewed were purchaed from non-preferred vendors and charged to personal credt
cards. Two additional aiares were purchaed though the approved vendor (World
Travel BTl), however the aiares were charged to employee's persona credit cards,
which the Company's T &E policy disallows. Ths practice violates established policies
and procedures and circumvents the controls designed to prevent the 10ss of corporate
volume discounts. It also increases the risk of makg duplicate payments. For example;
an employee was reimbursed for the cost of aiare which ha been charged to the
corporate account and paid by the Company. Ths occured because the employee
thougt it was chaged to her own persona credt card and submitted it thugh the T&E
process for reimbursement. As a result, the Company paid it twce, once though the
corporate travel account and agai though the employee reimbursement process. Ths
was an employee error, which Audit brought to the employee's attention, and the
employee subsequently reimbured the Company.
Audit also noted tht, in several intances, hotellodgig charges were biled directly to
United Water and paid by Accounts Payable, rather th the employee incurg the
charges and submittg them for reimburement thoug the employee expense reportg
process in accordace with corporate travel policy. The practice of directly bill the
Company for hotel chages circumvents internal controls and increases the potential of
makg duplicate payments. For example, durg our review, Audit noted tht an
employee was reimbursed for hotel room charges that ha been diectly biled to the
Company and paid by Accounts payable. The employee had submitted a copy of the
hotel bil as support for reimbursement and was under the impression tht his persona
credit card was chaged by the hoteL. The employee was visitig a business unt and the
business unt's magement had made the hotel reservation and had charged the
corporate account for the hotel cost, without the employee's knowledge. As a result, the
Company paid the hotel and the employee for the same hotel chages. Ths oversight was
brought to the employee's attention and the employee is reimbursing the Company for
the charges.
3
Recommendation:
Supervsors tht are responsible for approvig expenses should be aware of the aie
and hotel policies, as well as alI other travel and expense policies, and should be
questonig expenses submitted by employees for reimbursement, which are not in
compliance with corporate policy. If the employee's supervsors had questoned the
aiare and hotel reimbursements, the duplicate payments may have been prevente.
Also, management should ensure tht all employees read and understad United Water's
Travel and Reimbursable Expense policies and procedures. Management should consider
developing and utiliing an acknowledgement form, which requies employees to read
the corporate T &E policies and procedures and sign the acknowledgement form attstig
tht they have rea, understad and agree to comply. By requig employees to sign an
acknowledgement form it is more likely tht employees will tae the tie to read and
understad the policies and procedures, which should help to improve compliance.
Management's Response:
Mangement concurs with Audt's fidigs and will implement an
acknowledgement
form tht will be issued to all employees responsible for approvig employee expense
report. The form wil be issued anualy and signed acknowledgements will be requied
to be sent to the Manger- Fince Policies and Procedures in order to be filed. The
acknowledgement form wi be issued by the end of June.
2. Vanous Deficiencies Noted With The T&E Expense Reportg Process.
Durg our review, there were varous deficiencies noted with the documentation and
submission of employees' T&E expenses. Corporate T&E policy requies that ongi
receipts for all expenses exceedig $25 be attched as supportg documentation to each
expense report. It was noted durg our review tht some ongi receipts for chages
over the $25 theshold were missing in 13% of the expense reports reviewed. Several
employees substtuted their credit card statements for the ongi receipts. These credit
card sttements only show the charged amounts and not the detal of the purchaes.
Although the expense report with the missing receipts were approved by their
supervisors, it is diffcult to determe how these expenses were deemed appropnate
business expenses, due to the lack of supportg documentation.
The followig were additional deficiencies that were noted durg our review:
. Aiare expenses were paid for several employees' spouses. Per the Employee
Travel and Reimbursable Expenses "meal, entertent, lodgig, travel, and
miscellaneous expenses attbutable to spouses, relatives, or frends are
considered to be a personal and non-reimbursable expense." Although the cost
4
for the spouse's aiar was approved by the COO, accordig to policy, ths is not
normly an alowable expense.
. Severa employees purchaed First/usiness class tickets, althoug the policy
specifcaly limts the use of First/usiness class tickets to EMT members only,
under cert circumstaces. Al employees, other th EMT members, must fly
coach class.
. Credit card statements were used as support rather th the actu support
reeipt. In one intace, a duplicate payment of $670 for a deparentaluncheon
occured because a credit card statement was used as support rather th the
origi receipt. The charges were fist submitted and reimbured to the employee
in December 2005, based on the submission of the origial receipt. The employee
mistaenly sought reimbursement for the same item on a subsequent expense
report in June 2006, using only a credit card statement as support. As a result, the
employee was reimbursed twce for the same expense. Audit brought ths
oversight to the employee's attention and he is reimbursing the Company for the
error.
. Hotel charges, includig hotel restaurant charges, were not properly itemized in
the employee's expense report. An employee was reimbursed twce for the same
meal because the hotel resturant chages were not listed separately in the
employee's expense report but were combined together as hotel expenses. The
employee also filed the hotel restaurant receipt, separately, and was reimbursed
for the meal agai.
. Severa expense reports tht were reviewed ha excessive, as well as non-
reimbursable chages, which were reimbursed to the employee. Among the non-
reimbursable chages noted were cell phone bils, hotel movies, Bluetooth for cell
phones, etc. There was also one employee tht routiely submittd un-itemied
receipts from Stop and Shop. By the receipts tht are submitted, it is impossible to
determe what is actuly being purchased, yet these expenses are contiuay
reimbursed to the employee, unchalenged by the employee's Supervsor.
. On one expense report reviewed, it was note tht a charitable contrbution for
$6,000 was incorrectly charged to Sta Meetings, Conferences & Semiars.
Corporate contrbutions should be processed though the Accounts Payable
process, not though the T &E process.
. The names of attendees were not listed on meals or entertent events in 5% of
expense reports reviewed.
. 9% of employees did not break meals out by day and 7% did not itemi room
and other charges in their hotel bils.
. 8% of the expense reports reviewed were not fied tiely. The expense reports
had expenses that were more th two month old.
. Although the expense report were approved on-line in PeopleSoft and paid, 8%
of hard copy expense reports reviewed were not signed by the approver and
preparer.
5
Recommendation:
Mangement should reinorce the corporate T &E policies and procedures with al
employees. For the expense report process to be effective, supervisors/maers
responsible for approvig employees' expenses, mus be famliar with T&E policies and
procedures and ensure tht the expenses tht they are approvig are in compliance with
corporate policy. Approvers should ensure that all requied receipts are atthed before
approving expense report. Credit card sttements should not be substtuted for ongi
receipts. Approvers should also ensure that al purchaes are for appropnate business
puroses and al requied documentation is provided by the employee, i.e. attendees
naes at business meas. The approvers should also ensure tht the employee's expenses
are reasonableand their expense report are prepared in a maner which is compliant
with company policy. The expense report should also be signed by both the employee
and the Supervsor and sent to Accounts Payable for fiing, in a tiely maer.
Mangement should contiue to monitor the T &E process for compliance. Employees
makg submissions for reimbursement, as well as the supervsors approving the
expenses, should be held accountable and reprianded if it is determed tht they are
not followig corporate policy and procedures.
Additionaly, corporate chatable contrbutions should be processed though the normal
Accounts Payable process and not though the T &E process. Also, the approval process
for corporate contrbutions should be strengtened. The approval process for
contrbutions is curently decentralzed and approved at the business unt level, with no
one from corporate overseeing the process. Mangement should consider developin a
centralzed oversight fuction for chatable contrbutions at the corporate leveL.
Management Response:
Management agees with the recommendations and has aleay released an updated
Travel and Expense policy to all UW employees on April 9, 2007. The new policy
coupled with the implementation of the acknowledgement form should reinorce and
strengten the controls suroundig the T &E policy.
Management will also routiely monitor the T &E process in order to ensure employee
compliance.
Charitable contrbution -Management Response from Corporate Communcations
Corporate Communcations concurs with the recommendation and is in the process of
developing a centralized chartable contrbution oversight commttee by the thd quaer
of 2007. AlI UW chartable contributions will be consolidated though ths commttee
and the commttee will be responsible for monitoring, approving and distrbutig all
6
chartable donations/gi etc., on behalf of United Water BUs. The oversight commttee
will formally present its policies and procedures and madate to the EMT in the four
quar of 2007 for approval.
7
o¿;( VnitedWaterù .svez
2007
Sarbanes-Oxley Section 302
Review Report
May 1, 2008
UNITED WATER
200 Old Hook Road, Harrington Park, NJ 07640
Tel: [phone] . Fax [phone]
Ann. Koesterer~unitedwater.co
oç( United Water-S,-ez¡)
ANN KOESTERER
Director of Internal Audit
Date:May 1,2008
From:An Koestrer
To:Tony Hardig
cc:R. Iacullo
J. Ekman
JC G0ldman
E. Imparato
P. Race
D. Cole
X. Boulat
M.McKoy
SUBJECT:2007 SARANS-OXLY SECTION 302 REVIW REPORT
Every year, Internal Audit performs a Sarbanes-Oxley Section 302 review to ensure
United Water's disclosure controls are adequate and fuctionig as intended. Atthed is
the Sarbanes-Oxley Section 302 audit report with the results of our 2007 review. The
report provides an opinion regardig the adequacy of disclosure controls, as well as
recommendations for improvements, if needed.
Than you for the assistace provided to Internal Audit durg ths review.
UNTED WATER INTERNAL AUDIT DEPARTMENT
2007 SARANS-OXLEY SECTION 302
REVIW
AUDIT REPORT
TABLE OF CONTENTS
PAGE
BACKGROUN
OBJECTNS AN SCOPE
CONCLUSION
1
1
2
ISSUES AN RECOMMNDATIONS:
1. A Consolidated Accountig Policy And Procedure Manua Should Be Created 3
For Reguated Entities.
2. United Water's Envionmenta Compliance Reportg System, OPS SQL, 3
Should be Fuly Utilized.
BACKGROUN:
In 2002, the SEC adopted new legislation known as the Sarbanes-Oxley Act (SOX). The
SEC's mai objective in creatig ths act was to improve corporate governance and
oversight, as well as to requie increased accountability of senior management for
reportg and disclosing corporate ficial results and data. The Sarbanes-Oxley Act
applied to al "issuers" (publicly traded companes) who were mandatory reportg
companes.
Prior to September 2007, United Water's parent, Suez, was listed on the New York Stock
Exchage and, as a result, Suez was requied to comply with the Sarbanes-Oxley Act. As
par of Suez's compliance process, and in order to support Suez' certification under the
Sarbanes-Oxley Act, Suez requested that its subsidiares comply with certain aspects of
the Act, specifically Section 302. Section 302 relates to corporate responsibility for
financial reportg and requies the CEO and CFO to certfy to reports submitted to the
SEC. Ths certification includes the acknowledgement that the certifyg officers have
reviewed the reports and, based on their knowledge, are not aware of any untre
statement of material fact. It also requies the offcers to acknowledge that they are
responsible for establishig and maitaig internal controls and tht these controls have
been designed properly, have been evaluated, and are effective. To comply with the Act,
Suez requied its subsidiares to attest to a simlar certfication that they were requied to
make. In response to Suez's request, United Water developed a process/strctue for
United Water that would enable us to comply with Section 302 of the Sarbanes-Oxley
Act on an on-going basis.
In September 2007, Suez delisted from the New York Stock Exchage and, resultantly,
was no longer requied to comply with the Sarbanes-Oxley Act. As a result of Suez'
delisting, United Water was no 10nger requied to perform the anual Sarbanes-Oxley
302 review; however, United Water management determed that the SOX 302 anual
review was a good corporate governance practice that they would like to see retaed and
performed on an anual basis.
OBJCTIS AN SCOPE:
In order to support United Water's CEO and CFO certfications, United Water developed
an approach, simlar to Suez's approach, to provide assurance that United Water's
disclosure controls and procedures were in place and fuctionig to ensure that fiancial
and non-fiancial inormation communcated to Suez though the SMAT package was
complete and accurate. Ths process was intially developed and implemented in 2003
and has been executed each year, thereafer. '
The process included a 4- level certfication strctue/process for United Water that
requied certfication at all four levels of mangement. It is a layered approach, in which
one layer relies upon the certfication from the previous layer. For example: the Segment
Controller, the President and COO provided certfications to the Drafter of SMAT. The
Drafter of SMAT then provided a certfication to the Reviewer of SMAT, who, in
retu, provided a certfication to the CFO and CEO. Ultimately, the CEO and CFO
1
received certfications from all of the aforementioned areas, as well as from the Vice-
Presidents of key M&S áreas, such as Legal, Tax, Procurement and Human Resources.
In order to support the certfication process, the four levels of management were
intervewed. The purose of these interews was to document the key disclosue controls
for their areas of control. Each year, these intervews are reviewed and updated.
Additionally, a disclosure control questionne, which was intended to gather inight
into potential risks, mitigatig controls, magement concern, and key disclosure
controls, was completed/updated by the interiewees for each area reviewed. Each
member intervewed was requied to complete ths questonne, which is also updated
anualy. The objective of the intervews and questionnaie process was to identify and
document key disclosure controls thoughout the organzation and to determe whether
these controls are adequate. Where disclosure controls were noted to be deficient,
appropriate recommendations were made to strengten controls. Ths exercise was also
used as an opportty to not only strengten disclosure controls, but also to improve
other internal controls and processes, where applicable. Additionally, disclosure control
recommendations from the previous year were followed-up to ensue prior
recommendations were implemented.
Before the CEO and CFO provided their certfications, the United Water Disclosure
Commttee met in order to discuss the Sarbanes 302 fidings and recommendations and
to review management's cerfications, to ensure that al disclosures that should be mae
to Suez had been properly disclosed.
CONCLUSION
In our opinon, the disclosure controls and procedures thoughout United Water, for
2007, appear to be more than adequate to ensure tht fiancial and non-fiancial
inormation communcated to Suez though the SMAT package are both complete and
accurate. Although there were no signficant disclosure control weakesses noted durg
our review, there were a few opportties noted that could fuer enhance disclosure
controls.
2
ISSUES AN RECOMMNDATIONS:
1. A Consolidated Accountig Policy And Procedure Manual Should Be Created
For Regulated Entities.
United Water does not have a consolidated accountig policy and procedure manual
in place that can be utilized by alI of the reguated business unts. Each reguated
business unt has its own accountig policy and procedure manual tht incorporates
their own accountig procedures, which may differ with other regulated business
unts' procedures. Maitag varous accounting policy and procedure manuals for
the regulated business unts can result in inconsistent practices thoughout United
Water's reguated segment.
Recommendation:
Management should ensure that a consolidated accounting policy and procedure
manua is developed tht can be utilized by al regulated business unts.
Management Response:
Although each major business unt (UJ, UW has their own policies,
management agrees with the recommendation and has aleady intiated a project to
accomplish ths objective to have one consolidated policy. The Manager - Policies
and Procedures will work with representatives from the Regulated and Contract
Services segments durg the fit year of a 2-3 year process to merge United Water's
varous accountig standad operatig procedures and processes into one
comprehensive accountig manual that can be utilied by the entire organzation.
2. United Water's Environmental Compliance Reportg System, OPS SQL,
Should be Fully Utied.
United Water's Environmental Reporting System, OPS SQL, is not being utilized by
alI business unts in order to report their samplig and compliance results, as required
by the United Water Environmental Compliance Program. There are some facilities
that may not be fuy utilizing the system because they may still require traig on
the environmental reporting system; however, there are other business unts that are
just not enterig their data. The OPS SQL system is used by management as a
reporting tool to oversee compliance results for all United Water business unts and
its use should be enforced.
Recommendation:
Management should ensure that the OPS SQL is being utilized by all business unts,
as requied by the Envionmental Compliance Program.
3
Management Response:
The Techncal Services Deparent and our Compliance Assurance Offcers are
monitorig ongoing usage and ever effort is being taen to insure that alI our
Reguated Companes and Contract Servces Projects are utizing the OPS SQL
system.
A pIan is also in place to roll out the OPS SQL system to our AOS projects ths year.
Both the Techncal Servces and Inormation Servces (IS) Deparents are involved
in the roll out pIan. Four major traig and intiation events have been scheduled,
individual facility varables, form templates and hot keys are being created, and the
roll out team is curently checkig and confg the availability of the softare and
communcation lies.
As new reguations are promulgated, the Techncal Services Deparent will work
with the Compliance Assurance Officers to incorporate new varables into the OPS
SQL program and inure tht al our companes and projects report on the new
varables.
To re-enforce the importance of the OPS SQL system and the role it plays in United
Water's Envionmental Compliance Program, the Techncal Servces Deparent will
work with the Chief Operatig Officer and Segment Presidents to send out a remder
to United Water's general management that OPS SQL is a requied par of our
envionmental compliance system.
4
oç( United Water..vezú
Corporate Procurement Card
Follow-up Audit
December 15, 2008
ANN KOESTERER
Director of Internal Audit
UNITED WATER
200 Old Hook Road, Harrngton Park, NJ 07640
Tel: [phone]. Fax: [phone]
Ann.Koeterer~unitedwater.com
o~( United Water.s~ez'-
Date:December 15, 2008
To:Michael Algranati
From:An Koesterer
Distribution:B. Camus
R. Iacullo
E. Imparato
T. Brown
D. Ciemnecki
D. Cole
M.McKoy
M. DiVincenzo
M.Onojeta
Mazars:R. Forgeas
J. Devilers
Audit Committee: E. Bar
L. Codey
Jean Marc Boursier
Subject:Corporate Procurement Card (P-Card) Follow-up Audit
Please fid attached the audit report for the Corporate Procurement Card (P-card) Follow-
up audit. If you have any questions, do not hesitate to contact me.
Than you for the assistance provided to Internal Audit durng our review.
UNTED WATER
INTERNAL AUDIT DEPARTMENT
AUDIT REPORT
FOLLOW-UP OF CORPORATE PROCURMENT CAR AUDIT
TABLE OF CONTENTS
PAGE
EXECUTIV SUMY:
(Includes Background, Objectives, Scope and Conclusion)
1
AUDIT ISSUES/RCOMMNDATIONS FROM THE ORIGINAL AUDIT
AN CURNT STATUS OF RECOMMNDATIONS FOR IMROVEMENTS:
1. The P-Card Program Lacks Ownership, Oversight and Adequate Resources. 2
2. The Approval Process Required To Obta A P-Card Needs To Be Revised. 3
3. Lack ofSupervsorslManager's Review and Approval ofP-Card Statements 4
And Purchases.
4. P-Card Purchases Are Being Made In Violation ofP-Card Policy. 5
MAAGEMENT RESPONSE TO FOLLOW-UP RECOMMNDATIONS: 6
EXECUTIVE SUMY
hitemal Audit conducted an audit of the United Water Corporate Procurement Card (P-
card) program in late 2006 and early 2007. The audit was completed in Februar 2007
and an audit report was issued to management. The report concluded that the United
Water Corporate P-card program was not fuctionig as intended and was in need of
improvement. Durng our review, we noted that policies and procedures were not being
followed. As a result, unauthorized purchases were made, individual monthly P-
cardholder statements were not approved by supervsors/managers and purchases were
not adequately supported with receipts. It was also noted that a reconciliation of
approved individual statements to the consolidated statement was not performed tiely
and the number ofP-cards issued was excessive because the responsibility for authorizing
and approving P-card applications was placed too low at the supervisor/manger leveL.
hi order to address hitemal Audit's recommendations, management prepared an action
pIan to improve the program and enance the controls. To ensure that the
recommendations from the audit were implemented by management, hitemal Audit
commenced a follow-up review of the United Water Corporate Procurement Card Audit
in September 2008. As a result of our follow-up review, we noted that the majority of the
recommendations have been successfully implemented or are in the process of being
implemented. Oversight of the P-card was elevated to the level of the Chief Procurement
Officer. The day to day admstration of the P-card program is performed by a Supply
Chai Administrative Assistant. A new United Water Purchasing Card Policy and
Procedure Manual was sent to all purchasing cardholders, approvig supervisors and
project managers. P-cardholders were requied to read and evidence their acceptance of
the policy by signng and retug the agreement to the P-card Admstrator.
Although management has been very proactive in implementing the recommendations
from the P-card audit, there were areas noted that stil need improvement. Audit noted
purchases being made with the P-card that violate the P-card policy. Normally, the
Merchant Category Code (MCC) for these purchases are blocked (i.e. food/restaurants),
however the MCC restrctionllock was overlooked on some cards. Regardless of the
fact that the merchant code had not been blocked, the P-cardholder and the P-
cardholder's supervisor should have been aware that these charges were prohibited by P-
card policy and the charges should not have been made and approved.
hi our opinion, compliance with the United Water Corporate Procurement Card (p-card)
program has signficantly improved; however, additional steps should be taken to prevent
cardholders from makg purchases that are in violation of the P-card policy.
Improvements to compliance can be made by eliminatig management overrdes ofMCC
codes and by ensurg that all restrcted Merchant Category Codes (MCC) are blocked.
Procurement management should also send a memo to all P-cardholders and their
approvers to remind them of the necessity to become familiar with and to comply with
the P-card policy.
1
AUDIT ISSUES AN RECOMMNDATIONS:
1. The P-Card Program Lacks Ownership, Oversight and Adequate Resources.
Original Recommendation:
The P-card process should be redesigned with accountability for the process assigned to a
specific individual or deparent and clear policies and procedures must be enorced.
Adequate resources should be provided to the individual or deparent charged with the
admstration of the P-card in order to provide adequate oversight for the entire program.
The selected owner of the process should also be at a higher level of management in
order to effectively enforce the policies and procedures, including terminating P-cards if
a P-cardholder does not comply with the policies and procedures of the P-card progr.
Enforcement of the P-card policies and procedures is key for the P-card program to be
successfuL. The following are additional steps that should be taken by the Admnistrator
to aid in the enforcement of the P-card policies:
· The Adminstrator of the P-card program should be trackig P-card violations in a
database.
. A standard form should be developed by the Admnistrator, which can be used to
notify the appropriate management if there is a P-card violation for an individuaL. For
example, if a Supervsor/Manager has not approved one of their employee's P-card
statements, a "non-compliance" memo should be sent to the P-cardholder's
supervisor, with a copy to the General Manager. If there is a second violation for ths
P-cardholder, the P-card should be cancelled.
Current Status of Recommendation: Implemented
Oversight of the P-card process was elevated to the level of the Chief Procurement
Officer. The day to day admnistration of the P-card program is performed by a Supply
Chain Administrative Assistant. A new United Water Purchasing Card Policy and
Procedures Manual was issued by Corporate Procurement, which included a new
agreement form to accept a United WaterP-card. The agreement form is requied to be
signed and retued, prior to the issuance of the P-card. A list of Merchant Category
Codes (MCC) was also sent to all P-cardholders and approving superisors and project
managers, to ensure that P-cardholders and their supervisors were famliar with MCC
purchases that are permissible with the P-card, as well as the MCC codes that are not
allowed to be used with the P-card.
The P-card admistrator created a Cardholders' Database which is now used to track
signed monthly P-card statements. Each month, the admistrator reconciles the master
statement balance with all approved individual statements for the period. Each P-card
2
that has a monthy balance is checked off in the database as the individual signed and
approved statement is received. The names of P-cardholders who did not retu a signed
and approved statement are recorded and tracked as violators in the database. In addition,
the appropriate management is notified of any violation using a new standard violation
notice form. For the 1 st violation, the P-card is suspended by changing the credit limit to
zero. For the 2nd violation, the card is cancelled.
2. The Approval Process Required To Obtain A P-Card Needs To Be Revised.
Original Recommendation:
Management needs to reevaluate the curent approval process required for an individual
to obtain a P-card. The curent procedure requires the authorization of a supervisor;
however, this procedure needs to be revised to require a higher level of authorization,
such as a General Manager.
Additionally, the curent list of P-cardholders should be reviewed by a higher level of
management, such as the General Manager, to ensure only individuals with a valid
business need have a card. Those individuals having P-cards, which are deemed to be
unecessar, should have their cards cancelled.
The following are additional procedural changes that should be implemented:
· All approved P-card applications should be maintaied by the Admstrator and
should be filed centrally.
· The procedure, in which Procurement sends an approved applicant a P-card with an
agreement acknowledgement form, should be revised. Procurement should send the
agreement to the approved applicant fist, and should not send the P-card until a
signed agreement is retued.
· Once the P-card process has been reorganzed and the policies and procedures have
been updated, a revised policies and procedures manual should be sent to all P-
cardholders with a requirement for the P-cardholder to read the manual and sign an
updated acknowledgement form, which requires the P-cardholder to comply with all
P-card policies and procedures.
· A database should be developed and maitaed of all P-Card users, indicating
whether an approved application has been received, a signed policies and procedures
agreement is on file, list the curent manager/supervsor of the cardholder, as well as
details of restrctions on the card (dollar value and usage type). Ths database can
also be used to record whether there have been any policy violations by the
cardholder.
· The P-cardholder's supervsor/manager should be included on the P-card statement.
3
Current Status of Recommendations: Implemented
Management implemented a new procedure that is included in the updated United Water
Purchasing Card Policy and Procedure Manual, which requires a year-end review of all
P-card usage. The purose of the yearly review is to allow managers to make a
determation regarding whether a P-card is needed or should be cancelled. This review
helps to ensure that only individuals with a valid business need have a card.
Management also developed a Cardholders Database. For fuer details regardig the
implementation of recommendations relating to the cardholder database, the new policy
manual and the acknowledgement form, please see Issue #1 above, under the section
"Curent Status of Recommendations".
3. Lack of Supervisors/Manager's Review and Approval of P-Card Statements and
Purchases.
Origial Recommendation:
Proper approval of P-card charges is essential in ensurng the success of the P-card
program. The supervsor/manager's approval on an individual's statement is the only
approval and oversight that these purchases receive. If supervisors and managers are not
reviewing their diect reports P-card statements, there is the risk that fraud could occur
and go undetected.
Also, the process whereby the P-card consolidated statement is paid by the Administrator
prior to receiving the approved individual statements needs to be revised. P-cardholders
are provided approximately two weeks to have their individual statements approved and
retued to the P-card Administrator. Two weeks appears to be more than ample time for
all individual statements to be approved and retued to the Admstrator before the
consolidated statement is required to be paid. If the Admnistrator ha not received all
individual statements by the tie the consolidated statement is required to be paid, the
Administrator should not delay the payment of the consolidated statement; however, a
process needs to be implemented in which the Admnistrator can report those individuals
that have not submitted approved P-card statements. The P-card Administrator should
develop a standard "Non-Compliance" form, which can be used by the Adminstrator
when there is an issue with a P-cardholders statement or charges. The form should be
addressed to the P-card's supervisor, with a copy to the General Manager. The form
should require a response with a certai period of time, i.e. one week. If a response to
the non-compliance form is not received, P-card privileges should be suspended. If this
situation occurs twice with the same individual, disciplinar action should be taen, such
as cancelling the individual's P-card. The P-card policies and procedures should be
revised to reflect these new procedures.
4
In addition, although the ongial receipts that support an individual's P-card statement
are to be retained at the deparent level along with a copy of the approved statement,
the P-card manua is not clear regardig ths procedure. This procedure needs to be
fuer clarfied in the P-card policy and procedure manuaL.
Current Status of Recommendations:
improvement.
Partially Implemented, but needs
To help manage the approval and payment process, the Admnistrator has created a
database to track individua statements, to ensure that all approved statements are being
received timely in order to facilitate the tiely payment of the consolidated statement. A
process has been developed, which includes a violation notice and penalties to
cardholders if individual statements are not approved and retued to Procurement withn
the required timeframe. For fuher detals regarding this process, please see Issue #1
under the section "Curent Status of Recommendations".
Supervisory review ofP-card statements needs improvement. Audit noted that there were
charges for meals on P-cards, which are not allowed by Corporate P-Card policy. The
Merchant Category Code for food/restaurants was supposed to be blocked, but was
inadvertently overlooked and was not blocked. However, regardless of the fact that the
charges were not blocked by the restrction of a merchant code, the charges made were
not in compliance with P-Card policy and should not have been made by the P-cardholder
and should not have been approved by the P-cardholder's supervisor. Corporate
Procurement should send a memo to all P-cardholders remiding them of their
responsibility to comply with the policy, as well as a remider to supervsors/managers to
be more diligent in reviewing and approving the statements.
4. P-Card Purchases Are Being Made In Violation of P-Card Policy.
Original Recommendation:
Management should ensure compliance with the P-card policy and discipline should be
enforced for violations of the policy.
· Only purchases that are in compliance with the P-card policy should be approved for
payment.
· Cardholders should be held accountable for purchases that are made which are not in
compliance with P-card policy. P-cards should be taken away from those individuals
that do not observe the policy.
· Supervisors/managers should be responsible for forwarding to the P-card
Adminstrator, on a timely basis, the ongial approved monthly statements after
reviewig them for appropnateness of purchases and adequacy of supporting
5
documentation. Supervisors should not approve statements of their direct report
without reviewing the supporting receipts to ensure that they are valid business
charges. These supporting receipts should also be retaied by the supervisors in their
appropriate deparent.
Current Status of Recommendations:
improvement
Partally Implemented, but needs
In September 2007, following the P-card audit, the P-card Administrator sent a list to
Mellon Ban of Merchant Category Codes (MCC) to be added or deleted from the United
Water P-card program. In our follow-up review, we noted that purchases that violate the
P-card policy were still being made, although the Merchant Category Codes for these
purchases should have been restrcted. Upon fuer review, it was noted that a Merchant
Category Code for föod and restaurant purchases was inavertently left off of the list of
restrcted codes that was sent to Mellon Ban. As a result, purchases such as
food/restaurants that are not allowed accordig to P-card policy were still being made by
some P-Cardholders. Audit also noted that the P-Card adnistrator overrode several
blocked and restrcted Merchant Category Codes to allow some P-cardholders to make
purchases that violate the P-card policy. Per the adnistrator, the overrdes were
necessar because the transactions were for legitimate business puroses and the P-card
holders had no other mean of makg the purchases at that time. Going forward,
management should not overrde the merchant category codes and should inform the p_
card user that the purchase is not allowed with the P-card. For fuer details regarding
the non-compliant P-card purchases and recommendations for improvements, please see
Issue #3 above, under the section "Curent Status of Recommendations".
Management Response to Follow-up Recommendations:
The P-card admstrator wil review the active MCC Codes and update the list of
restrcted codes. In addition, Supply Chai Management (SCM) will review the codes
that were opened by the P-card administrator over the past 12 months to determne their
relevance in performg their jobs. Once reviewed, the appropriate changes to the
allowed and restrcted codes will be communcated to Mellon Ban which wil process
the changes accordingly. To insure the accuracy of the Ban's changes, SCM wil review
the updates perormed by the ban. Once ths process is complete, all codes restrcted by
policy wil remain restrcted and SCM wil no 10nger allow over-rides to occur.
SCM wil issue a memo to all P-cardholders remiding them of their responsibility to
comply with the policy, as well as a reminder to supervsors/managers to be more diligent
in reviewing and approving the statements. Non-compliance will result in disciplinar
action which may include additional suspension of privileges.
6
..... .w~.
2008
Sarbanes-Oxley Section 302
Review Report
June 19, 2009
UNITED WATER
200 Old Hook Road, Harrington Park, NJ 07640
Tel: [phone] . Fax: [phone]
Ann. Koesterer(gunitedwater.com
ANN KOESTERER
Director of Internal Audit
Date: June 19,2009
From: Ann Koest~rer
To: Bertand Cam~
Distribution: R. Iaculo
D. Ciemnecki
T. Brown
E. Imparto
D. Cole
M.McKoy
Mazars: R. Forgeas
J. Devillers
Audit Commttee: E. Bar, Chaian
L. Codey
Jean Marc Boursier
SUBJECT:2008 SARANS-OXLEY SECTION 302 REVIW REPORT
Every year, Internal Audit performs a Sarbanes-Oxley Section 302 review to ensure
United Water's disclosure controls are adequate and fuctionig as intended. Attched is
the Sarbanes-Oxley Section 302 audit report with the results of our 2008 review. The
report provides an opinon regarding the adequacy of disclosure controls, as well as
recommendations for improvements, if needed.
Than you for the assistace provided to Internal Audit durg ths review.
UNTED WATER INERNAL AUDIT DEPARTMENT
2008 SARANS-OXLEY SECTION 302
REVIW REPORT
TABLE OF CONTENTS
BACKGROUN
OBJECTIVS AN SCOPE
CONCLUSION
PAGE
1
1
2
BACKGROUN:
In 2002, the SEC adopted new legislation known as the Sarbanes-Oxley Act (SOX). The
SEC's mai objective in creatig ths act was to improve corporate governance and
oversight, as well as to requie increased accountabilty of senior mangement for
reporting and disclosing corporate fiancial results and data. The Sarbanes-Oxley Act
applied to al "issuers" (publicly traded companes) who were mandatory reportg
companes.
Prior to September 2007, United Water's parent, Suez Envionnement, was listed on the
New York Stock Exchange and, as a result, Suez Environnement was requied to comply
with the Sarbanes-Oxley Act. As par of Suez's compliance process, and in order to
support Suez Environnement's certification under the Sarbanes-Oxley Act, Suez
Envionnement requested that its subsidiares comply with cert aspects of the Act,
specifcally Section 302. Section 302 relates to corporate responsibility for fiancial
reportg and requies the CEO and CFO to cert to report submitted to the SEC. Ths
certifcation includes the acknowledgement tht the certfyg offcers have reviewed the
reports and, based on their knowledge, are not aware of any untre statement of material
fact. It also requies the offcers to acknowledge tht they are responsible for estblishig
and maitag internal controls and tht these controls have been designed properly,
have been evaluated, and are effective. To comply with the Act, Suez Envionnement
required its subsidiares to attest to a simlar certcation tht they were requied to make.
In response to Suez Envionnement's request, United Water developed a
process/strctue for United Water that would enable us to comply with Section 302 of
the Sarbanes-Oxley Act on an on-going basis.
In September 2007, Suez Envionnement delisted from the New York Stock Exchage
and, resultantly, was no longer requied to comply with the Sarbanes-Oxley Act. Due to
Suez Envionnement's delistig, United Water was no longer requied to perform the
anua Sarbanes-Oxley 302 review; however, United Water manement determed that
the SOX 302 anua review was a good corporate governance practice that they would
like to see retaed and performed on an anua basis. As a result, the SOX 302 review
is performed every year in order to ensure disclosure controls are adequate and to support
the CEO and CFO's certifications to Suez Envionnement.
OBJCTIVS AN SCOPE:
In order to support United Water's anua CEO and CFO certifications, United Water
developed an approach to provide assurance that United Water's disclosure controls and
procedures were in place and fuctionig to ensure tht ficial and non-fiancial
inormation communcated to Suez Envionnement though the SMAT package was
complete and accurate. Ths process was intially developed and implemented in 2003
and has been executed each year, thereafer.
The process included a 4-level certfication strctue/process for United Water that
required certification at al four levels of management. It is a layered approach, in which
one layer relies upon the certfication from the previous layer. For example: the Segment
1
Controllers, Presidents and COO provided certfications to the Draftr of SMAT. The
Vice-Presidents of key M&S areas, such as Legal, Tax, Procurement and Hum
Resources, also provided certifcations to the Draer of SMAT. The Drafer of SMAT
then provided a certfication to the Reviewer of SMAT, who,' in retu provided a
certification to the CFO and CEO. Ultiately, the CEO and CFO received certfications
from all of the aforementioned areas.
At the inception of the SOX 302 review process in 2003, all members of the four levels
of maagement were intervewed in order to document the key disclosure controls for
their areas of control. Each year, these interviews are reviewed and updated.
Additionally, a disclosure control questionne, which was intended to gather inight
into potential risks, mitigating controls, mangement concern, and key disclosure
controls, was completed/updated by the interviewees for each area reviewed. Each
member intervewed was requied to complete ths questionne, which is also updated
anuay. The objective of the intervews and questionnaie process was to identify and
document key disclosure controls thoughout the organtion and to determe whether
these controls are adequate. Where disclosure controls were noted to be deficient,
appropriate recommendations were made to strengten controls. Additionally, disclosure
control recommendations from the previous year were followed-up to ensure prior
recommendations were implemented.
Before the CEO and CFO provided their certfications, the United Water Disclosure
Commttee met in order to discuss the Sarbanes 302 fidigs and recommendations and
to review mangement's certcations, to ensure that all disclosures that should be made
to Suez Environnement had been properly disclosed.
CONCLUSION
In our opinon, the disclosure controls and procedures thoughout United Water for 2008
appear to be more th adequate to ensure that fiancial and non-financial inormtion
comml,cated to Suez Environnement though the SMAT package are both complete
and accurate. Disclosure controls appeared to be sufcient and operating as intended and
there did not appear to be a need to increase/strengten the existig disclosure controls.
As a result, for the 2008 review, there were no recommendations for improvements
noted.
2
UNTED WATER IDAHO INC.
CASE UWI-W-09-01 2fJß9 OCT I"
FIT PRODUCTION REQUEST OF TH COMMSS,~O~TtM.~~I:: 4/
v Ti U I ¡ F-'~ (' n.,., ~ ~.' ';,' ", C,¿'"..v J\.r!¡.;','i¡!Scit..:~;;H¡¡ i' vH.')i'~J
REGEl D
Preparer/Sponsoring Witness: Kevin Dohert
REQUEST NO. 14:
Please provide a copy of the policy and procedures for overhead loading including accounts and
amounts used with related explanation as to their use in 2008 and 2009, including inormation of
any changes planed to ths process.
RESPONSE NO. 14:
Please refer to the attched information. The Company has no planed changes to this process.
Staff Set 1 Request 14
Attachment A
United Water-Capital Overheads
United Water Resources has a standard policy for captug and allocating capital
overheads. A common overhead policy is requied to ensure that all costs are tracked and
allocated in a unform and consistent maner across all companies.
A. Overview
There are five components of capita overhead charges:
. Local overhead charges (capital overheads)
. Segment overhead charges (capital overheads)
. Corporate overhead charges (capital overheads)
. Vehicle allocations (vehicle overheads)
. Benefits allocations (benefit overheads)
All capita overheads are allocated monthly using the Project Costing system. The
overhead costs are collected each month in accounts 10700 (reg segment) or
12100 (for the non-reg segment).
The namng convention for these overhead projects is:
=
Overhead-xxx where XX= Business Unit number
Local (Local), Segment (Reg), Corporate (Corp)
. Project ID
. Activity
=
The Capita Overhead allocations are ru in the followig order:
1. Local
2. Segment
3. Corporate
The Vehicle and Benefit Allocation Processes are ru each month before the
Capita Overhead Allocation is begu. As a result, Vehicle costs and Benefit
Overheads wil be included in the Local overhead base. Segment overheads are
compounded on top of the Vehicle, Benefit and Local charges and Corporate
Overheads are calculated on all costs including Vehicle, Benefits, Local and
Segment overheads.
Listed below are several key points relating to the overhead allocation process.
. Capital allocations for Local , Segment and Corporate overheads will be
applied to curent month CWIP expenditues in Project Costing, including
direct purchases, Vehicle and Benefit costs. CWIP expenditues are
defined as costs charged to account 10700 (water), 10750 (wastewater) or
12100 (nonreg)
. All capita-related costs must be charged to a CWIP account.
. All charges made to CWIP must have a Project ID and an Activity, in
order to be tracked in Project Costing. PeopleSoft requires that a Project
ID and Activity be entered when enterig costs to a CWIP account.
. Overhead allocation rates will be determined at the beginning of each year
for each Business Unit, and should be monitored and adjusted, if
necessar, on a reguar basis throughout the year.
. The Segment and Corporate overhead rates are set by the UW M&S
Company for all Business Units. Local overhead rates are calculated and
approved for each Business Unit by the Segment Controller for that unt.
Benefit and Vehicle rates are calculated for each Business Unit (Detals as
to how the rates are determined will be discussed in subsequent sections of
ths document)
. Each overhead pool should be allocated as completely as possible at each
year end.
. All capita overhead charges at the local Business Unit must be made to
the Local Activity. Segment and Corporate Activities should not be
charged.
. Overheads will be applied to preliminar Survey and Investigation
projects. These projects will be tracked in the Project Costing system
using the "M" (water) or "X" (sewer) project coding described in the
capital Expenditue Policy and Procedure Manual.
. Overheads are not calculated on AFUDC.
. Overheads are not calculated on accruls if Source tye MISC and the
Category ACCRL is used when posting to the General Ledger.
. Overheads wil not post to any General Ledger entry that uses a Source
tye of MISC and a Category tye of TRNFR. This coding should not be
used except in special circumstances when it is necessar to move costs
between projects and additional overheads are not required.
. Each of the overhead allocations wil be distinguished by a separate
Category (ex Local, Seg, Corp) within project costing. The category field
is a breakdown within the Source field OHEAD. Reports can be ru on the
Category field to gather tota overheads for a period or to retreve a
breakdown by overhead category. Benefits and Vehicle costs are identified
by BENEF and VEHIC respectively.
. Overhead will be trcked in the Project Costing module using reports
written for that purose (ex. Report UWPC60M provides a breakdown of
costs for any project. Rung the Overhead_xx project on a life to date
basis provides the user with the amount of overheads that have not been
distrbuted to date) The General Ledger should not be used to track
overheads or any other project. All project trackig should be done from
the Project Costing module.
B. Local Overheads
Local Overheads are capital related costs incurred by local Business Units and
include thee main types of expenses: Labor, Materials and General Expenses.
Also included are benefits and vehicle costs that are applied to labor hour as par
of the Benefit and Vehicle allocation processes. Where possible, all costs should
be charged direct to a valid approved project. However in some cases, charging to
a valid approved project is not practical such as time spent reviewig capital
budgets. In ths case, the time will be captued as local overheads and will be
allocated to all projects though and overhead allocation process. The Local
Overhead project should be restrcted to costs that are definitely capital related
and are not chargeable to a specific capital project. The Local Overhead costs are
combined into a single total in order to calculate an overhead rate to allocate local
expenditues.
The Local Overhead percentage is determined by takg the tota budgeted Local
Overhead costs and dividing by the Gross Capita Expenditues for the Business
Unit excluding Local, Segment and Corporate Overheads and Interest to
constrction (AFUDC)
Tota Budgeted Local Overhead Charges
()verhead ~ == -------------------------------------------------------------------------------
(Gross CapEx - Local, Segment, Corp Overhead Charges - AFUDC)
The Local Overhead allocation is ru each month after all costs have been
recorded including the Benefit and Vehicle allocations. The Local Overhead Rate
will be charged to every dollar in project costing charged to CWI, including the
Benefit and Vehicle allocation costs.
Materials
Materials associated with specific capita projects should always be
charged direct to that project. Materials purchased for use on multiple non-
specific projects should be charged to the Local Overhead project. An
example of ths is stone, which is usually purchased in bulk and used in
many projects.
Labor
Payroll Expenditues associated with a specific capita project should be
charged directly to that project. Time related to capital, but not specifically
related to a specific project, should be charged to the Overhead Local
project. Direct charging of small increments of time to specific projects is
unealistic. COMMON SENSE should be used when determnig whether
to charge directly or to the Local Overhead project. All employee time
spent on capital activities must be charged to a CWIP account, either
directly to a capita project or to the Local Overhead project. Time should
be charged to the where the employee spends their time. Predetermined
percentages are not to be used to record time.
General Expenses
General Expenses are costs that canot be charged directly to a specific
work order but are recognized as a component of the capital process. Rent
paid for office space for engineenng personnel would be an expense that
should be capitalized in the Local Overhead account. Other costs would
include engineenng supplies, telephone costs, etc.
The decision as to what items should be capitalized as General Expenses
in the Local Overhead project should be reviewed and approved by the
local Company manager.
c. Segment Overheads
Segment Overheads are costs incured by employees of the Regulated Segment of
United Water M&S Co. and are compnsed maiy of Labor, Consulting and
General Expenses. Also included are benefits costs that are applied to labor hours
as par of the Benefit allocation process. Where possible, all costs should be
charged direct to a valid approved project. However in some cases, charging to a
valid approved project is not practicaL. For example, time spent reviewing capita
budgets normally canot be charged to a specific project. In ths case, the time
will be captued as Segment Overheads and will be allocated to all projects
through an overhead allocation process. The Segment Overhead project should
not be used as a dumping ground but should be restrcted to costs that are
definitely capital related and are not chargeable to a specific capita project. The
Segment Overhead costs are combined into a single total in order to calculate an
overhead rate to allocate local expenditues.
The Segment Overhead percentage is determined by tang the total budgeted
Segment Overhead costs and dividing by the Gross Capital Expenditues for the
Business Unit less Segment and Corporate Overheads and Interest to construction
(AFUDC).
Total Budgeted Segment Overhead Charges
Seg Overhead % = --------------------------------------------------------------------------------
(Gross CapEx - Seg & Corp Overhead Charges - AFUDC)
The Segment Overhead allocation is ru each month afer all capita costs have
been recorded including the local Overhead, Benefit and Vehicle allocations. The
Segment Overhead Rate will be charged to every dollar in project costing charged
to CWI, including the Local Overhead, Benefit and Vehicle allocation costs.
D. Corporate Overheads
Corporate Overheads are capital related costs incurred by employees of United
Water M&S Co. and are comprised mainly of Labor, Consulting and General
Expenses. Also included are benefits that are applied to labor hours as par of the
Benefit allocation processes. Where possible, all costs should be charged direct to
a valid approved project. However in some cases, charging to a valid approved
project is not practicaL. For example, time spent reviewing capita budgets is not
normally charged direct to a project. In ths case, the time will be captued as
Corporate Overheads and will be allocated to all projects though an overhead
allocation process. The Corporate Overhead project should not be used as a
dumping ground but should be restrcted to costs that are definitely capital related
and are not chargeable to a specific capital project. The Corporate Overhead costs
are combined into a single total in order to calculate an overhead rate to allocate
local expenditues.
The Corporate Overhead percentage is determned by taking the tota budgeted
Corporate Overhead costs and dividing by the Gross Capita Expenditues for the
Business Unit less Corporate Overheads and Interest to constrction (AFUDC)
Total Budgeted Corp Overhead Charges
Corp. Overhead % = -------------------------------------------------------------------------------
(Gross CapEx - Corp Overhead Charges - AFUDC)
The Corporate Overhead allocation is ru each month after all costs have been
recorded including the Local Overhead, Segment Overhead, Benefit and Vehicle
allocations. The Segment Overhead Rate will be charged to every dollar in project
costing charged to CWIP, including the Local Overhead, Segment Overhead,
Benefit and Vehicle allocation costs.
E. Transportation
Transporttion costs on local Business units are to be charged to account 18420
Clearng-Transporttion. These costs are then allocated to expense, capita, other
based on a Vehicle allocation process within the PeopleS oft system. Ths
allocation does not apply to United Water M&S employees.
Each local Business Unit is to identify those employees with access to Company
vehicles or who receive a Vehicle allowance for use of their vehicle. The Local
Company managers are responsible for reviewing ths list semianually to ensure
that the list is complete and accurate. They are also responsible to ensure that any
changes are made with the PeopleSoft system to correct any inaccuracies. A
signed copy of this review is to be mailed to the Segment Controller's offce,
where it will be reviewed and fied as par of the anual CODIS compliance.
The allocation of the Vehicle costs in PeopleSoft is accomplished by tag the
balance in the 18420 Clearng -Transporttion account at month end and
allocating it to the curent month payroll dollars of those employees included by
the local Company manager on the vehicle list described above. Only the time of
those employees are used in the vehicle allocation. The entr to record the data is
to debit expense/capitaother and credit account 18420. The 18420 account
should be zero at the end of each month.
F. Employee Benefits
Benefits are employee related expenses which are deemed to be a par of an
employee's compensation and should follow the employee's time wherever it is
charged. Benefits will be added to all labor charged to any capital project,
including labor charged to a capita overhead project. The Benefit Overhead is
based on an allocation of costs charged to certn benefit accounts in the Genera
Ledger which have been identified as being appropriate for re-allocation from
expense. This re-allocation is based on time sheets prepared by each employee.
When capital is charged on the time sheet, a portion of the employee benefits are
transferred from expense to capital to reflect the fact that these costs should
follow an employees time.
Examples of costs included in the benefits calculation are:
. Payroll taes paid by the employer
. Pension Costs
. Post Retirement Benefit Costs
. Group Medical Costs
. 401K Costs
. Worker Compensation costs
Because benefits don't flow into the General Ledger evenly thoughout the year, a
"Predicted monthly benefit amount" is calculated and used in the Benefit
allocation process. The "Predicted monthy benefit amount" is calculated using
the employee benefits from the anua operating plan and dividing those benefits
by 12.
For example, if tota benefits for the year are $1,200,000, the "Predcted
monthy Benefit amount" would be $100,000. Ths amount is allocated out
each month based on total payroll costs. The amount is divided by tota
payroll dollars and is applied to each dollar of payroll in that month. If
20% of the payroll costs are charged to capita, 20% of the frges should
follow. The $100,000 is biled out in the Fringe benefit allocation process
which debits account 10700 CWI and credits account 18410 Clearng-
frnge Benefits.
At Month end, another PeopleSoft process moves the actu Benefit costs
on the General Ledger to the 18410 account as a debit. Ths allows anyone
to see whether benefits have been over or under biled for the period
simply by looking at the 184 i 0 account. A debit balance in the account
means that Benefits have been under biled, while a credit balance
indicates that Benefit costs were overbiled.
At year end, the balance in the account must be zero as all Benefits are
required to be biled out durng the curent calendar year. Thoughout the
year the balance in account 18410 is monitored and adjustments are made
to the "Predicted monthy benefit amount" as needed to be sure the
account zeros by year end.
Benefits are applied to all payroll dollar durng the month and follow the labor to
whatever account they are charged on the time sheets.
UWldaho
Summary of Construction Overheads
2008 and 9 months 2009
Jan-08
Feb-08
Mar-D8
Apr-08
May-08
Jun-08
Jul-D8
Aug-08
Sep-08
Oct-D8
Nov-D8
Dec-08
Corporate
8,736.00
3,695.92
8,347.16
6,953.64
4,830.73
14,288.50
5,316.60
18,655.71
6,160.30
18,705.15
12,888.96
13,007.81
121,586.48
Regulated
25A44.61
10,765.23
24,312.11
14,680.74
10,198.72
30,165.79
11,224.37
39,386.45
2,727.04
8,280.08
5,705.41
(0.57)
182,889.98
Staff Set 1 Request 14
Attachment B
Local
48,181.05
19,186.81
40,795.46
48,806.75
33A74.22
103,051.82
36,610.87
108,246.82
31,837.91
101,089.21
34,539.77
34,942.88
640,763.57
Totals
82,361.66
33,647.96
73A54.73
70,441.13
48,503.67
147,506.11
53,151.84
166,288.98
40,725.25
128,074.44
53,134.14
47,950.12
945,240.03
Corporate Regulated Local Totals
Jan-D9 12,662.94 86,324.55 19,941.71 118,929.20
Feb-09 7,387.76 47,871.49 11,634.11 66,893.36
Mar-09 7A58.27 44,822.52 11,745.30 64,026.09
Apr-D9 5,786.11 42,734.49 9,112.00 57,632.60
May-D9 9,023.44 68A22.16 14,210.05 91,655.65
Jun-09 9,696.75 72,831.27 15,270.42 97,798.44
Jul-09 8,575.98 65,122.35 13,505.32 87,203.65
Aug-09 0.04 117,521.24 24,001.54 141,522.82
Sep-09 0.00 33,952.93 10,126.13 44,079.06
Oct-D9 0.00
Nov-D9 0.00
Dec-09 0.00
60,591.29 579,603.00 129,546.58 769,740.87
Journal entry to record amounts:
Corporate:
Dr 107 Construction Work in Progress
Cr 233 Accounts Payable Affilates
Regulated:
Dr 107 Construction Work in Progress
Cr 233 Accounts Payable Affliates
Local:
Dr 107 Construction Work in Progress
Cr 107 Construction Work in Progress- Overhead Project
UWldaho
Fringe Benefits Transferred to construction
2008 and 9 months 2009
Staff Set 1 Request 14
Attachment C
2008 employee benefits transferred to Construction Benefits
00060 United Water Idaho BENAL 51,288.00 2008 1
00060 United Water Idaho BENAL 53,790.99 2008 2
00060 United Water Idaho BENAL 53,947.66 2008 3
00060 United Water Idaho BENAL 49,689.64 2008 4
00060 United Water Idaho BENAL 47,197.12 2008 5
00060 United Water Idaho BENAL 49,346.93 2008 6
00060 United Water Idaho BENAL 55,205.68 2008 7
00060 United Water Idaho BENAL 55,445.17 2008 8
00060 United Water Idaho BENAL 53,251.65 2008 9
00060 United Water Idaho BENAL 58,987.93 2008 10
00060 United Water Idaho BENAL 42,052.47 2008 11
00060 United Water Idaho BENAL 51,599.28 2008 12
621,802.52
2009 benefits
00060 United Water Idaho BENAL 48,280.39 2009 1
00060 United Water Idaho BENAL 56,793.77 2009 2
00060 United Water Idaho BENAL 59,114.84 2009 3
00060 United Water Idaho BENAL 67,117.42 2009 4
00060 United Water Idaho BENAL 62,769.17 2009 5
00060 United Water Idaho BENAL 55,626.25 2009 6
00060 United Water Idaho BENAL 61,423.23 2009 7
00060 United Water Idaho BENAL 58,478.29 2009 8
00060 United Water Idaho BENAL 63,246.62 2009 9
532,849.98
Entry to record data:
Dr 107 construction work in Progress
Cr 675 (922) Fringe Benefits Transferred