WHISTLEBLOWING: RESPONDING TO THE RACE TO REPORT

February 3, 2011

REMINDERS
In order to receive participation credit, you must: Be appropriately registered for Webcast #21297 within the BDO Online CPE Network Be logged in for the entire webcast Be responsive to at least 75% of all polling/review questions

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Q&A FEATURE
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PRESENTERS
Select Experience Over ten years of experience in accounting for private and publicly traded businesses. Member of the Financial Reporting Disputes and Investigations group, encompassing securities litigation, accountants professional liability, and corporate internal investigations. Assists organizations and their counsel with matters involving alleged financial statement irregularities and management fraud as well as fraud perpetrated by rogue employees. Participated in a number of internal investigations and matters involving whistleblower allegations. Helps counsel identify relevant documents during discovery and prepare for depositions of witnesses concerning testimony that involves the application of generally accepted accounting principles (GAAP) and generally accepted auditing standards (GAAS). Education B.S., Accounting, The College of New Jersey
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Nicole Sliger, CPA, CFE, CFF

Director BDO Consulting New York, NY nsliger@bdo.com 212-885-8062

PRESENTERS
Select Experience Focuses on securities transactions and M&A transactions, restructurings and bankruptcies, and general corporate matters Worked for underwriters and issuers in a wide array of industries on offerings of diverse types of securities, medium-term note programs, 144A offerings and debt tenders, and M&A transactions Regularly advises on SEC reporting, disclosure and corporate governance issues Recently served as Chair of the Securities Regulation Committee and Chair of the Financial Reporting Committee of the New York City Bar Education J.D., Cornell Law School B.A., Cornell University, College Scholar

N. Adele Hogan
Cadwalader, Wickersham & Taft LLP New York, New York Adele.Hogan@cwt.com 212-504-5586 917-402-3688

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PRESENTERS
Select Experience Twenty-five years of experience assisting clients with securities litigation matters and investigations involving alleged financial statement and management fraud, as well as representing accounting firms against claims arising from professional liability issues. Co-National Director of the Securities Litigation & Regulatory Enforcement practice. He is also the lead Partner on Credit Crisis Litigation matters. Led numerous high profile securities litigation engagements and investigations. Testified before various courts, including the International Court of , g Arbitration and the American Arbitration Association, and has presented investigation results to the staff of the Securities and Exchange Commission and various committees. Education B.S., Accounting, Long Island University, (C.W. Post Center), summa cum laude
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Anthony M. Lendez, CPA, CFE, CFF

Partner BDO Consulting New York, NY alendez@bdo.com 212-885-8025

PRESENTERS
Select Experience Over twenty years experience in Risk Management and Compliance His writings have been featured in National Underwriter Magazine and Risk Management Magazine and his commentary on the Fox Business Channel Led the development of an integrated Governance, Risk and Compliance (GRC) platform that brings together policy management, compliance training/certification, issue/incident detection, event/case management, corrective action/remediation management and business intelligence/analytics Featured speaker at conferences hosted by the Institute of Internal Auditors (IIA), the Risk and Insurance Management Society (RIMS), (RIMS) the Association of College and University Auditors (ACUA) Provides over 3,000 companies, including nearly 50% of the Fortune 500, with GRC related solutions Education B.S., University of Central Florida, with a concentration in business and risk management
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Luis Ramos
Chief Executive Officer The Network, Inc. , Norcross, Georgia luisramos@tnwinc.com 770-409-5011

PROGRAM OBJECTIVES
Review the Dodd-Frank Acts whistleblower provisions, the proposed SEC rules, some criticisms of these proposed rules, and the related amendments to the U.S. Sentencing Guidelines Discuss the impact on companies compliance/ethics programs, boards and audit committees, and employees Provide practical guidance on how to enhance current ethics and compliance programs in response to the new legislation to: Encourage early internal reporting of potential wrongdoing Enable companies to conduct thorough and timely investigations of allegations Assist with prudent decisions regarding self-reporting Comply with the new U.K. Bribery Act and increased Foreign Corrupt Practices Act (FCPA) enforcement
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AGENDA
Key Components
Dodd-Frank Act SEC Whistleblower Program Whi l bl P Recent Amendments to the U.S. Sentencing Guidelines U.K. Bribery Act and FCPA Enforcement Activities

Current State of Affairs How Companies Can Respond

- Mitigate Impact on Compliance & Ethics Programs g p p g - Enhance Existing Internal Reporting Systems - Expedite the Process to Investigate & Possibly Self-Report

Questions & Comments

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KEY COMPONENTS
DODD-FRANK ACT The Dodd-Frank Wall Street Reform and Consumer Protection A t P t ti Act was signed into l i d i t law on July 21, 2010 J l 21 Whistleblower provisions are designed to incentivize and protect individuals who voluntarily provide original information to the SEC Significantly expands the scope of whistleblower claims and applicable entities from Sarbanes-Oxley (SOX)

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KEY COMPONENTS
DODD-FRANK ACT Eligibility for awards Original Information Must be:
- Derived from independent knowledge or analysis - Not known to the SEC from other sources - Not exclusively derived from an allegation made in a judicial or administrative hearing, other governmental proceeding, investigation or news media

- Voluntarily provided by whistleblower Successful SEC enforcement action with > $1M in sanctions 90-Day Grace Period
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KEY COMPONENTS
DODD-FRANK ACT Substantial monetary awards 10 30% of the sanctions i 10-30% f h i imposed over $1 million d illi Amount varies based on a number of criteria including:
- Significance of information to the successful enforcement and imposition of monetary sanctions - Degree of assistance provided by whistleblower - Interest of SEC/CFTC in deterring securities and commodities law violations - Whether an award enhances the SECs or CFTCs ability to enforce securities and commodities laws, protect investors, and encourage the submission of high-quality tips
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KEY COMPONENTS
DODD-FRANK ACT Expanded scope of claims and applicable entities
Relates to any potential violation of securities laws, including FCPA
- Previously only insider trading violations could be the basis for an award under the SECs previous program - For first time applies to Commodity Exchange Act (CEA) (violations over commodity futures trading is overseen by Commodity Futures Trading Commission (CFTC))

Any action brought by the SEC/CFTC under the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, 1940 the Investment Company Act of 1940 Applicable to both public AND private companies including: - Statistical rating organizations - Subsidiaries and affiliates whose financial information is included in consolidated financial statements of a publicly-traded entity
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KEY COMPONENTS
DODD-FRANK ACT Additional anti-retaliation safeguards and enhanced protections t ti Private cause of action for individuals discriminated against by employers due to whistleblowing Applies to anyone who provides information on a potential violation, regardless of whether a securities or commodities law violation is ultimately determined Remedies include double back-pay (but not for CEA whistleblowers) with interest, restatement of seniority status, and attorneys fees

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KEY COMPONENTS
DODD-FRANK ACT Lengthened reporting period for whistleblower retaliation claims
Originally under SOX, whistleblowers had 90 days after the date of the alleged retaliatory conduct or after the individual became aware of the alleged retaliatory conduct to bring a complaint Now its 180 days Under Dodd-Frank, up to a maximum of ten years for SEC retaliation claims - No more than six years after the violation -oror - Three years after facts material to the right of action are known or reasonably should have been known by the employee For CTFC retaliation claims, up to a maximum of two years Reporting pre-Dodd-Frank Act conduct may still qualify for award
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KEY COMPONENTS
SEC WHISTLEBLOWER OFFICE Office to be created as part of the Dodd-Frank Act (put ( t on hold d t b d t h ld due to budgetary i issues) ) Expands and remakes the SECs previous program Timeline of events
- November 3, 2010 Proposed rules issued - December 17, 2010 - Comment period ended - April 17, 2011 - Final rules must be issued

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POLL
What are your initial thoughts on the SECs proposed whistleblower guidelines? A. The Proposed Rules are acceptable as initially issued. B. With a few minor tweaks, the Proposed Rules should be an effective way to increase reports of securities violations. C. C The Proposed Rules require significant rework rework. D. Even with significant rework, the Proposed Rules will not be an effective way to increase reports of securities violations.
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KEY COMPONENTS
SEC WHISTLEBLOWER PROGRAM Criticisms of proposed rules Permit awards to culpable individuals, and thus, may reward misconduct
- Awards to whistleblowers who engage in the wrongdoing are not eligible if they are convicted of a criminal offense in relation to the wrongdoing - While fines based on conduct that a whistleblower directed, planned or i iti t d are not i l d d i t t l award f l d initiated t included in total d for purposes of calculating whistleblowers potential award, culpable individuals are still eligible, and misconduct could thus be condoned
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KEY COMPONENTS
SEC WHISTLEBLOWER PROGRAM Criticisms of proposed rules Large incentive created for employees to bypass internal reporting systems
- Enormous awards potentially available under the new program Some recent enforcement actions have resulted in sanctions exceeding $100 million - Proposed Rules contain no requirement that an individual utilize an internal reporting system first SEC commentary on rules states that the agency may consider internal reporting as a factor in determining a higher percentage
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KEY COMPONENTS
SEC WHISTLEBLOWER PROGRAM Criticisms of proposed rules 90-day grace period creates a deadline for voluntary disclosures
- Attempt by the SEC to avoid discouraging the use of internal reporting systems, but creates no affirmative incentive for employees to use such systems - 90 days is rarely enough time to properly investigate an allegation of employee misconduct; corporations may b ll ti f l i d t ti be forced to self-report without knowing all the facts relating to the potential violation

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KEY COMPONENTS
SEC WHISTLEBLOWER PROGRAM Criticisms of proposed rules
Lack of clarity in exclusion from eligibility of individuals with legal or compliance responsibilities
- Such personnel are generally excluded from eligibility in most circumstances, but may be eligible in cases of bad faith or where the company fails to report to the SEC in a reasonable time

Do not address SEC procedures for sharing information with affected companies to permit them to address reports internally
- Commentary states the agency will share information in appropriate cases, but does not provide further detail

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KEY COMPONENTS
SEC WHISTLEBLOWER PROGRAM Criticisms of proposed rules Provide no guidance on the anti-retaliation provisions of Dodd-Frank
- Dodd-Frank creates cause of action for individuals that suffer employment discrimination because of whistleblower status - An employee may violate code of conduct by failing to report misconduct i t t i d t internally, b t nevertheless b a ll but th l be whistleblower under the proposed rules - Employers risk litigation by enforcing code of conduct in such situations
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KEY COMPONENTS
RECENT AMENDMENTS TO THE U.S. SENTENCING GUIDELINES Provide increased opportunity for companies to reduce the penalties imposed for securities law violations by:
Having an effective compliance and ethics program in place Including anti-retaliation provisions in compliance programs Incorporating direct reporting obligations between the head of the compliance program and the Board of Directors or Audit Committee Assessing and reporting on the implementation and effectiveness of the compliance and ethics program at least annually
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KEY COMPONENTS
U.K. BRIBERY ACT Provides more stringent rules than those established in the U.S. US
Applies to all companies with a business presence in the U.K. Effective April 2011 (Delayed Perhaps until three months after application guidance is established) Failure to prevent bribery, not only the act of bribery itself, will now be punishable by law Companies can protect themselves from liability by implementing adequate procedures

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KEY COMPONENTS
U.K. BRIBERY ACT Differs from the Foreign Corrupt Practices Act (FCPA) in several ways the U K Bribery Act: U.K.
Makes no exception for small facilitation payments Establishes liability on behalf of companies for the failure to prevent bribes, even if bribes were given without the knowledge of the company Explicitly prohibits the bribery of private citizens, not just government officials Includes criminal penalties of up to ten years in prison, as opposed to five years as stipulated by the FCPA
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KEY COMPONENTS
U.K. BRIBERY ACT Establishes draft guidance on six principles intended to identify risks and outline expectations:
1) Risk Assessment Companies must identify possible risks, including a deficiency of employee knowledge of bribery regulations or a lack of clear policies regarding potentially confusing issues (e.g., gifts and travel expenses) 2) Top Level Commitment Top management must show their commitment to fair business practices and make it a priority to facilitate a zero tolerance environment 3) Due Diligence Companies should have comprehensive knowledge of third parties with whom they are doing business
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KEY COMPONENTS
U.K. BRIBERY ACT Establishes draft guidance on six principles intended to identify risks and outline expectations:
4) Clear, Practical and Accessible Policies and Procedures Companies should establish mechanisms to prevent bribery throughout the company 5) Effective Implementation Must be clearly outlined and embedded throughout the company including training 6) Monitoring and Review Internal checks and balances and external verification must be undertaken to ensure on-going compliance with bribery regulations, even as the risk environment undergoes changes
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KEY COMPONENTS
FCPA ENFORCEMENT ACTIVITIES The SEC released new enforcement criteria in 2010:
The Department of Justice (DOJ) has recently reemphasized its commitment to the FCPA, wanting to usher in a new era of enforcement The DOJ aims to be more aggressive in its enforcement and prosecutorial efforts The SEC has also appointed new leadership to lead the FCPA pp p Unit Cheryl J. Scarboro, Chief of the FCPA Unit

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KEY COMPONENTS
FCPA ENFORCEMENT ACTIVITIES Recent trends in FCPA enforcement:
Increased Number of Prosecutions Average number of FCPA enforcement cases per year increased 400% from approximately 10 cases between 2004-2006 to 40 cases in 2009 alone Increased Penalties In the past year, the DOJ has imposed criminal penalties totaling over $1 billion, up from just $11 million in 2004 Longer Sentences for Individuals In April 2010, the longest sentence was handed down - 87 months in prison! Focus on International Cooperation DOJ is committed to establishing effective partnerships with overseas agencies
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POLL
Is your current compliance/ethics program sufficient to encourage internal reporting by employees? A. B. C. D. D E. F. Yes, absolutely Probably Marginally sufficient No, No not at all Not sure / Not applicable I dont want to answer this question Plead the 5th!

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CURRENT STATE OF AFFAIRS

WHERE DO WE GO FROM HERE? Impact on boards and audit committees May limit the time available to investigate and assess claims May compel hasty self-reporting of potential wrongdoing without vetting out facts May require increased training on Dodd-Franks whistleblower provisions, U.K. Bribery Act, and FCPA provisions May require increased communications to include the tone at the top as one of compliance

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CURRENT STATE OF AFFAIRS

WHERE DO WE GO FROM HERE? Impact on compliance/ethics programs Bounties create incentives for employees to bypass internal compliance/ethics programs and report directly to the SEC Could undermine internal programs by reducing the effectiveness of the companys existing procedures for indentifying, investigating and responding to potential violations of federal securities laws Whistleblowers might be encouraged to wait until a potential problem grows into a larger issue to increase their chance of collecting a more significant award
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CURRENT STATE OF AFFAIRS

WHERE DO WE GO FROM HERE? Impact on employees Provides financial incentive to report directly to the SEC Provides greater retaliatory protections when reporting wrongdoing to the SEC May need to restore faith in the effectiveness of the companys processes to entice them to report internally May require encouragement to use internal reporting May affect employment agreements

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POLL
To date, how has your company p p y p y prepared itself to respond to p new legislation / proposed rules? A. B. C. D. D We have discussed at length and in significant detail We have discussed briefly at a high-level We have not held any discussion at this time Not N sure / not applicable li bl

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HOW COMPANIES CAN RESPOND

MITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS Review and update relevant aspects of existing compliance programs
Employee codes of conduct Training programs Conduct early and often, live-based with multiple mediums and interactive discussions Internal reporting systems - Encourage use; bounties Clear procedures for investigating reports P Procedures for addressing required remediation d f dd i i d di i Post notices on intranet sites and provide compliance materials and policies online

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HOW COMPANIES CAN RESPOND

MITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS Implement policy enhancement suggestions and internal corrective measures Companies may consider:
Drafting requirements for simultaneous disclosure clauses in employment contracts and compliance policies Developing internal bounty programs Promoting recognition of tips that were awarded I Incorporating substantive ethics metrics i t corporate ti b t ti thi t i into t competencies and performance evaluations

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HOW COMPANIES CAN RESPOND

MITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS Implement policy enhancement suggestions and internal corrective measures Companies may consider:
Lengthening document retention policies Amending vendor and supplier contracts to have vendors and suppliers notify the companies of any suspected wrongdoing Obtaining quarterly certifications from employees stating that no wrongdoing is suspected or has been observed

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HOW COMPANIES CAN RESPOND

MITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS Develop anti-retaliation policies and procedures Ensure current policies are updated for all new antiretaliation protections Educate employees on the existence of such policies Entice employees to come forward internally Communicate regularly with employees on antiretaliation and other compliance policies

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HOW COMPANIES CAN RESPOND

MITIGATE IMPACT ON COMPLIANCE & ETHICS PROGRAMS Heighten the visibility and availability of compliance and ethics programs through: Involvement of top management in communications to add creditability and emphasize importance Training programs Availability of hotline programs
24-7/365 Access Cover all geographic/international locations Be aware of language barriers Expand reach to third parties such as customers, suppliers, business partners, competitors, etc.
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POLL
How often does your company provide training or communications on internal reporting mechanisms? A. B. C. D. E. Frequently (more than twice a year) Once annually Very seldom Never Not sure / Not applicable

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HOW COMPANIES CAN RESPOND

ENHANCE EXISTING INTERNAL REPORTING SYSTEMS Assess functionality of current internal reporting systems and investigative procedures Companies should ask themselves:
- Do employees utilize the existing system? - How does our hotline compare to others in the industry?

Perform periodic reviews (at least annually) y Assess and evaluate by:
- Anonymous surveys - Exit and other interviews - Benchmarking - Feedback from reporting system users - Focus groups - Incident logs
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HOW COMPANIES CAN RESPOND

ENHANCE EXISTING INTERNAL REPORTING SYSTEMS Employ effective internal reporting mechanisms Evaluate and update i l d d internal compliance programs l li Ensure that any reports received from employees through internal mechanisms remain confidential (and this is clear to employees), and where appropriate, lead to prompt investigation and disciplinary action Elicit trust by exhibiting a corporate culture that takes claims of fraud and other potential violations seriously

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HOW COMPANIES CAN RESPOND

ENHANCE EXISTING INTERNAL REPORTING SYSTEMS Encourage board & audit committee involvement R i i corporate culture to ensure i promotes an Revisit l it open, honest and candid environment Review current policies for unlawful acts Request regular reports on hotline complaints, ongoing analyses/investigations and resolutions p p g Reiterate importance of internal reporting and participate in regular training on compliance/ethics programs

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HOW COMPANIES CAN RESPOND

ENHANCE EXISTING INTERNAL REPORTING SYSTEMS Utilize live, skilled interviewers to handle call intake B tt able t elicit complete and relevant Better bl to li it l t d l t information regarding allegations Ensure interviewers have the requisite language skills to accommodate ethnic backgrounds and international callers Assist with preserving anonymity and confidentiality, especially if third-party, which, in turn, will encourage use of internal system

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HOW COMPANIES CAN RESPOND

ENHANCE EXISTING INTERNAL REPORTING SYSTEMS Provide true confidentiality O igi of calls should remain secret (i l di g Origin f ll h ld i t (including incoming numbers or Caller ID) Gender should not be revealed Unique ID code should be provided to caller to followup on his/her report or to report more information about their claim at a later date Secure data and maintain integrity of access to internal reporting systems

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POLL
How well would you rate your companys internal compliance/ethic/hotline reporting system? A. B. C. D. Very effective Somewhat effective Not nearly as effective as it should be Not sure / Not applicable

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HOW COMPANIES CAN RESPOND

EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORT Establish & execute prearranged investigative procedures Define clear roles and responsibilities for those assigned to evaluate tips Implement clear lines of reporting from hotline to senior management, the Board and the Audit Committee Consider developing a report distribution matrix Employ controls to reduce risk of management override Create a clear communication process for status reports Establish a disciplinary committee to assess remedial actions
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HOW COMPANIES CAN RESPOND

EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORT Perform a preliminary assessment of the allegations Corroborate or disprove the allegations Gain an understanding of the scope, origin and reach of the alleged misconduct Determine the nature and amount of resources needed to carry out an investigation (if needed) Identify legal, accounting, and investigative experts upfront f

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HOW COMPANIES CAN RESPOND

EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORT Plan and execute an investigation, if warranted Determine the scope and identify a lead person to direct the investigation Identify specific objectives, responsibilities and work product to be produced upfront Limit continuation of alleged misconduct Consider using outside counsel as appropriate Investigate all internal whistleblower reports thoroughly, including anonymous reports Document companys receipt, review of, and response to each complaint/report
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HOW COMPANIES CAN RESPOND

EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORT Consider following-up on allegations by: Informing whistleblowers about the investigations progress and address any additional concerns Publicizing internally the results of the companys review and response where violations are found Mitigating possible future whistleblowers, when employee separates from the company Analyzing trends in claim volume by type of claim and frequency and benchmark to industry to monitor for similar complaints of past allegations

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HOW COMPANIES CAN RESPOND

EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORT Develop procedures to address reports to the SEC Outline specific procedures for senior managers to rapidly respond to the SEC in the event of a whistleblower complaint Devise a document production process in the event requests are made by the SEC Arrange resources in anticipation of independent internal investigations i ti ti Identify protocols for notifying third parties such as auditors, investors and the public

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POLL
Does your company have appropriate prearranged investigative procedures in place? A. B. C. D. Yes, very much so Somewhat No, not at all Not sure / Not applicable pp

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HOW COMPANIES CAN RESPOND

EXPEDITE THE PROCESS TO INVESTIGATE AND SELF-REPORT Implement mechanisms that result in more thorough selfreporting Requires careful evaluation to determine the most prudent course of action Keep in mind the strict time limitations with the 90-Day grace period Consider remediation and disciplinary actions for those involved i possible violations i l d in ibl i l ti Be mindful of credits offered by the SEC for cooperation Be careful not to self-report prematurely before the alleged violation can be investigated adequately
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POLL
After listening to our discussion today, do you feel opportunities exist to enhance performance of your companys i t internal compliance and ethics programs? l li d thi ? A. B. C. D. D Yes, very much so Somewhat No, not at all Not sure / Not applicable

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POLL
After listening to our discussion today, what are your thoughts now on the SECs proposed whistleblower guidelines? A. The Proposed Rules are acceptable as initially issued. B. With a few minor tweaks, the Proposed Rules should be an effective way to increase reports of securities violations. C. The Proposed R l require significant rework. C Th P d Rules i i ifi t k D. Even with significant rework, the Proposed Rules will not be an effective way to increase reports of securities violations.
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QUESTIONS & COMMENTS

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HELPFUL RESOURCES
- BDO Practice Aid: Strengthening Corporate Governance: Effective Mechanisms for Reporting, Investigating and Remediating Fraud http://www.bdo.com/acsense/practiceaids.aspx p p p - Acsense 2010 Internal Investigations http://www.bdo.com/acsense/events/InternalInvestigations.aspx - BDO Consulting Thought Leadership http://www.bdoconsulting.com/resources/thought-leadership.aspx - Cadwalader, Wickersham & Taft LLP http://www.cadwalader.com/ - The Network, Inc. http://www.tnwinc.com/index.aspx

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PRESENTER CONTACT INFORMATION

Todays Presenters: N. ADELE HOGAN ANTHONY M. LENDEZ LUIS RAMOS NICOLE SLIGER adele.hogan@cwt.com alendez@bdo.com luisramos@tnwinc.com nsliger@bdo.com

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ADDITIONAL ACSENSE INFORMATION

AcsenseSM Programs and Website: http://www.bdo.com/acsense/
NOTE: Link to a self study course of todays program will be available self-study today s shortly at: http://www.bdo.com./acsense/events/Whistleblowing.aspx

Upcoming webcast: Executive Compensation: Impact of the Dodd-Frank Act and Next Steps February 23, 2011 p y , http://www.bdo.com./acsense/events/ExecutiveCompensa tion.aspx

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CPE CERTIFICATES
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1. 1 Individuals - by logging onto the http://university.learnlivetech.com/BDOonline after the session is completed and clicking on My Learning - Completed Items. Under the Certificate column, click the Print button beside the completed webcast. 2. Group participants - After receipt and processing of submitted group sign-in sheets to cpdregistrar@bdo.com, group participants will be p proctored into Learn Live and will be notified via e-mail when they y can retrieve their certificates, following the steps above. 3. Sign-in sheets may be downloaded from the following: https://university.learnlive.com/content/public/1029/accessinstru ctions/CPE%20Attendance%20Sheet.doc
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EVALUATION
We continually try and improve upon our programming and appreciate constructive f db k i d i t t ti feedback Following the program, we will be sending out a thank you e-mail that contains a link to a brief evaluation Thank you in advance for you consideration!

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THAT CONCLUDES TODAYS PROGRAM.

Thank you for attending!

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