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��op01 <br />mmmc^LsEnvnces <br />� <br />Progra00Accoun'tability <br />Unlike many parking management conlpanies. SP+ rn@inU3inS an independent Internal Audit <br />Department that reports to the COnnp8ny'S Audit Committee. This direct and independent <br />reporting line 8nSUneS the integrity and objectivity Of facility audits by 8|inninBdnQ pOteDd@| <br />conflicts Ofinterest inherent inaudits conducted within the operations function itself. All required <br />internal audits are administered under the supervision Ofour corporate Director of Internal Audit. <br />The Internal Audit Department oversees identification and testing ofthe company's entity -level <br />controls including the Code Of Ethics and other high -|8V8| Q]ntnD|S that ensure the integrity of <br />SP+'sbusiness processes and financial statements. <br />Managing this process puts the Internal Audit Department in touch with every aspect of the <br />business and assures our clients that their parking facilities are properly managed. <br />Internal Auditing Prograrns <br />SP+ oversees client revenues and facilities more carefully than any other parking Operator. <br />Ensuring the integrity and objectivity Of p@/king facility audits is CridCe| to evaluating and <br />improving the financial p8rfOrnn8DCe Of C|i8Dt properties. SP* accomplishes these objectives <br />through an independent |Ot8rD8| Audit Department that reports directly iOthe company's Chief <br />Financial Officer. This direct reporting line eliminates the potential conflicts Ofinterest iOh8n8Dt in <br />audits conducted within the operations function. <br />SP+ accomplishes accountability objectives through rigorous control programs and an <br />independent Internal Audit Department that reports to the Audit CornrOiUe8 of the company's <br />Board of Directors. This direct reporting line eliminates the potential conflicts Ofinterest inherent <br />inaudits conducted within the operations function. <br />Internal Audit Department staff members—including Certified Public Accountants and facility <br />rnan8genn8ni experts—conduct audits that are performed either on @ scheduled (but <br />unannounced) basis oratthe specific request Ofsenior management. These audits cover G <br />broad spectrum Of operations including revenue Contro|e, payroll procedures, accounts <br />[8C8iv@b|e. cash security, public and employee Safety. customer service and facility <br />appearance. <br />Our auditors are familiar with industry parking technology and its impact on revenue collection <br />Each 8udh, which produces recommendations to improve operations where neuegamry, is <br />retained in a d8i3b8S8 for further analysis. The database provides an objective evaluation Of <br />nn3n8g8r performance and 8SSi5te o8OiOr management in identifying areae that need <br />improvement and additional training resources. Audits are not considered final until all <br />recommendations have been implemented successfully. Moreover, 8 significant portion of the <br />compensation payable to SP*^s management team is based on the audit scores achieved at <br />their facilities. <br />Page 13 0��| <br />