General Accounting Policy

Process Owner

Senior Executive of Corporate Finance and Accounting

Purpose

This document provides general accounting guidelines.

Definitions

None

Policy

1. All GovC organizational units shall record their assets, liabilities and operating results in accordance with generally accepted accounting principles in U.S.A., government procurement regulations and cost accounting standards, applicable tax laws and established practices.

2. All organizational units shall follow GovC’s written accounting and financial policies and practices. Managers with financial and/or accounting responsibilities are responsible ultimately to the Chief Executive Officer and Chief Financial Officer for the design, implementation and documentation of programs and controls to prevent and detect fraud and errors, and to ensure compliance with relevant GovC policies and procedures.

3. All organizational units will maintain books of account in a manner that facilitates the accumulation of consolidated data into consistent account groupings so as to achieve compliance objectives.

Responsibilities

1. Management shall hire and maintain adequate, qualified accounting and finance staff.

2. Finance and accounting management, including ones who oversee such functions, shall ensure that all personnel working under their direction are familiar with job requirements and receive adequate supervision and training in the performance of their jobs.

3. Management will ensure that all transactions recorded in the Company’s accounting and financial records are:

a. Approved in accordance with Company policies and with management’s general or specific authorization;

b. Represent valid business transactions;

c. Recorded to maintain accountability for assets;

d. Recorded to support the accumulation and proper allocation of allowable costs to contracts in our project accounting system in accordance with our disclosed practice; and

e. Recorded to permit preparation of financial statements and reports in conformity with this policy and other relevant policy statements.

4. Employees must ensure that all costs including labor, travel and material costs are accurately recorded and charged. Employees must ensure that costs are recorded currently, accurately and completely to the proper project or indirect activity in accordance with policy, contract terms and regulation.

5. Employees must ensure that all cash and checks received are promptly deposited in a GovC bank account and recorded in GovC’s accounting records. No funds shall be maintained in the form of cash, excepting the retention of reasonable amounts of petty cash.

Procedures

Management

1. Establish and maintain an organizational structure, including processes and procedures that reflect sound accounting and financial internal controls.

2. Ensure that this structure includes proper accounting and disclosure of all transactions and events, an appropriate segregation of duties, and effective internal controls to facilitate the detection and correction of errors and prevention and detection of fraud.

All Organizational Units

1. Adhere to disclosed accounting practices.

2. If any change or deviation from a disclosed accounting practice, or adoption of a new accounting practice is desired, obtain advance written approval from the CFO, Senior Compliance Officer, and Controller.

3. Changes to cost accounting practices must be implemented in compliance with Cost Accounting Standards and Federal Acquisition Regulations, including appropriate and timely notification of the Contracting Officer.