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302(a)(4)(A)
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The signing officers are responsible for establishing and maintaining internal controls.
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The
SOX-XL spreadsheet software provides security controls, audit trail and e-signature functionality to ensure the authenticity, integrity and confidentiality of electronic records, and to irrevocably link an electronic signature to its owner. Since only authorized users can create or modify any electronic record in the
SOX-XL Excel Spreadsheet, the authenticity of the record is assured. Changes to electronic records can only be made by authorized users.
The system contains a secure, computer-generated, time-stamped audit trail to independently record the date and time of operator entries and actions that create, modify, or delete electronic records. Recorded fields include date, time, user ID, full user name, worksheet modified, cell location, action type, old value and new value. The audit trail is protected and cannot be altered by users. This assures record integrity. Further, several search, querying and graphical tools are available to search the audit trail to locate the information of interest.
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302(4)(B)
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The signing officers have designed such internal controls to ensure that material information relating to the issuer and its consolidated subsidiaries is made known to such officers by others within those entities, particularly during the period in which the periodic reports are being prepared.
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SOX-XL
Reason fields and electronic signatures can be enforced to allow material information to be entered into the spreadsheet at any point during the record management life cycle which can be reviewed by the signing officers prior to approval.
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