Archived — Audit of Strategic Aerospace and Defence Initiative (SADI) Governance

October 2010

Recommended for Approval to the Deputy Minister by Departmental Audit Committee on October 19, 2010

Approved by the Deputy Minister on October 21, 2010

Table of Contents

1.0 Executive Summary

1.1 Introduction

In accordance with the approved 2009–2010 to 2011–2012 Multi-Year, Risk-Based Internal Audit Plan, the Internal Audit Directorate undertook an audit of the governance of the Strategic Aerospace and Defence Initiative (SADI).

SADI, launched in April 2007, supports industrial research and development in Canada's aerospace, defence, security and space industries. The first SADI project was approved in 2008. As of August 24, 2010, a total of 20 projects with value of more than $470 million were approved. It is the largest grants and contributions program in Industry Canada.

The Industrial Technologies Office (ITO) is a Special Operating Agency of Industry Canada. It reports through the Assistant Deputy Minister, Science and Innovation Sector. ITO is a key program delivery channel and is accountable for SADI. ITO also manages projects previously contracted through the Technology Partnerships Canada program, the Hydrogen Early Adopters Program and the Program for Strategic Industrial Projects.

Since the appointment of a new ITO Executive Director in September 2008, several significant improvement and transformation initiatives have been implemented.

The objectives of this audit were to determine the adequacy of SADI's governance framework and the implementation of ITO's risk management process. Treasury Board of Canada Secretariat's Core Management Controls define governance as "the combination of processes and structures implemented to inform, direct, manage and monitor the activities of the organization toward the achievement of its objectives."1

The scope of this audit covered governance processes for SADI managed by ITO for fiscal years 2008–2009 to 2009–2010 and the implementation of its risk management process in 2009–2010.

1.2 Overall Conclusion

Overall, the SADI governance framework and risk management practices have significantly evolved.

SADI has established an adequate governance framework, which includes the key elements contained in our audit criteria.

With regard to risk management, the implementation of the SADI risk management process is satisfactory and effective with two exceptions: the full implementation of the proposed project risk monitoring plan, and monitoring and periodic update of program-level risks.

1.3 Main Findings

Governance

1.

The SADI governance framework has been established and includes various oversight committees; roles and responsibilities within ITO are clearly defined; policies, guidelines and processes are documented; and the decision-making process is clearly outlined. A business plan, aligned with program objectives, sets out operational priorities. Minor improvements are proposed to ensure the continued relevance of the various committees.

2.

ITO and the Program and Policy Management (PPM) Directorate have not formally approved their respective roles and responsibilities for the repayment activities related to SADI projects.

3.

Management's tone and operating philosophy support and promote values and ethics. Human resources practices include regular meetings, the Employee Engagement Committee, management's open door policy and access to the ITO intranet for effective communications. However, the extent to which documentation be maintained on exit interviews and discussions relating to personnel issues should be considered.

Risk Management

4.

Risk management strategies have been documented and implemented at the corporate level, program level and project level with two exceptions. At the program level, risks need to be reassessed and updated periodically. At the project level, the risk monitoring template needs to be fully implemented.

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1.4 Recommendations

Governance

1.

The Executive Director of ITO should introduce a periodic self-assessment for the various ITO committees to ensure their continued relevance.

2.

The Executive Director of ITO and the Director General of Corporate Finance, Systems and Procurement Branch should finalize the documentation of their respective roles and responsibilities for SADI repayment activities.

3.

It is recommended, as a best practice, that the Executive Director of ITO consider the extent to which documentation should be maintained on exit interviews and discussions relating to personnel issues.

Risk Management

4.

The Executive Director of ITO should implement the risk monitoring template that includes the project monitoring plan. In addition, senior management should ensure that program-level risks are monitored and periodically updated.

1.5 Statement of Assurance

In my professional judgment as Chief Audit Executive, sufficient and appropriate audit procedures have been conducted and evidence gathered to support the accuracy of the opinion provided and contained in this report. The opinion is based on a comparison of the conditions, as they existed at the time, against pre-established audit criteria that were agreed to with management. The opinion is applicable only to the entities examined and within the scope described herein. This audit was conducted in accordance with the Internal Auditing Standards for the Government of Canada.

1.6 Audit Opinion

In my opinion, SADI has no material weaknesses in the governance and risk management processes and these processes are effective and sustainable.

__________________________________
Susan Hart
Chief Audit Executive, Industry Canada

_____________________
Date


1 Treasury Board of Canada Secretariat, Core Management Controls: A Guide for Internal Auditors (Draft), November 2007. (Return to Reference 1)

2.0 About the Audit

2.1 Background

In accordance with the approved 2009–2010 to 2011–2012 Multi-Year, Risk-Based Internal Audit Plan, the Internal Audit Directorate undertook an audit of the governance of the Strategic Aerospace and Defence Initiative (SADI). The Industrial Technologies Office (ITO) is a key program delivery channel and accountable for SADI.

In April 2007, SADI was launched to support private sector industrial research and pre competitive development in Canada's aerospace, defence, security and space industries. Through repayable project contributions, the government is helping Canadian companies undertake strategic research and development (R&D) to benefit all Canadian citizens.

An audit of SADI and Technology Partnerships Canada (TPC) was originally proposed in Industry Canada's 2008–2009 Risk-Based Internal Audit Plan to provide assurance that the initiative complied with relevant legislation, policies, directives and procedures. Risk Management, Internal Controls, Governance and Results and Performance were to be addressed.

Due to ITO and Audit and Evaluation Branch (AEB) timing issues, and the fact that ITO's governance processes were undergoing significant changes, the audit strategy was revised. An assessment of SADI/TPC's risk management and internal controls was undertaken in June 2009. The governance element of this audit was scheduled for the last quarter of 2009–2010. In addition, since ITO's new risk management framework was under development at the time of the June 2009 assessment, AEB tested its implementation during this audit. The Results-based Management and Accountability Framework (RMAF) implementation review of SADI was being conducted at the same time by AEB's Evaluation Directorate and, therefore, results and performance were excluded from this audit.

2.2 What is Governance?

There is no single, comprehensive, universally accepted definition of organizational governance; however, certain common elements are present in most definitions.Footnote 2 For example, ITO states that governance is "about mandates, responsibility and authority on the one hand, and incentives, constraints, rules and monitoring on the other."Footnote 3

Treasury Board of Canada Secretariat's Core Management Controls define governance as "the combination of processes and structures implemented to inform, direct, manage and monitor the activities of the organization toward the achievement of its objectives"Footnote 4

2.3 Entity Information

SADI's objectives are to encourage strategic R&D that will result in innovations and excellence in new products and services; to enhance the competitiveness of Canadian aerospace and defence companies; and to foster collaboration between research institutes, universities, colleges and the private sector.

As of August 24, 2010, $470 million had been approved in 20 SADI projects. This funding excludes operating resources, and is funded through a base budget and access to repayments.

SADI projects have three phases: the Application phase, the Work phase and the Benefits phase. Figure 2.3.1 illustrates the SADI project life cycle including the description of the application phase, the work phase, and the benefits phase.

Figure 2.3.1: SADI Project Life Cycle Overview

SADI Project Life Cycle Overview

[Description of Figure 2.3.1]

ITO is accountable for the delivery of SADI and operates with a workforce of 77 employees. Figure 2.3.2 shows ITO's organization structure.

Figure 2.3.2: ITO's organization structure.

Figure 2.3.2: ITO's organization structure.

[Description of Figure 2.3.2]

As part of the new initiatives, new documented processes and frameworks in ITO include talent management guidelines, Risk Management Approach and new committee structures.

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2.4 Objective

The objectives of this audit were to determine the adequacy of SADI's governance framework, and the implementation of ITO's risk management process.

2.5 Scope

The scope of this audit covered governance processes for SADI managed by ITO for fiscal years 2008–2009 to 2009–2010 and the implementation of its risk management process in 2009–2010.

All new SADI project proposals over $500,000 are required to obtain approval through Industry Canada's Programs and Services Board (PSB). This committee serves as a forum for senior Industry Canada officials to provide corporate direction. Since PSB is outside of ITO, it was excluded from the audit scope.

None of SADI's projects were in the Benefits phase (Phase 3) at the time of the audit.

2.6 Methodology

This internal audit was conducted in accordance with Treasury Board's Policy on Internal Audit and its Internal Auditing Standards for the Government of Canada. Audit fieldwork was conducted between March 2010 and May 2010. The audit approach consisted of the following:

  • The planning phase was conducted during the December 2009 to February 2010 period. It included a thorough risk assessment by AEB using the Core Management Controls in the context of SADI's governance. An audit planning memorandum was completed from which audit criteria were presented to ITO management. The audit criteria are detailed in Appendix A.
  • Over 40 key documents, including past audit and evaluation reports, were reviewed to gain an understanding of SADI's governance framework, processes and procedures, and the supporting analysis and documentation used by the program.
  • 17 interviews were conducted with program managers and staff, for inquiry and corroboration.
  • 15 SADI files were examined to test compliance and consistency for risk management processes and project-related governance practices.

Footnotes

  1. 2 Institute of Internal Auditors, Organizational Governance: Guidance for Internal Auditors (position paper), July 2006. (back to footnote reference 2)
  2. 3 Industry Canada, ITO Governance Framework (Draft), December 18, 2009 (back to footnote reference 3)
  3. 4 Treasury Board of Canada Secretariat, Core Management Controls: A Guide for Internal Auditors (Draft), November 2007. (back to footnote reference 4)

3.0 Findings and Recommendations

3.1 Introduction

This section presents detailed findings from the audit of SADI Governance. Findings are based on the evidence and analysis from both the initial risk analysis and the detailed audit conduct.

3.2 Governance

Finding 1.0: The SADI Governance Framework

The SADI governance framework has been established and includes various oversight committees; roles and responsibilities within ITO are clearly defined; policies, guidelines and processes are documented; and the decision-making process is clearly outlined. A business plan, aligned with program objectives, sets out operational priorities. Minor improvements are proposed to ensure the continued relevance of the various committees.

In reviewing the governance structure, we expected to find oversight bodies in place receiving timely and accurate information and effectively exercising their oversight function. We also expected that ITO had in place operational plans and objectives aimed at achieving SADI objectives.

Overall, ITO has established the key elements of the governance framework that defines the processes, roles and responsibilities of all parties involved in SADI; its policies, guidelines and processes are documented and provide guidance and direction to ITO and their clients; and SADI's decision-making process is clearly outlined and transparent. SADI's risk management practices have evolved significantly in the last two years as the ITO organization has undergone a transformation.

A business plan for 2010–2011 has been developed. This plan provides an opportunity for ITO to both review its progress over the last year and develop new and/or enhanced priorities and activities. The plan has been shared with all ITO staff through the ITO intranet.

In addition to a clear organizational structure, a number of committees are in place within ITO to provide guidance, direction and oversight to SADI (refer to Figure 3.2.1). The various committees in place include Senior Management Committee (SMC), Business Transformation Team (BTT), Operations Management Meeting (OMM), Review Committee, Risk Management Committee (RMC), Operational Audit Committee (OAC) and Employee Engagement Committee. Members are selected based on the needs of each committee.

Figure 3.2.1: Organizational Committees

Figure 3.2.1: Organizational Committees

[Description of Figure 3.2.1]

We found that the mandate and membership for each committee were defined in terms of reference (TOR). Our review of minutes indicated that generally, each committee was addressing its mandate. We were informed that the committee members received clear and timely information related to SADI. Based on the interviews conducted, staff stated that the interrelationships of committees were clearly understood.

At the time of our audit, we noted that all of the committees met as indicated in their TOR except for the RMC. As per the TOR, it was to meet formally at least once every two months. It had not met since January 2010, a period of 6 months. Both the Chair and the Vice-Chair had been away. While these two were away, there was no alternative meeting procedure in place. Without regular meetings of RMC, there is insufficient assurance that risk information is adequately shared.

Some of the interviewees indicated that certain committees have some of the same members as other committees (e.g., BTT, SMC and OMM) and this can place a significant time burden on the participants. It was acknowledged that all members of SMC are the members of BTT. But BTT also incorporates a number of other individuals such as the Manager, Risk and Performance Management and the Senior Advisor to the Executive Director. BTT was established with a specific mandate and is only temporary. In addition, it was suggested that there is a risk that the project officers may feel that their role is diluted if they have to take their issues to various committees. Our analysis confirms that there is no duplication in the mandates. However, as SADI governance processes mature, there may be merit in conducting self-assessments to ensure that the committees remain relevant.

Appropriate communication protocols were formed for internal and external stakeholders. Internally, information is disseminated through committee meetings and down through the directorate via staff meetings, emails and the ITO intranet. Externally, ITO follows departmental procedures to provide and receive information through media such as reports and meetings.

We found that operational plans were in place and support the achievement of SADI objectives. Linkages exist between high-level ITO business priorities and operational work objectives.

Recommendation 1.0

The Executive Director of ITO should introduce a periodic self-assessment for the various ITO committees to ensure their continued relevance.

Finding 2.0: Roles and Responsibilities between ITO and PPM

ITO and the Program and Policy Management (PPM) Directorate have not formally approved their respective roles and responsibilities for the repayment activities related to SADI projects.

In reviewing accountability, we expected that authority, responsibility and accountability would be clear and communicated throughout the organization.

SADI's program delivery comprises three phases. ITO is accountable for the Application phase and the Work phase. When it comes to the Benefits (repayment) phase, collection services have been provided by PPM for over 10 years on a cost-recovery basis. PPM reports to a different sector. PPM is considered the centre of expertise of managing repayments under Industry Canada's various repayable contribution programs. PPM is currently managing over 180 active TPC projects representing a $2 billion portfolio. PPM also manages other Departmental legacy program such as the Defence Industry Productivity Program.

The April 1, 2007, to March 31, 2010, Memorandum of Understanding (MOU) between ITO and PPM, which describes the roles and responsibilities of each party, was not formally approved by both parties. A new MOU for the period of April 1, 2010, to March 31, 2015, has been drafted by ITO. We understand that PPM needs to clarify some of the roles and responsibilities in the MOU and therefore the document was not formally signed by either party.

Both ITO and PPM staff have indicated that good communications exist between the two organizations and PPM participates in several ITO committees. However, PPM's client management approach differs during the Benefits phase.

When services are provided by a separate sector, as in this program, it is a good business practice to have both parties document and confirm their respective roles and responsibilities. Clearly documented accountabilities and responsibilities promote efficiency and effectiveness and provide clear direction for the work to be performed and related services expectations.

Recommendation 2.0

The Executive Director of ITO and the Director General of Corporate Finance, Systems and Procurement Branch should finalize the documentation of their respective roles and responsibilities for SADI program repayment activities.b>

Finding 3.0: Values and Ethics

Management's tone and operating philosophy support and promote values and ethics. Human resources practices include regular meetings, the Employee Engagement Committee, management's open door policy and access to the ITO intranet for effective communications. However considerations should be given to which extend documentation should be maintained on exit interviews and discussions relating to personnel issues should be considered.

We expected to find that management, through its actions, demonstrated that ITO's integrity and ethical values could not be compromised, and that employees formally and periodically acknowledged compliance with ITO's corporate values and ethics, code of conduct or equivalent policy.

SADI requires significant interaction with private sector companies, which creates a risk for ethical dilemmas when dealing with clients.

ITO values are included in the Business Plan for 2010–2011. Management's tone and operating philosophy are positive. This is achieved through open discussions, sharing of information and the creation of the Employee Engagement Committee, which gives employees a voice and an opportunity to be engaged. We were told that all new employees receive an orientation course and we have reviewed an orientation guide that describes the values and ethics within ITO. Employees acknowledge receiving Conflict of Interest documentation when they accept their appointment to the position. It was indicated that any issue of a personal nature is dealt with the employee directly; issues of a more general nature are discussed at staff meetings. We were informed that there is no procedure with regard to documentation of such issues.

The Executive Director conducts all entry and exit interviews with employees. These were not documented.

Recommendation 3.0

It is recommended, as a best practice, that the Executive Director of ITO consider the extent to which documentation should be maintained on exit interviews and discussions relating to personnel issues.

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3.3 Risk Management

Finding 4.0: Risk Monitoring

Risk management strategies have been documented and implemented at the corporate level, program level and project level with two exceptions. At the program level, risks need to be reassessed and updated periodically. At the project level, the risk monitoring template needs to be fully implemented.

At the time of the SADI/TPC Assessment conducted in June 2009 by AEB, ITO's Risk Management Strategies (RMS) were documented and reflected in 2007-2008 SADI Results-based Management and Accountability Framework (RMAF) and Risk Based Audit Framework (RBAF). During the assessment not all RMS were implemented, therefore, we were not able to test its implementation.

In this audit, we expected to find that ITO's RMS have been fully implemented and ITO management appropriately communicates its risk management strategies to key stakeholders.

At the corporate level, risks are identified, assessed and mitigated as part of ITO's annual business planning process. ITO's corporate level risks were incorporated in the Industry Canada's Corporate Risk Profile (updated for 2009–2010).

At the program level, risks are not reassessed and there is no evidence that these risks are being monitored and updated.

At the Project Level, risks are identified by the officer during the application phase and documented in the Project Summary Form. The results of the risk assessment are entered in the ITO Data Warehouse. Monitoring of risks forms part of the ongoing activities of the SADI investment officers. The project level risks are then updated, at a minimum, on an annual basis, the results of which are held in the ITO Data Warehouse. Procedures exist for communicating higher risk information to Deputy Minister through Quarterly High Risk Reporting and Early Warning System.

In addition, at the project level, as per the SADI Risk Rating Guidelines 2009 (p. 21), "The risk-based monitoring approach will use the risk rating to define the scope and frequency of monitoring activities (e.g., site visits, audits, repayment forecasting, financial reviews, etc.) that will take place. The Monitoring Officer develops for each project a monitoring plan that is based on the level of risk and issues associated with the company and project." ITO has developed a template to help officers prepare their monitoring plan but it was not implemented at the time of the audit.

Regular monitoring and updating of risks at the program level would help ITO achieve SADI objectives. Implementing the monitoring plan template for all projects and documenting this information in the ITO Data Warehouse would help manage the projects more effectively.

Recommendation 4.0:

The Executive Director of ITO should implement the risk monitoring template that includes the project monitoring plan. In addition, senior management should ensure that program-level risks are monitored and periodically updated.

Appendix A: Audit Criteria

Audit Criteria
Criteria Link to CMCFootnote 5 Criteria Met or Not
  1. 5 Audit criteria are derived from Treasury Board of Canada Secretariat Core Management Controls (CMC). (back to footnote reference 5)
  2. * No known departmental procedures requiring that exit interview be documented. (back to footnote reference *)
Objective 1: To determine the adequacy of SADI's governance framework

Governance
Effective oversight bodies are established.

CMC–G1 Met
Oversight bodies effectively exercise their oversight function (i.e., timely). CMC–G2 Met with exception
ITO has in place operational plans and objectives aimed at achieving SADI's objectives. CMC–G4 Met
Oversight bodies (senior management) request and receive sufficient, complete, timely and accurate information. CMC–G6 Met

Public Service Values
Management, through its actions, demonstrates that ITO's integrity and ethical values cannot be compromised.

CMC–PSV1 MetFootnote *
Employees formally and periodically acknowledge compliance with ITO's corporate values and ethics, code of conduct or equivalent policy. CMC–PSV5 Met

Learning, Innovation and Change Management
ITO has processes and practices to ensure change initiatives are properly implemented.

CMC–LICM2 Met
ITO has in place a formal approach to knowledge and talent management. CMC–LICM4 Met

Accountability
Authority, responsibility and accountability are clear and communicated.

CMC–AC1 Met
Employees formally acknowledge their understanding and acceptance of their accountability. CMC–AC2 Met
A clear and effective organizational structure is established and documented. CMC–AC3 Met
ITO's accountabilities in support of collaborative initiatives are formally defined. CMC–AC4 Met with exception

Stewardship
Appropriate and timely financial and non-financial reporting is communicated internally and externally.

CMC–ST20 Met
Objective 2: To determine the adequacy of the implementation of ITO's risk management practices.
ITO's documented approach to risk management strategies and processes has been implemented. CMC–RM Met with exception
Management appropriately communicates its risks and risk management strategies to key stakeholders. CMC–RM6 Met with exception

Appendix B: Management Action Plan

Project Name /
Number:

 SADI Governance Audit
space to insert number

 Updated As At:
space to insert date

Management Action Plan
Recommendation (Page/Section) Planned Action or Justification for No Action on the Recommendation Responsible Official Target Completion Date Revised Completion Date Current Status
Recommendation 1.0:
The Executive Director of ITO should introduce a periodic self-assessment for the various ITO committees to ensure their continued relevance.
The Executive Director shall review, on an annual basis at a minimum, the terms of reference of the various committees mentioned in this report to ensure their continued relevance and make changes as appropriate. This review will occur as part of the business planning cycle and changes will be recommended through the annual ITO Business Plan. Executive Director, ITO Immediate   Implemented
Recommendation 2.0:
The Executive Director of ITO and the Director General of Corporate Finance, Systems and Procurement Branch should finalize the documentation of their respective roles and responsibilities for SADI program repayment activities.
A Memorandum of Understanding (MOU) will be signed between ITO and Comptrollership and Administration Sector (CAS) outlining the respective roles and responsibilities of each organisation. Executive Director, ITO and Director General, Corporate Finance, Systems and Procurement Branch, CAS October 15, 2010    
Recommendation 3.0:
It is recommended, as a best practice, that the Executive Director of ITO consider the extent to which documentation should be maintained on exit interviews and discussions relating to personnel issues.
The Executive Director shall, on a case-by-case basis, consider the amount of documentation required to be maintained on exit interviews, taking into account the privacy rights and effect on candidness of the individual in question. Executive Director, ITO Immediate   Implemented
Recommendation 4.0:
The Executive Director of ITO should implement the risk monitoring template that includes the project monitoring plan. In addition, senior management should ensure that program-level risks are monitored and periodically updated.
1. A project monitoring plan will be implemented using a risk-based monitoring template supported by weekly advisory panel meetings to discuss specific project-related issues and mitigation plans. Director, Investments and Benefits Management, ITO Immediate   Implemented
2. Program-level risks will be periodically monitored and updated as part of the bi-monthly Risk Management Committee (RMC) meeting. Deputy Executive Director, ITO Immediate   Implemented

Figure 2.3.1 SADI Project Life Cycle Overview

Figure 2.3.1 describes the Strategic Aerospace and Defence Initiative project life cycle. The overview is divided into 3 phases. Phase 1 is the Application phase, activities include guiding the applicants, reviewing the application for completeness and eligibility, conducting due diligence, and walking the application through the departmental approval process. The Strategic Investment Analysis Directorate from Industrial Technologies Office is responsible for these tasks. Deliverables from this phase include the approved Strategic Aerospace and Defence Initiative project and signed Contribution Agreement. Phase 2 is the Work phase. During this phase, recipients conduct Research and Development, Industry Canada processes claims and amendment requests, disburses funds, monitor progress and conduct recipient audits. The Investment and Benefits Management Directorate from the Industrial Technologies Office is responsible for these tasks. Deliverables from this phase include amendments of Contribution Agreements and disbursement of funds. Phase 3 is the Benefit phase, were recipients accrue benefits and make repayments to Industry Canada in which they conduct recipient audits. Program and Policy Management manages this phase but both the Program and Policy Management and the Industrial Technologies Office have shared responsibility for tasks. Deliverables from this phase includes the Contribution Agreement amendment and repayment. The approval authority for Executive Director is less than $500,000, Assistant Deputy Minister, Science and Innovation Sector less than $1 Million, Deputy Minister less than $5 Million, Minister less than $10 Million, the Treasury Board Ministers for amount between $10– 20 Million, and the Cabinet and Treasury Board Ministers for amount greater than $20 Million.

Return to Figure 2.3.1

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Figure 2.3.2: ITO's Organization Structure

Figure 2.3.2 shows the Industrial Technologies Office's organization structure. At the very top, it is the Executive Director of Industrial Technologies Office, who is responsible to cooperate with the Program Policy and Management directorate. Program Policy and Management is considered an external group from Industrial Technologies Office that monitor projects in Benefit phase. The Deputy Executive Director and Executive Assistant report directly to the Executive Director. The Deputy Executive Director is responsible for the Director of Corporate & Management Services. There are six different functional directorates within Industrial Technologies Office who report directly to the Executive Director: Policy, Communications, Investment & Benefits analysis, Strategic Investment Analysis, Financial Investment analysis and program services.

Return to Figure 2.3.2

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Figure 3.2.1: Organizational Committees

Figure 3.2.1 shows the committees that are in place within Industrial Technologies Office and that provide guidance, direction and oversight for Strategic Aerospace and Defence Initiative. The various committees include Senior Management Committee, Business Transformation Team, Operations Management Meeting, Review Committee, Risk Management Committee, Operational Audit Committee and Employee Engagement Committee. Members are selected based on the needs of each committee.

Return to Figure 3.2.1

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