Companion Policy to National Instrument 52-109 Certification of Disclosure in Issuers' Annual and Interim Filings
Part 7 Evaluating Operating Effectiveness oOf DC&P and ICFR
Section 7.7

Certifying Officers’ Daily Interaction

The certifying officers’ daily interaction with their control systems provides them with opportunities to evaluate the operating effectiveness of the issuer’s DC&P and ICFR during a financial year. This daily interaction could provide an adequate basis for the certifying officers’ evaluation of DC&P or ICFR if the operation of controls, policies and procedures is centralized and involves a limited number of personnel. Reasonable support of such daily interaction would include memoranda, e-mails and instructions or directions from the certifying officers to other employees.