Companion Policy to National Instrument 52-109 Certification of Disclosure in Issuers' Annual and Interim Filings
Part 6 Design of DC&P and ICFR
Section 6.14

Efficiency and Effectiveness

In addition to the considerations set out in this Part that will assist certifying officers in appropriately designing DC&P and ICFR, other steps that certifying officers could take to enhance the efficiency and effectiveness of the designs are:

(a) embedding DC&P and ICFR in the issuer’s business processes;

(b) implementing consistent policies and procedures and issuer-wide programs at all locations and business units;

(c) including processes to ensure that DC&P and ICFR are modified to adapt to any changes in business environment; and

(d) including procedures for reporting immediately to the appropriate levels of management any identified issues with DC&P and ICFR together with details of any action being undertaken or proposed to be undertaken to address such issues.