Audit of Targeted Geoscience Initiative 4 (AU1501)

TABLE OF CONTENTS

EXECUTIVE SUMMARY

INTRODUCTION

Over the past 30 years there has been a steady decline in proven and probable Canadian mineral reserves for all the major base metals. Deeper exploration for new resources is required, as a result of the increasing rarity of surface discoveries. The Targeted Geoscience Initiative Program (TGI) is designed to provide the mineral exploration industry with the next generation of geoscience knowledge and innovative techniques that will allow for more effective discovery of deeply buried mineral deposits.

The TGI Program is delivered by the Geological Survey of Canada Division (GSC) of the Earth Sciences Sector (ESS). It was first launched in 2000 as a three-year program with a goal of increasing the level and cost-effectiveness of private sector exploration for mineral resources and was subsequently renewed three times. The fourth program renewal (TGI-4) was approved for a five-year period beginning in 2010-11 at a total cost of $25,000,000 and is the focus of this audit.

The audit of TGI-4 was included in the Department’s Risk-Based Audit Plan, approved by the Deputy Minister on February 27, 2014.

The objective of the audit is to provide reasonable assurance on the overall adequacy and effectiveness of management controls supporting the operations of the TGI-4.

STRENGTHS

Roles, responsibilities and accountabilities are defined at the management level and the program is aligned with government and NRCan priorities. Furthermore, the Program has monitoring mechanisms in place to provide oversight of its activities and is participating in a department-wide initiative to create efficiency metrics for NRCan.

AREAS FOR IMPROVEMENT

The audit identified opportunities for improvement with regards to mitigating risk exposure related to potential for perceived conflict of interest (COI); information management; ensuring consistency in managing Grants and Contributions (G&C); and further strengthening compliance with NRCan’s Policy on Transfer Payments.

AUDIT CONCLUSION AND OPINION

In my opinion, overall the program is aligned with government and NRCan priorities and has governance and monitoring mechanisms in place to provide oversight. Opportunities exist to improve the adequacy and effectiveness of management controls in the areas of G&C’s and to improve mitigation measures related to conflict of interest.

STATEMENT OF CONFORMANCE

In my professional judgement as Chief Audit Executive, the audit conforms with the Internal Auditing Standards for the Government of Canada, as supported by the results of the Quality Assurance and Improvement Program.

Christian Asselin, CPA, CA, CMA, CFE
Chief Audit Executive

ACKNOWLEDGEMENTS

The audit team would like to thank those individuals who contributed to this project and, particularly employees who provided insights and comments as part of this audit.

INTRODUCTION

Over the past 30 years there has been a steady decline in proven and probable Canadian mineral reserves for all the major base metals. Deeper exploration for new resources is required, as a result of the increasing rarity of surface discoveries. The Targeted Geoscience Initiative Program (TGI) is designed to provide the mineral exploration industry with the next generation of geoscience knowledge and innovative techniques that will allow for more effective discovery of deeply buried mineral deposits.

The TGI Program is delivered by the Geological Survey of Canada Division (GSC) of the Earth Sciences Sector (ESS). It was first launched in 2000 as a three-year program with a goal of increasing the level and cost-effectiveness of private sector exploration for mineral resources and was subsequently renewed three times. The fourth program renewal (TGI-4) was approved for a five-year period beginning in 2010-11 and is the focus of this audit.

The total planned funding of TGI-4 from 2010-11 to 2014-15 is $25,000,000 Footnote1 with the significant majority of costs related to Operations and Maintenance (O&M) at approximately $19.9M, which consists mainly of travel expenses, laboratory and consulting services, rentals of machinery as well as purchase of utilities and supplies. Additional planned funding include Personnel at approximately $3.3M and G&C of $1.8M. 

TGI-4 carries out projects planned to leverage funding and gain maximum impact for the following Program objectives:

  • Providing industry with the next generation of geoscience knowledge and innovative techniques to better model and detect buried mineral deposits;
  • Reducing investment risk and cost through smarter targeting; and
  • Training and mentoring students in order to increase the number of highly qualified personnel available to the mineral industry.

Unlike earlier cycles of the TGI program, which focused on specific geographic areas, TGI-4 uses a thematic approach, defining projects in terms of mineral systems Footnote2 across the country. The Program is composed of seven ore body projects and one Methodology project that are based on partnerships with provinces, academia and the mineral industry that operate under the Intergovernmental Geoscience Accord.

Direct stakeholders in the TGI-4 Program include the following groups:

  • Provincial-Territorial Geological Surveys;
  • Industry;
  • Academia; and
  • Other stakeholders, including Aboriginal groups, mining communities and others in regions where deep exploration could yield expanded or new discoveries of commercial ore deposits.

The audit of the TGI-4 was included in the Department’s Risk-Based Audit Plan, approved by the Deputy Minister on February 27, 2014.

AUDIT PURPOSE AND OBJECTIVES

The objective of the audit was to provide reasonable assurance on the overall adequacy and effectiveness of management controls supporting the operations of the Targeted Geoscience Initiative - Phase 4. Specifically, the audit assessed:

  • Governance and accountability;
  • Program and project administration; and
  • Monitoring and oversight.

AUDIT CONSIDERATIONS

A risk-based approach was used in establishing the objectives, scope and approach for this audit engagement. A summary of the underlying risks that were identified during the audit includes:

  • Situations where a COI exists or is perceived to exist may have a negative impact on the Program’s reputation;
  • Information necessary for internal decision-making and reporting may not be available or provided to NRCan management in a timely manner;
  • A perception of a lack of fairness and transparency in distribution of G&C’s could have a negative impact on the Program’s reputation; and
  • Resources, processes and related control frameworks may not be in place to ensure the effective management of Program activities.

SCOPE

The scope of the audit covered key aspects of the management control framework including activities and payments between April 1st, 2011 to March 31st, 2014. The audit will also serve as a tool for ESS and NRCan management by providing observations on the on-going implementation of the new efficiency metrics related to TGI-4 as one of the pilot projects for NRCan.

In addition, NRCan’s Strategic Evaluation Division recently completed an evaluation of TGI-4, as part of their 2014-2018 Strategic Evaluation Plan. The Audit Branch has consulted with the Strategic Evaluation Division and excluded areas covered by the Evaluation to minimize duplication of efforts, wherever possible, between our two functions.

APPROACH AND METHODOLOGY

The approach and methodology followed the Internal Auditing Standards for the Government of Canada, which incorporates the Institute of Internal Auditors' International Standards for the Professional Practice of Internal Auditing. These standards require that the audit be planned and performed in such a way as to obtain reasonable assurance that audit objectives are achieved.

The audit included tests considered necessary to provide such assurance. Internal auditors performed the audit with independence and objectivity as defined by the Internal Auditing Standards for the Government of Canada.

The audit approach included the following key tasks:

  1. A review of relevant background documentation;
  2. Interviews with key corporate and Program personnel; and
  3. An examination of corporate and Program records and other supporting documentation.

CRITERIA

The criteria have been developed from the key controls set out in the Treasury Board of Canada’s Core Management Controls and relevant associated policies, procedures and directives. The criteria guided the fieldwork and formed the basis for the overall audit conclusion. Appendix A summarizes the detailed audit criteria.

FINDINGS AND RECOMMENDATIONS

GOVERNANCE AND ACCOUNTABILITY

Summary Finding

Overall, management roles, responsibilities and accountabilities are defined and the program is aligned with government and NRCan priorities. Opportunities for improvement exist with regards to mitigating risk exposure related to COI.

Supporting Observations

Alignment with Government Priorities

A critical component of effective governance surrounding a long standing program is to ensure that it remains consistent with the priorities of the Department and the Government of Canada as a whole. The TGI-4 program was first launched in 2000 as a three-year program with a goal of increasing the level and cost-effectiveness of private sector exploration for mineral resources and was subsequently renewed three times. Fourteen years later, in the midst of its fourth renewal, the audit was sought to assess whether the program remained aligned with NRCan’s priorities.

An Evaluation of the TGI-4 program was recently completed in October 2014. Consistent with the preliminary findings of the Evaluation, the audit also found that TGI-4 remained well aligned with both Government and NRCan objectives and priorities. Specifically, the program continues to support and collaborate with industry through its research program to find more efficient means to better detect mineral deposits.

In addition, the program’s objectives were also established and documented through a formal strategic planning activity that considers and aligns with the strategic objectives priorities of the Department and other relevant stakeholders.

Roles, Responsibilities and Accountabilities

Another critical component of governance is that roles, responsibilities and accountabilities of a given program are clearly established and communicated. This facilitates informed decision making, accountability for program funding and decisions, as well as compliance with relevant policies and legislation.

The audit found that overall the TGI-4 program has an established governance structure with defined management roles, responsibilities and accountabilities. In addition, the audit also noted that the Program had made efforts to separate project management duties from the actual scientific research portion of the program.

Conflict of Interest (COI)

Collaborative efforts with external stakeholders, such as industry and academia, are common for programs across the Department as the nature of scientific research will always require such partnerships. Such collaborative activities present inherent risks of real, apparent or potential conflict of interest. Within that context, NRCan employees involved in TGI-4 face such challenges regarding collaborative efforts through the G&C’s distributed by the program. While the audit did not identify any specific cases of wrongdoing with regards to the distribution of grants, there were several circumstances that appear to present potential conflict of interest situations. These include, for example, situations where NRCan scientists were also working as adjunct professors in academic institutions that received G&C funding from NRCan. Although they may have no influence on the distribution of Grants, these dual roles inherently present situations that could be perceived as a conflict of interest.

In circumstances where employees may have personal conflicts of interest they are required to take steps such as formally declaring those conflicts to their managers, whereas program managers should complete a G&C COI attestation to ensure that COI have been reviewed, addressed and properly documented. No such COI disclosures or risk assessment had been completed for the files reviewed.

It should be noted that although no disclosures or risk assessment had been completed, NRCan’s Values and Ethics Centre of Expertise (COE) has recently developed training and tools, such as the 2013 Employee Confidential Report. Within this context, the COE is in the process of rolling out related training across the Department to support staff in recognizing and documenting V&E issues including conflict of interest.

RISK AND IMPACT

Situations where a COI exists or is perceived to exist may have a negative impact on the Program and/or Department’s reputation, possibly impacting its ability to effectively manage stakeholder relationships and achievement of Program objectives.

RECOMMENDATIONS

1. It is recommended that the Assistant Deputy Minister-Earth Sciences Sector (ADM-ESS):

  1. Ensures that all future programs within the Sector document conflicts and put in place mitigation measures, in consultation with the Value & Ethics (V&E) Centre of Expertise, when required, and that the program manager completes Grants & Contributions Conflict of Interest (G&C COI) attestations; and
  2. Formally requests that the Natural Resources Canada’s (NRCan) Values and Ethics Centre of Expertise provides COI training to all employees involved in program activities at the earliest available date.

MANAGEMENT RESPONSE AND ACTION PLAN

Management agrees.

In response to recommendation 1, ESS has consulted with the Values & Ethics COE regarding potential future activities in targeted geoscience. In addition, ESS will work collaboratively with the NRCan Values & Ethics COE to further improve by March 31, 2015 the risk management of COI by:

  1. Maintaining a closer dialogue and consultation with the Values & Ethics COE and implementing the NRCan COI policy including G&C COI attestations.
  2. Ensuring that all ESS employees have completed or have on their learning plans (15/16 and ongoing for new employees) the training on COI provided by NRCan Values & Ethics COE.

Position responsible: Assistant Deputy Minister-Earth Sciences Sector (ADM-ESS)

PROGRAM MANAGEMENT

Summary Finding

With regards to the Program’s expenses, management has generally demonstrated compliance with relevant Treasury Board Secretariat (TBS) and NRCan policies. Opportunities for improvement exist with regards to ensuring adequate documentation to support program decisions.

Regarding the management of G&C, TGI-4 has a solicitation and communication approach, as well as an assessment process that provides a framework to support fairness and transparency in the selection process. The audit found; however, that these processes were not always applied in a consistent manner. Furthermore, the audit also found opportunities to ensure that expenditure initiations are consistently approved by the appropriate delegated authority; and, opportunities to improve compliance with the Policy on Transfer Payments, as well as establishing a comprehensive information management system for the management of Grants.

Supporting Observations

Program Funding - Context

The TGI-4 Program has total planned funding of $25M distributed over five fiscal years (2010-11 to 2014-15) of which approximately $23.2M is allocated towards salaries and operating expenses and $1.8M is allocated towards G&C’s.

Management of Program expenses

Management of Operating and Maintenance

The audit examined controls related to recording of financial transactions, appropriate financial delegated authorities and budgeting controls. Particular attention was paid to the O&M category since it represents a substantial component of total program funding.

With regards to the financial recording of O&M transactions (excluding travel), the audit expected that they would be recorded in the appropriate fiscal year, in accordance with the Public Sector Accounting Standards (PSAS). Overall, the audit noted that transactions reviewed were complete, accurate and recorded in the appropriate fiscal year. 

The audit also assessed whether financial transactions were approved in accordance with the Financial Administrative Act (FAA), particularly around exercising Section 32. The audit found that for the significant majority of transactions reviewed, Section 32 of the FAA was approved by the appropriate delegated authority.

For budgeting practices, the audit found that the TGI-4 Program has monitoring mechanisms in place to review the reasonability of the O&M expenses incurred. Specifically, the Program conducts a formal quarterly budget analysis, as part of the GSC Mid-Year and Year-End reviews. With that said, the audit noted that variances between the amounts initially budgeted and the amounts actually spent were not formally explained nor documented during these reviews.

Other similar issues were identified related to information being readily available to support management decisions.

Management of G&C

G&C represent $1.8M of the $25M allocated for the TGI-4 program. This funding is distributed to external proponents, predominantly academic institutions conducting relevant research projects. Although the amount represents less than 10% of the Program’s overall allocated funding, the management of these funds poses an inherent risk due to their transfer to external partner organizations.

Within this context, the audit sought to determine whether these funds were managed effectively to ensure a fair and transparent process to award G&C; as well as to confirm that the funds were managed in accordance with relevant NRCan and TBS policies.

Fairness and Transparency

In order to ensure that a process to distribute limited funds to multiple parties is conducted in a fair and transparent manner, each prospective proponent needs to be treated in a consistent manner. Consistency of rules and tools applied to all proponents needs to exist throughout the solicitation, submission, and assessment processes, as well as all other aspects of the G&C management process.

The audit found that the TGI-4 Program has communication strategies in place to invite proponents to submit proposals for funding, assessment tools to score and rank proposals submitted, and approval processes that provide a framework to support fairness and transparency in the selection process.

The audit noted; however, several inconsistencies in the application of these tools. Specifically, inconsistencies were found regarding communication with prospective proponents, proposal assessment methodologies and the approval process itself.

Regarding communication with prospective grant recipients, the audit found that the Program had received submissions for funding from proponents through both solicited and unsolicited communications. This could have led to a perception of preferential treatment, and it is recommended that measures be taken to avoid such optics in the future.

Inconsistencies were also found in the proposal assessment process. Specifically, TGI-4 management utilized different assessment mechanisms and tools to evaluate proposals. For example the website announcement for TGI-4 G&C contained the percentage of importance that would be attributed to each assessment criteria. Most of the files reviewed were assessed using a non-numerical evaluation, while one of the files reviewed included a numerical evaluation consistent with the information on website.

Compliance with NRCan’s Transfer Payment Policy

NRCan has a departmental policy on Transfer Payments to support Program compliance with related TBS policies and promote consistency in the management of G&C programs across the Department. NRCan maintains a Centre of Expertise (COE) on G&C to provide support and guidance for Program Managers across the department.

A fundamental difference between grants and contributions is that payments related to Contribution Agreements have conditions attached to them, while payments related to Grants do not normally have conditions. As such, grants require less administrative oversight for both the proponent and program in comparison to Contributions.

TGI-4 received $1.8M in transfer payments authority for fiscal years 2011-12 to 2014-15, in the form of Grants. The TGI-4 program utilized grants as the primary mechanism to distribute funding to proponents with the exception of one case where a contribution agreement of $40,000 was awarded. The audit noted; however, that payments related to the grant agreements were often conditional to the achievement of specific deliverables and milestones, requiring progress reports and financial reporting. These conditional requirements were requested to maintain oversight over the progress of Grant projects; however, conditional requirements related to payments are characteristics of Contribution Agreements rather than Grants. As a result, the Program may have been increasing the administrative burden on both itself, as well as recipients.

Regardless of whether grants or contributions were used, the audit sought to determine whether the Program complied with critical components of NRCan’s Policy on Transfer Payments (the NRCan Policy). These would include adequate oversight for Grants with values exceeding $100,000; effective segregation of duties between reviewing proposals and signing agreements; and comprehensive documentation of critical information supporting decision making.

With regards to oversight, the NRCan Policy requires that agreements in the amount of $100,000 or more are to be sent to Legal Services and the COE on G&C for formal review. Although the TGI-4 Program did not have a single Grant Agreement exceeding $100,000 in any given year, the audit noted that several proponents received Grants which were renewed in a subsequent year, therefore exceeding the limit.

The Policy also requires that there must be segregation of approval duties between the review of an application/proposal and the approval/signing of a Funding Agreement. However, the audit noted that for 4 out of the 7 Grant Agreements reviewed, the Program Manager signed off on both the grant agreements after they had also been involved in the assessment review process of the grants proposals. In addition, the audit noted that for 3 out of the 7 Grants reviewed, authorization was not provided by the appropriate delegated authority in accordance with Section 32 of the FAA.

Overall, the audit noted significant issues with the availability of documentation related to the Grants. The audit expected to find that critical information related to the management of Grants would be well documented and readily available. The audit found; however, that such information was often not always readily available. For example, documented rationale for rejecting or accepting project proposals was not available in Grant files. Management was able to eventually retrieve this information by searching individual mailboxes of TGI-4 employees. Similarly, there were often significant delays in management’s ability to retrieve other information related to Grant files.

Management had advised us that a significant majority of the information related to G&C issued by the Program was in hard copy format and not stored electronically. These circumstances, compounded by information being kept on personal drives and/or mailboxes, create challenges to locate and provide information in a timely manner.

It should be noted that NRCan is currently in the process of implementing GCDOCS as a new comprehensive information management solution for the Department. If the new system is used effectively, it could significantly improve the management of information across the Department, including maintaining adequate files and related documentation for Program’s such as TGI4.

RISK AND IMPACT

Inconsistencies in the approach taken to communicate with stakeholders and/or assess project proposals could be perceived as preferential treatment, particularly by proponent’s whose proposals were rejected, potentially impacting both the Program and Department’s reputation.

A lack on controls to ensure compliance with relevant policies and the lack of readily available information to support decisions to issue Grants could also have a negative impact on the effective management of the program.

RECOMMENDATIONS

2. It is recommended that the Director General Geological Survey of Canada Division (GSC) of the Earth Sciences Sector (ESS) (GSC-ESS) ensures that for all future Grants & Contributions (G&C) programs a consistent approach is used to communicate with proponents and assess project proposals.

3. It is recommended that the Director General GSC-ESS ensures that formal advice for future program funding is sought from the COE on G&C to ensure compliance with the Policy on Transfer Payments.

4. It is recommended that the Assistant Deputy Minister-Earth Sciences Sector (ADM-ESS) ensures that a standard electronic folder structure is established and implemented using GCDOCS to manage all program information in a comprehensive and consistent manner for all future G&C Programs within the Sector.

MANAGEMENT RESPONSE AND ACTION PLAN

Management agrees.

In response to recommendation 2, ESS has already modified its G&C processes for the second phase of the Geo-Mapping for Energy program (GEM) to ensure more comprehensive communications with potential recipients and the assessment of proposals and Targeted Geoscience Initiative Program (TGI) moving forward will follow the same process. ESS will continue to work  in collaboration with the Transfer Payment COE to further develop and implement by March 31, 2015 procedures that will ensure a robust and transparent G&C process that includes:

  1. Communicating and soliciting potential funding recipients;
  2. assessing project proposals to determine whether funding is granted; and
  3. ensuring that an overall assessment and comparative analysis of all proposals received is completed and documented to demonstrate rationale for project selection.

Management agrees.

In response to recommendation 3, ESS has sought formal advice from the Natural Resources Canada (NRCan) Transfer Payment COE and Review Committee throughout the program cycle regarding potential future G&C allocations.

ESS will continue to work with the Centre of Expertise (COE) of G&C and legal services to ensure that management decisions are aligned with updated NRCan transfer payment policies.

Management agrees.

In response to recommendation 4, ESS has initiated the implementation and use for TGI-4 of GCDOCS as it was launched in September 2014 and will:

Complete the archiving of business value documents for TGI-4 in GCDOCS by March 31, 2015 and implement the developed best practice for future activities.

Position responsible: Director General Geological Survey of Canada Division (GSC)-Central and Northern Canada Branch (CNCB)

MONITORING AND PERFORMANCE MEASUREMENT

Summary Finding

Overall the Program has monitoring mechanisms in place to provide oversight of its activities. In addition, it is participating in a department-wide project to create efficiency metrics for NRCan.

Supporting Observations

The audit found that the TGI-4 Program has monitoring mechanisms in place to regularly review and monitor program expenditures. For instance, Program Managers conduct weekly meetings with Project Managers to discuss the status of ongoing projects and related budgets.

In addition, the audit noted that the GSC has a middle management committee where table discussions often occur regarding programs across the Division. Examples of topics discussed include sharing of best practices and opportunities for collaboration between programs. Specific to TGI-4, the audit noted that it shared lessons learned. For instance, the Program developed a standard process to coordinate and standardize processes when communicating with specific stakeholders. This process was shared with GSC counterparts and is now being implemented by other programs in the Division. Similarly, the audit noted that Sector-wide mechanisms were also in place to share best practices and lesson’s learned.

With regards to performance measurement, the Program is currently participating in a department-wide pilot regarding the implementation of efficiency metrics. The Treasury Board Secretariat recently introduced new requirements for departments to implement program efficiency measures for all of their programs. In response, NRCan has worked towards the development of meaningful and consistent measures, including requiring each sub-program, such as TGI-4, to establish and track information against one measure of the cost per output. Collectively, these measures aim to provide “big picture” efficiency metrics for the Department as a whole.

Specific to TGI-4, the program has established a pilot metric to measure the ‘cost per knowledge product’. The program has provided the audit team with their pilot, which was used to test the metric for appropriateness. This piloted metric was established by management in order to determine whether the basis for calculation is sound and the data required for measurement will be available and accessible by the end of the year. After reviewing the metric, the audit team concluded that key costs were reflected in the metric and provided management with minor observations for their consideration.

Management has advised the audit team that they are currently in the process of collecting the necessary information required, and are confident that information required to meet their obligations will be readily available by the end of the year.

APPENDIX A – AUDIT CRITERIA

The criteria have been developed from the key controls set out in the Treasury Board of Canada’s Core Management Controls, Management Accountability Framework and relevant associated policies, procedures and directives.

The objective of the audit is to provide reasonable assurance on the overall adequacy and effectiveness of management controls supporting the operations of the Targeted Geoscience Initiative - Phase 4.

The following audit criteria were used to conduct the audit:

Audit Sub-Objectives Audit Criteria
Sub-Objective 1: The TGI-4 Program has in place effective governance and accountability framework. 1.1 It is expected that the Program objectives, activities and resources are aligned with Departmental objectives and strategic priorities.
1.2 It is expected that the Program has clearly set and communicated authority, responsibility and accountability to ensure the Program is applied and delivered consistently.
Sub-Objective 2: The Program communicates with its proponents and selects projects in a fair, transparent and timely manner. 2.1 It is expected that the Program provides for a fair and transparent process for the systematic and timely selection of projects/partners.
2.2 It is expected that effective mechanisms are in place to ensure that departmental Values and Ethics requirements related to the completion of Conflict of Interest disclosures are met.

Sub-Objective 3: The Program exercises risk-based control, monitoring and oversight of its activities.

3.1 It is expected that the Program has implemented effective risk-based controls over its activities, to ensure timely, accurate and complete financial information.
3.2 It is expected that the Program has established appropriate monitoring and reporting processes in place to support Program review and performance measurement, including the new efficiency metrics.
3.3 It is expected that there is a process for sharing best practices and lessons learned with other relevant programs within the Sector.

APPENDIX B – TGI-4 FUNDING

The total cost of TGI-4 over 5 years from 2010-11 to 2014-15 is $25,000,000, as detailed below Footnote3 :

 

2010-11

2011-12

2012-13

2013-14

2014-15

TOTAL

Personnel

$160,000

$625,000

$643,750

$663,062

$682,955

$2,774,767

EBP @ 20%

$32,000

$125,000

$128,750

$132,613

$136,591

$554,954

O&M

$3,308,000

$6,750,000

$5,227,500

$3,504,325

$1,080,454

$19,870,279

Total Vote 1 (O&M)

$3,500,000

$7,500,000

$6,000,000

$4,300,000

$1,900,000

$23,200,000

Vote 10
(G&C)

-

$500,000

$500,000

$500,000

$300,000

$1,800,000

TOTAL FUNDING

$3,500,000

$8,000,000

$6,500,000

$4,800,000

$2,200,000

$25,000,000