Corporate Governance Program

Memo

To: Edward Harrison, Chief Executive Officer

CC: Jason McMillin, Chief Financial Officer

From: Stephannie Spitaleri, Staff Accountant

Date: August 3, 2010

Subject: Proposal to Establish a Corporate Governance Program

In the pages that follow is my proposal to establish a Corporate Governance Program (CGP) for White Hat Management. Although White Hat Management is a privately held company, I believe the passing of the Sarbanes Oxley Act provides us with a great opportunity to incorporate its principles. By doing so, White Hat Management can improve internal controls, improve employee morale, and job accountability, as well as improve our public reputation.

There are many objectives to initiating a CGP. I feel the most important objective to this is to minimize risks. I believe our risk of fraudulent activity is lowered when strong internal controls are in place and employee accountability is held at the highest level.   As a state and federally funded business, we count on our student data records to fuel our revenue. Preventing fraud or errors in our student data records and staying in compliance with state agencies can increase our revenue and shorten the gap for receiving it. The CGP is a tool to head off any discovered risks before fraud occurs, a third party internal audit, or external audit is performed by a state or federal agency.

Our mission is to love, inspire and educate the children we come in contact with daily. Sometimes running “the business” gets in the way. It is my position that by implementing a CGP, much of our focus can move away from scrutiny of our business practices to developing more successful programs to help our students succeed. Moreover, opening the door to also focus our efforts to marketing and recruitment of students will positively affect our bottom line.

I believe we have the tools and expertise within our organization to make this initiative a reality. We need to leverage this expertise to... [continues]

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