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Cornell University has a Financial Internal Controls Policy, which establishes the foundation for the university-wide internal control framework. The University’s internal control framework is dependent upon individual operating units which are characterized by separate and distinct sets of operational objectives and financial operations. These decentralized operations make it imperative that each operating unit develops, documents, and maintains an effective system of internal controls. The Financial Internal Controls Policy requires each operating unit to develop, implement, and maintain its own unit-specific internal control plan and take necessary measures to effectively monitor the effectiveness of the plan and respond accordingly to any control risks that are identified.

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