Management shall consistently apply the internal control standards to meet each of the internal control objectives and to assess internal control effectiveness.

WHITEHOUSE: OMB Circular A-123 - Management's Responsibility for Internal Control | The White House

In addition to these efforts, we are in the process of documenting and testing our internal control over financial reporting in order to report on the effectiveness of our internal controls as of December 31, 2012, as required following our initial public offering in 2011.

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When assessing the effectiveness of internal control over financial reporting and compliance with financial-related laws and regulations, management must follow the assessment process contained in Appendix A. Annually, management must provide assurances on internal control in its Performance and Accountability Report, including a separate assurance on internal control over financial reporting, along with a report on identified material weaknesses and corrective actions.

WHITEHOUSE: OMB Circular A-123 - Management's Responsibility for Internal Control | The White House