Internal Controls

Internal controls are extremely important to our company. Kingdom Trust’s Compliance Officer is Tim Kuhman, who is responsible for knowing and understanding the rules and regulations that govern the operation of Kingdom Trust and insuring that the company’s policies and procedures are within the scope of the same. He also insures that the company’s administrative services agreements, and those of Kingdom Services, meet the requirements of all applicable laws. Tim ensures that all operating departments are working in compliance with the Company’s Policy and Procedures Manual. He also works with the Chief Operating Officer to amend and modify the Policy and Procedures Manual to accommodate changes to governing rules and regulations. The policies and procedures are reviewed in their entirety annually but may be amended more frequently as required.

Tim stays abreast of changes to the rules and regulations that govern Kingdom Trust’s business as well as tracks legislation that may impact that business. He works with members of the South Dakota Department of Revenue and Regulation, Division of Banking, and its auditors as the need arises.

He is also the General Counsel for Kingdom Trust and Kingdom Services. He monitors all claims and complaints against the company and maintains a complaint log. The complaint log tracks each complaint received and documents the steps taken to resolve said complaints. He serves as the company’s primary contact with its outside legal counsel and the company’s insurance carriers.

In both capacities, Tim prepares and presents a report to the company’s Board of Directors covering all legal and compliance issues as well as any changes to company policy requiring board approval. The report is presented quarterly unless circumstances require board input sooner.

Compliance Committee

The Kingdom Trust Board of Directors created a Compliance Committee charged with general oversight of the company’s compliance function. It consists of the Compliance Officer and three members of the Board. The committee reviews new policies and procedures as well as recommendations for modifications to existing policies and procedures. The committee reports its recommendations to the full board for discussion and approval on a quarterly basis unless circumstances require action by the board sooner.

Auditing

A member of the Board of Directors performs the internal audit function. The member reviews the company’s policies, procedures and operations and reports his or her findings to the board’s Audit Committee on a quarterly basis. At such time as deemed necessary, an internal auditor will be added to the company’s staff and assume the internal audit functions performed by the member of the board; this internal auditor will then report his or her findings to the board’s Audit Committee on a quarterly basis.

An annual independent external audit is performed annually by Certified Public Accountants auditing Kingdom Trust’s financial statements and evaluating the company’s internal controls and systems.

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