Agenda packet — Compton City Council, February 6, 2024 (part 2 of 2)

2 ADOPTED this ____________ day of _____________, 2024. ____________________________________

MAYOR OF THE CITY OF COMPTON
ATTEST:
________________________________

CLERK OF THE CITY OF COMPTON

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss

CITY OF COMPTON )
I, Vernell McDaniel, City Clerk of the City of Compton, hereby certify that the foregoing Resolution was adopted by the City Council of the City of Compton, signed by the Mayor and attested by the City Clerk at a regular meeting thereof held on this ___________ day of ________________, 2024.

That said Resolution was adopted by the following vote, to wit:

AYES: COUNCILMEMBERS -
NOES: COUNCILMEMBERS -
ABSTAIN: COUNCILMEMBERS -
ABSENT: COUNCILMEMBERS -
________________________________________

CITY CLERK OF THE CITY OF COMPTON
February 6, 2024
TO: HONORABLE MAYOR AND COUNCIL MEMBERS
FROM: CITY CONTROLLER
SUBJECT: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

COMPTON AUTHORIZING THE CITY MANAGER TO ENTER
INTO A FIVE (5) YEAR AGREEMENT WITH AND ESTABLISH A

PURCHASE ORDER FOR ETHICO LLC TO PROVIDE FRAUD
HOTLINE SERVICES TO THE CITY OF COMPTON ($16,285.00)

SUMMARY
Adoption of this resolution will authorize the City Manager to enter into a five (5) year agreement with and establish a purchase order for Ethico LLC to provide Fraud Hotline services to the City of Compton in an amount not to exceed SixteenThousand, Two-Hundred Eighty-Five Dollars ($16,285.00).

BACKGROUND
The State Controller’s audit report of March 2018 for the City of Compton found that there was an embezzlement that occurred from May 2010 through December 2016, which totaled $3.72 million. This embezzlement was not timely detected nor reported. Finding number 2019-009 in the City’s Single Audit Report for the FiscalYear 2018-2019 further stated that “An embezzlement of $3.72 million remained undetected for years, and was only discovered in 2016”. This aforementioned Single Audit Report is available on the City’s website.

Further, the aforementioned Single Audit report made the following recommendations within the following finding numbers:
#2014-101B: Risk Identification (SD)
Recommendation: We recommend that the City put mechanisms in place to aid in anticipating, identifying, and reacting to routine events that affect the achievement of objectives.
#2014-122B – Communication (BP)
Recommendation: We recommend that the City has forms and means of communication in place to be able to communicate important information with employees and others.

Staff Report – Resolution re Ethico
Fraud Hotline Services
February 6, 2024, Page 2
#2014-136B – Report Deficiencies (SD)
Recommendation: We recommend that issues and deficiencies are directly communicated to the Responsible Person and elevated to someone at least a level higher.

Lastly, it should be noted that The Association of Certified Fraud Examiners (ACFE) in a “Report to the Nations” in 2018 on Global Occupational Fraud and Abuse stated that “Fraud in general poses a tremendous threat to organizations of all types and sizes, in all parts of the world”. They advised that proactive measures such as fraud hotlines are vital in catching frauds and abuses early, which can help to limit losses. [Source: 2018 ACFE Fraud Report to the Nations].

STATEMENT OF THE ISSUE
In order to remove obstacles to lines of communication (that may contribute to the risk of fraud within the City), a fraud-hotline-service is being recommended by City staff, the City’s Audit Committee, and by the City’s auditor (Eadie and Payne) in order to take an important measure to prevent and detect the risk of fraud.

The City’s Audit Committee (which is made up of two Councilmembers, one appointed resident, the City Manager, the City Controller, and the Internal Auditor as authorized by Resolution number 25,220) solicited quotes from three (3) professional Fraud Hotline service providers. Three companies (who were actively providing services to other local governments) were contacted by the Controller’s department staff: (i) Navex Global Inc.; (ii) Lighthouse/Syntrio Services; (iii) and Ethico LLC. These firms were invited for presentation and interview and each were asked to provide a list of references. Thereafter, members of the Audit Committee rated the candidates based on their presentation and the candidates’ submitted responses to the invitation. The candidate list and the proposed cost of services are stated below:

Service Provider Amount
NAVEX $7,300
ETHICO $3,257
SYNTRIO $2,100
The rating was based on the following criteria:

1. Company Background and General Qualification.

2. Technical Expertise and Knowledge of the Service.

3. Previous Experience with Services Similar in Scope.

4. Completeness and Accuracy of the Proposal.

5. Service Delivery Approach.

6. Cost of Services.

7. References.

Staff Report – Resolution re Ethico
Fraud Hotline Services
February 6, 2024, Page 3
The ranking scores out of 100 points are as follows:
 Navex 70 points
 Lighthouse Syntrio 90 points
 Ethico LLC 92 points
The ratings were tallied and Ethico LLC received the highest rating by the City’s Audit Committee. The audit committee was convinced that based on the candidate presentations and a review of the submitted candidate responses, Ethico had the best technical expertise and experience to meet the needs for the City of Compton.

Section 4-11.5 of the Compton Municipal Code states:
“In addition to price, in determining the lowest responsible bidder, consideration shall be given to the quality and performance of the supplies to be purchased or services by the vendor. The criteria for determining the low bid shall include, but not be limited to the following:

1. The ability, capacity, and skill of the bidder to perform the contract or provide the supplies or services required.

2. The ability of the bidder to provide the supplies or services promptly, or within the time specified, without delay or interference.

3. The character, integrity, reputation, judgment, experience, and efficiency of the bidder.

4. The quality of the bidder's performance on previous purchases or contracts with the City.

5. The ability of the bidder to provide future maintenance, repair parts, and services for the use of the supplies or equipment purchased.

6. Current compliance by the bidder with federal acts and executive orders and state statutes governing the subject of nondiscrimination in employment; provided, however, the City Manager shall recognize as proof of noncompliance only the final decisions and orders of those federal and state agencies empowered under the law to make such findings.

7. Certification by the bidder that the bidder shall pursue an affirmative course of action as required by the affirmative action guidelines adopted by the City Council reasonably pertaining to the work of the contract and to the nature and size of the bidder's work force to ensure that applicants are sought and employed, and that employees are treated during employment, without regard to their race, color, national origin or ancestry, or religion.

Such specific guidelines will be adopted by Council resolution from time to time, identifying the nature and scope of the affirmative action desired by the City. Such guidelines shall be made available to all persons desiring to bid on City business.

8. Each bidder shall enclose with its bid a certificate stating whether the bidder is currently in compliance with all federal and state laws covering nondiscrimination in employment, and that the bidder will pursue an affirmative course of action as required by the affirmative action guidelines Staff Report – Resolution re Ethico
Fraud Hotline Services
February 6, 2024, Page 4
provided for in Subsection a6 above of this section, and resolutions adopted pursuant thereto, and that, if awarded the contract, it will not discriminate in the employment of any person under the contract because of the race, color, national origin or ancestry, or religion of such person, and that the bidder will participate, if requested, in a pre-award review of his/her/its qualifications under the provisions of this section.

Ethico was chosen as the front runner of the solicitation based on the tallies described above, athough Ethico did not present the lowest bid. As previously mentioned their rating resulted in their selection.

Staff is requesting that the City Council authorize the City Manager to execute a contract between City of Compton and Ethico LLC for a period of Five (5) years at a total cost of Sixteen-Thousand Two-Hundred Eighty-Five dollars ($16,285.00).

FISCAL IMPACT
The amount for this service is Sixteen-Thousand Two-Hundred Eighty-Five dollars ($16,285.00) for the five (5) year contract. This amount is appropriated in the City Controller’s office budget for the Fiscal-Year 2023-2024 in account number 1001- 650-000-4266. (General Fund – Contract Services)
The five-year contract will be payable and a purchase order is being requested to be opened as follows:

Fiscal Year Account Code Account Name Amount
2024 1001-650-000-4266 Contract Services $3,257
2025 1001-650-000-4266 Contract Services $3,257
2026 1001-650-000-4266 Contract Services $3,257
2027 1001-650-000-4266 Contract Services $3,257
2028 1001-650-000-4266 Contract Services $3,257

ALTERNATIVE
Alternatively, if the resolution is not adopted and the City continues without anonymous access for employees to report instances of fraud and/or misappropriation of City assets, the risk of embezzlement or fraud may occur or may go undetected. Moreover, some employees may not be comfortable with reporting such matters to their supervisor or manager, unless there is an avenue of anonymity.

Staff Report – Resolution re Ethico
Fraud Hotline Services
February 6, 2024, Page 5

RECOMMENDATION
Staff recommends that the City Council adopt the attached Resolution

SHARON RAHBAN NAVIZADEH

CITY CONTROLLER
APPROVED FOR FORWARDING:

WILLIE A. HOPKINS, JR.

CITY MANAGER
Fraud Hotline Presentation Rating
$19,780.21 $2,100 $3,257
NAVEX

LIGHTHOUSE/S
YNTRIO
ETHICO
LLC
Stephanie Smith
Company Background and General Qualification 20 20 20 20 Technical Expertise and Knowledge of the Firm 20 20 20 20 Previous Experience with Services Similar in Scope 15 10 15 15 Completeness and Accuracy of Proposal 15 15 15 15
Service Delivery Approach 15 15 15 15
Cost of Services 5 5 5 5
References: Minimum of three 10 0 10 10
100 85 100 100
Council Woman Lillie Darden
Company Background and General Qualification 20 16 19 18 Technical Expertise and Knowledge of the Firm 20 15 18 17 Previous Experience with Services Similar in Scope 15 10 13 14 Completeness and Accuracy of Proposal 15 13 15 13
Service Delivery Approach 15 12 15 12
Cost of Services 5 3 5 5

Page 1 ends

References: Minimum of three 10 9 10 8
100 78 95 87
Austin Okonta
Company Background and General Qualification 20 17 18 20 Technical Expertise and Knowledge of the Firm 20 16 17 20 Previous Experience with Services Similar in Scope 15 12 13 15 Completeness and Accuracy of Proposal 15 13 14 15
Service Delivery Approach 15 13 13 15
Cost of Services 5 2 5 5
References: Minimum of three 10 0 10 10
100 73 90 100
Sharon Rahban
Company Background and General Qualification 20 20 20 20 Technical Expertise and Knowledge of the Firm 20 20 20 20 Previous Experience with Services Similar in Scope 15 0 15 12 Completeness and Accuracy of Proposal 15 10 10 10
Service Delivery Approach 15 15 10 15
Cost of Services 5 5 5 5
References: Minimum of three 10 0 10 10

Page 2 ends

100 70 90 92
Total Points 400 306 375 379
Percentage Achieved: 77% 95% 96%
Overall Ranking 3 2 1

Page 3 ends

February 6, 2024
TO: HONORABLE MAYOR AND COUNCIL MEMBERS
FROM: CITY CLERK
SUBJECT: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COMPTON

AUTHORIZING THE CITY MANAGER TO ENTER INTO AN

AGREEMENT AND ESTABLISH A PURCHASE ORDER FOR ALL STAR

SUMMARY
Adoption of this Resolution will authorize the City Manager to enter into a twelve (12) month agreement (i.e. July 1, 2023 through June 30, 2024) with All Star Interpreting Service (“All Star”) to provide Spanish language translation and interpretation services for the public meetings of the City’s legislative bodies for Fiscal Year 2023-2024 and establish a purchase order in the amount of Thirty Five Thousand Dollars ($35,000).

BACKGROUND
The City Council conducts much of the City’s business during its weekly public and televised meetings in the English language. A substantial portion of the City’s population is Spanish speaking and the City believes that it is important for all residents of the City to understand and participate in the governance of the City, thus the need to provide interpretation and translation services for City Council meetings and other community meetings. The City conducts public meetings of its legislative bodies up to four (4) times monthly.

STATEMENT OF ISSUE
The Clerk’s Office does not have staff to perform the professional services needed to provide professional, certified language translation and interpretation services for the various City’s legislative bodies. Thus, informal proposals were sought and received from four (4) firms; to wit:

All Star Interpreting Service - $750.00 flat rate per meeting Bilingual Services International - $595.00 times 2 Interpreters (required) up to 3 hours, $195.00 per each additional hour per interpreter

5. Staff Report – Resolution Authorizing Contract for
Spanish Language Translation Services for Legislative Bodies All Star Interpreting Service FY 2023-2024
February 6, 2024, Page 2
Medrano Interpreting - 1600.00 times 2 Interpreters (required) up to 6 hours for a total of $3200.00 per meeting.

Reliable Translation Inc. - $228.00 times 2 Interpreters (required) up to 2 hours, (additional cost {NOT SPECIFIED} per every 15 minutes, and mileage) Proposals received were evaluated on experience, professionalism, knowledge, etc.

While each of the firms seemingly were qualified to adequately perform the tasks needed, All Star Interpreting Service proposed fees were most competitive and reasonable.

Additionally, the City has previously contracted with All Star Interpreting Service and has found their services reliable and very satisfactory.

All Star has been providing translation and interpreting service for over twenty-nine (29) years. All Star is a member of the American Translators Association, State and Federally Certified Interpreters and provide services for virtually every language.

All Star will provide professional Spanish language interpretation and translation services for all of the public meetings of the City’s legislative bodies (i.e. City Council, Public Finance Authority, Urban Community Development Commission and Successor Agency), including regular, special and emergency meetings, which includes translation for the City’s cable telecast of the aforementioned meetings. The contract with All Star will be for one (1) year (July 1, 2023 through June 30, 2024). The costs of services will remain at the rate of Seven Hundred Dollars ($750.00) per date of services rendered for the entire term of the agreement.

FISCAL IMPACT
The costs for services for Fiscal Year 2023-2024 is estimated at Thirty Five Thousand Dollars ($35,000.00). Funds for this expenditure are available in:

RECOMMENDATION
Staff recommends that Council approve the attached Resolution.

Staff Report – Resolution Authorizing Contract for
Spanish Language Translation Services for Legislative Bodies All Star Interpreting Service FY 2023-2024
February 6, 2024, Page 3

VERNELL MCDANIEL

CITY CLERK
APPROVED FOR FORWARDING:

WIILIE HOPKINS JR.

CITY MANAGER
RESOLUTION NO. ________________

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COMPTON

AUTHORIZING THE CITY MANAGER TO ENTER INTO AN

AGREEMENT AND ESTABLISH A PURCHASE ORDER FOR ALL STAR

INTERPRETING SERVICE FOR PROVISION OF SPANISH LANGUAGE
INTERPRETATION AND TRANSLATION SERVICES FOR CITY’S
LEGISLATIVE BODIES FOR FISCAL YEAR 2023-2024 IN THE AMOUNT OF THIRTY-FIVE THOUSAND DOLLARS ($35,000)
WHEREAS, the City Council conducts much of the City’s business during its weekly public and televised meetings in the English language; and WHEREAS, a substantial portion of the City’s population is Spanish speaking and the City believes that it is important for all residents of the City to understand and participate in the governance of the City, thus the need to provide interpretation and translation services for City Council meetings and other community meetings; and WHEREAS, informal quotes were sought from vendors that provide Spanish translation services; and
WHEREAS, there were only four (4) quotes received:

All Star Interpreting Service - $750.00 flat rate per meeting Bilingual Services International - $595.00 per interpreter (2 required) Medrano Interpreting - $1600.00 per interpreter (2 required) Reliable Translations Inc. - $228.00 per interpreter (2 required) WHEREAS, the existing contract has expired; thus, it is requested that the City Manager is authorized to enter into a contract for a period of 12-months (i.e. July 1, 2023, through June 30, 2024); and
WHEREAS, All Star Interpreting Service (“All Star”) has been providing translation and interpreting service for over twenty-eight (28) years and is a member of the American Translators Association, State and Federally Certified Interpreters and provide services for virtually every language; and
WHEREAS, All Star will provide professional Spanish language interpretation and translation services for all of the public meetings of the City’s legislative bodies (i.e. City Council, Public Finance Authority, Urban Community Development Commission and Successor Agency), including regular, special and emergency meetings, which includes translation for the City’s cable telecast of the aforementioned meetings; and WHEREAS, the contract with All Star will be for a term of one (1) year (July 1, 2023 through June 30, 2024) at a cost not to exceed Thirty Five Thousand Dollars ($35,000.00); and
WHEREAS, funds for this expenditure are available in the following account numbers of the 2023-2024 Fiscal Year Budget:

Resolution No. ________________

Page 2 ends

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF COMPTON DOES HEREBY RESOLVE:

Section 1. That the City Manager, upon the advice and approval of the City Attorney is authorized to enter into a twelve (12) month (i.e. July 1, 2023 through June 30, 2024) agreement with All Star Interpreting Service to provide “as-needed” professional Spanish language interpretation and translation services for all of the public meetings of the City’s legislative bodies (i.e. City Council, Public Finance Authority, Urban Community Development Commission and Successor Agency), including regular, special and emergency meetings and translation for the City’s cable telecast of the aforementioned meetings in an amount not-to-exceed $35,000.00.

Section 2. That a purchase order in the amount of Thirty Five Thousand Dollars ($35,000.00) is authorized to be established for All Star Interpreting Service from the following account numbers:

Account No. Account Name Amount
1001-470-000-4262 General Fund, City Clerk $34,000
Dept, Contractual Services Account
1201-910-000-4269 Successor Agency Fund, Other $1,000
Contractual Services Account _
$35,000
Section 3. That funds for this expenditure are available in the 2023-2024 Fiscal Year budget in the following account numbers:

Account No. Account Name Amount
1001-470-000-4262 General Fund, City Clerk $34,000
Dept, Contractual Services Account
1201-910-000-4269 Successor Agency Fund, Other $1,000
Contractual Services Account _
$35,000
Section 4. That a certified copy of this Resolution shall be filed in the offices of the City Manager, City Clerk, City Controller, and City Attorney.

Section 5. That the Mayor shall sign and the City Clerk shall attest to the adoption of this Resolution.

ADOPTED this __________ day of ________________, 2024.
________________________________

MAYOR OF THE CITY OF COMPTON
ATTEST:
____________________________________

CITY CLERK OF THE CITY OF COMPTON

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss

Page 2 ends

the Mayor, and attested by the City Clerk at a regular meeting thereof held on the ________ day of __________________, 2024.

That said Resolution was adopted by the following vote, to wit:

AYES: COUNCIL MEMBERSNOES: COUNCIL MEMBERSABSTAIN: COUNCIL MEMBERSABSENT: COUNCIL MEMBERS- ____________________________________

CITY CLERK OF THE CITY OF COMPTON

INTERPRETATION AND TRANSLATION SERVICES AGREEMENT

BETWEEN

THE CITY OF COMPTON
AND

ALL STAR INTERPRETING SERVICE
This AGREEMENT is made by and between the CITY OF COMPTON, a municipal corporation of the State of California (hereinafter referred to as “CITY”) located at 205 South Willowbrook Avenue, Compton, California 90220, and ALL STAR INTERPRETING SERVICE (hereinafter referred to as “ALL STAR”), located at 1925 Vassar Avenue, Glendale, California 91204.

RECITALS:

WHEREAS, the City Council conducts much of the City’s business during its weekly public and televised meetings in the English language; and
WHEREAS, a substantial portion of the City’s population is Spanish speaking; and WHEREAS, the City believes that it is important for all residents of the City to understand and participate in the governance of the City, thus the need to provide interpretation and translation services for City Council meetings and other community meetings; and WHEREAS, All Star warrants that it is specifically trained, experienced, competent, and has the resources to provide such services which will be required by this Agreement; and WHEREAS, by Resolution No. ___________, adopted on the _____ day of _________, 2024, the City Council authorized the City Manager to enter into an agreement with All Star to provide interpretation and translation services to the City; and WHEREAS, All Star is willing to render such professional services, as hereinafter defined, on the following terms and conditions.

NOW, THEREFORE, All Star and City, for the consideration, terms and conditions herein described, mutually agree as follows:

AGREEMENT:

1. Services to be rendered by All Star. It is the mutual understanding of the parties that the All Star shall perform and be responsible for providing professional Spanish language interpretation and translation services for all of the public meetings of the City’s legislative bodies (i.e. City Council, Public Finance Authority, Urban Community Development Commission and Successor Agency), including regular, special and emergency meetings, which includes translation for the City’s cable telecast of the aforementioned meeting. All Star shall be available for performance of services at the aforementioned public meetings of the City’s legislative bodies commencing at 5:30 p.m. on any Tuesday that a meeting(s) is scheduled, unless directed otherwise by the City Clerk’s Office. For special and emergency meetings of the aforementioned legislative bodies, All Star shall be available upon twenty-four (24) hours advance notice of the date and time.

All Star acknowledges that in entering into this Agreement the City is relying on All Star's special skills and experience to do and perform the services in accordance with best standards of professional practice. While performing the services, All Star agrees to perform all the said work and furnish all the necessary materials at its own cost and expense necessary to complete said services in a manner consistent with that degree of care and skill ordinarily exercised by Spanish Translation/Interpretation – All Star Interpreting Service (City Clerk) FY 2023-2024
Resolution No. ___________
2 members of the same profession currently practicing under similar circumstances and to the reasonable satisfaction of the City.

All Star services hereunder shall be performed in good, workmanlike and professional manner. All Star shall be responsible for correcting and completing all errors and omissions related to the services provided by the All Star for this Agreement at no additional cost to the City. “Errors” and “Omissions” for purposes of this paragraph are defined to mean a failure by the All Star to meet the standards of its profession as set forth in the preceding paragraph. The acceptance of the services by City does not release All Star from these obligations.

All Star will be responsible for employing or engaging all persons necessary to perform the services. All of All Star's staff will be qualified by training and experience to perform their assigned tasks. All Star will give its personal attention to the fulfillment of the provisions of this Agreement by all of its employees and subcontractor, if any, and will keep the services under its control. On demand of City, if any employee or subcontractor of All Star fails or refuses to carry out the provisions of this Agreement or appears to be incompetent or to act in a disorderly or improper manner, he or she will be discharged immediately from the services.

Acceptance by City of the work performed under this Agreement does not operate as a release of said All Star from such professional responsibility for the services performed.

2. Duration of Contract. The term of this Agreement shall be for the period of July 1, 2023 through June 30, 2024, unless this Agreement is terminated as provided herein.

3. Compensation. The method of payment for this Contract will be on a flat feefor-services basis. Interpreter labor shall be assumed to be for a full day event at a cost of Seven Hundred Dollars ($750.00). The total price paid All Star will include compensation for all work, including travel, materials, supplies, vendor services, expenses and subcontracted work. No additional compensation will be paid to the All Star, unless there is a change in the scope of the work or the scope of the project. In the instance of a change in the scope of work or scope of the project, adjustment to the total compensation will be negotiated between the All Star and the City.

Adjustment in the total compensation will not be effective until authorized and approved by written contract amendment.

Progress payments may be made in arrears based on the percentage of work and deliverables completed by the All Star. If All Star fails to submit the required deliverable items according to schedule, unless the failure is through no fault of the All Star or the schedule is altered/extended by the City, the City shall have the right to delay payment and/or terminate this Agreement in accordance with the provisions noted herein.

All Star shall be reimbursed within thirty (30) days, or as promptly as fiscal procedures may permit, upon receipt by the City of itemized invoices for services completed. Invoices shall be submitted no later than 45 calendar days after the performance of work for which the All Star is billing. Invoices shall detail the work performed on each task as applicable. Invoices shall be mailed or delivered to the City Clerk at the following address: City of Compton, 205 South Willowbrook Avenue, Compton, California 90220.

All Star is required to comply with all federal, state and local laws and ordinances applicable to the work.

Spanish Translation/Interpretation – All Star Interpreting Service (City Clerk) FY 2023-2024
Resolution No. ___________
3 All Star understand and agree that the maximum compensation authorized for the services to be performed pursuant to this Agreement is limited to a not-to-exceed sum of Thirty Five Thousand Dollars ($35,000.00).

In the event of termination, the All-Star shall be entitled to compensation for the undisputed reasonable value of services performed to the effective date of termination, including any noncancellable obligations incurred prior to termination, provided, however, that the City may condition payment of such compensation upon the All Star’s delivery to the City of any and all City property, documents, reports, records, materials and work product associated with the performance of this Agreement.

4. Ownership of Materials. All Star agrees that all of its electronic and hardcopy reports, documents, disc, diskettes and other materials and work product created or assembled by it in the course of performing the services (“Work Product”) hereunder are works for hire for the benefit of the City and as such is the sole property of the City. To the extent that such materials and work product do not constitute work for hire, in consideration of the payments and other covenants of the City, as set forth or called for herein, All Star hereby sells, transfers, conveys and assigns any and all of its rights therein to the City. In the event this Agreement is terminated, all Work Product produced by All Star or its agents, employees and subcontractor pursuant to this Agreement will be delivered to City pursuant to the termination clause of this Agreement.

The Work Product may be used by City and its agents, employees, representatives, and assigns, in whole or in part, or in modified form, for all purposes City may deem advisable, without further employment of or payment of any compensation to All Star; provided, however, that if this Agreement is terminated for any reason prior to expiration of this Agreement and if under such circumstances City uses, or engages the services of and directs another All Star to use, the Work Product, City agrees to hold All Star harmless from any and all liability, costs, and expenses relative to claims arising out of matters and/or events which occur subsequent to the termination of this Agreement as a result of causes other than the fault or negligence of All Star, or anyone for whose acts it is responsible, in preparation of the Work Product. All Star will not be responsible for deficiencies solely attributable to modifications of the Work Product performed by others.

5. Independent Contractor Status. All Star, its officers, employees, subcontractors, agents and volunteers (collectively hereinafter the “All Star”), will perform the services in All Star's own way and pursuant to this Agreement as an independent contractor and in pursuit of All Star's independent calling, and not as an employee of City. The persons used by All Star to provide the services under this Agreement will not be considered employees of City for any purposes. Neither the City nor any of its officers, employees, agents or volunteers shall have any control over the conduct of the All Star, except as expressly set forth in this Agreement. All Star expressly warrants that while engaged in carrying out and complying with any terms and conditions of this Agreement that All Star shall not at any time or in any manner, represent that All Star is in any manner officers, employees, agents or volunteers of the City. All Star shall obtain no rights to retirement, health care or any other benefit that accrue to City officials, officers, or employees. All Star expressly waives any claim to such rights.

The payment made to All Star pursuant to the Agreement will be the full and complete compensation to which All Star is entitled. City will not make any federal or state tax withholdings on behalf of All Star or its agents, employees or subcontractors. City will not pay any workers' compensation insurance, retirement contributions or unemployment contributions on behalf of All Star or its employees or subcontractors. All Star agrees to indemnify and pay City within thirty (30) days for any tax, retirement contribution, social security, overtime payment, unemployment payment or workers' compensation payment which City may be required to make on behalf of All Spanish Translation/Interpretation – All Star Interpreting Service (City Clerk) FY 2023-2024
Resolution No. ___________
4 Star or any agent, employee, or contractor of All Star for work done under this Agreement. At the City’s election, City may deduct the amounts paid pursuant to this Section, from any balance owing to All Star.

6. Successors, Assignment and Delegation. City and the All Star each binds themselves, their partners, successors, assigns and legal representatives to the other hereto and to partners, successors, assigns and legal representatives of such other party in respect to all covenants, agreements and obligations contained in this Agreement.

The expertise and experience of All Star are material considerations for this Agreement.

All Star shall not assign or transfer any interest in this Agreement or the performance of any of All Star’s obligations under this Agreement without the prior written consent of the City. Any attempted assignment or transfer of any of All Star’s rights, duties or obligations arising under this Agreement shall be null and void.

7. Nondiscriminatory Employment Practices. During the performance of this Agreement, the All Star agrees not to discriminate against any employee or applicant for employment because of race, sex, creed, color, religion, age, sexual orientation, marital status, national origin, political affiliation, handicap or belief in accordance with requirements of City, State or Federal laws and regulations. All Star will take affirmative action to ensure that applicants are employed, and that employees are treated during employment without regard to their race, sex, creed, color, religion, age, sexual orientation, marital status, national origin, political affiliation, handicap or belief in accordance with requirements of City, State or Federal laws and regulations. Such actions shall include, but not be limited to the following: employment, upgrading, demotion or transfer; recruitment or recruitment advertising; layoffs or termination; rates of pay or other forms of compensation; and selection for training, including apprenticeship.

The All Star agrees to post in conspicuous places, available to employees, applicants and subcontractors for employment, notices setting forth the provisions of this non-discrimination clause.

In the event of the All Star’s non-compliance with the non-discrimination clause of this Agreement, this Agreement may be immediately canceled, terminated or suspended in whole or in part.

8. Subcontracting. All Star's services are unique and personal. Except as may be agreed to by the City, All Star will not subcontract any portion of the services without prior written approval of City Manager or his/her designee. If All Star subcontracts any of the services, All Star will be fully responsible to City for the acts, errors and omissions of All Star's subcontractor and of the persons either directly or indirectly employed by the subcontractor, as All Star is for the acts and omissions of persons directly employed by All Star. Nothing contained in this Agreement will create any contractual relationship between any subcontractor of All Star and City. All Star will be responsible for payment of subcontractors. All Star will bind every subcontractor and every subcontractor of a subcontractor by the terms of this Agreement applicable to All Star's work unless specifically noted to the contrary in the subcontract and approved in writing by City.

9. Other Contractors. The City reserves the right to employ other contractors in connection with the services.

Spanish Translation/Interpretation – All Star Interpreting Service (City Clerk) FY 2023-2024
Resolution No. ___________
5 10. Indemnification. All Star shall indemnify and save harmless the City, its officials, officers, employees, agents and volunteers (collectively hereinafter the “City”), against any and all damages to property or injuries to or death of any person or persons, including property and employees or agents of the City and shall indemnify and save the City from any and all liability and expense including reimbursement of reasonable defense costs and legal fees, and claims, demands, suits, actions or proceedings of any kind or nature, including Workers’ Compensation claims, of or by anyone whomsoever to the extent resulting from or arising out of the negligent, reckless or willful misconduct for the All Star, its officers, employees, subcontractor, subcontractors or agents in the performance of the duties undertaken by All Star pursuant to this Agreement.

This indemnification and hold harmless obligation does not extend to claims arising out of the negligence or willful misconduct of the City.

11. Insurance. Without limiting the All Star’s indemnification of the City, All Star shall obtain and maintain, at its cost and expense, for the duration of the Agreement and any and all amendments, insurance against claims for injuries to persons or damage to property which may arise out of or in connection with performance of the services by All Star or All Star’s agents, representatives, employees or subcontractors. The insurance will be obtained from an insurance carrier admitted and authorized to do business in the State of California. Such evidence shall specifically identify this Agreement and shall contain express conditions that the City is to be given written notice at least thirty (30) days in advance of any termination or implementation of a reduction of limits or material change of insurance coverage as specified herein. Failure on the part of the All Star to procure or maintain insurance shall constitute a material breach upon which the City may immediately terminate this Agreement. All insurance required hereunder shall be primary with respect to any insurance maintained by the City.

Coverages and Limits. All Star will maintain the types of coverages and minimum limits indicated below, unless the Risk Manager or City Manager, in consultation with the City Attorney approves a lower amount. These minimum amounts of coverage will not constitute any limitations or cap on All Star's indemnification obligations under this Agreement.

City, its officers, agents, volunteers and employees make no representation that the limits of the insurance specified to be carried by All Star pursuant to this Agreement are adequate to protect All Star. The coverage will contain no special limitations on the scope of its protection to the below-indicated insureds except for Workers Compensation. All Star will obtain occurrence coverage, excluding Professional Liability, which will be written as claims-made coverage. If All Star believes that any required insurance coverage is inadequate, All Star will obtain such additional insurance coverage, as All Star deems adequate, at All Star's sole expense.

11.1 Commercial General Liability Insurance. $1,000,000 combined singlelimit per occurrence for bodily injury, personal injury and property damage. If the submitted policies contain aggregate limits, general aggregate limits will apply separately to the work under this Agreement or the general aggregate will be twice the required per occurrence limit.

11.2 Workers' Compensation and Employer's Liability. Workers' Compensation limits as required by the California Labor Code and Employer's Liability limits of $1,000,000 per accident for bodily injury. Workers' Compensation and Employer's Liability insurance will not be required if All Star has no employees and provides, to City's satisfaction, a declaration stating this.

Spanish Translation/Interpretation – All Star Interpreting Service (City Clerk) FY 2023-2024
Resolution No. ___________
6 Endorsements. For Commercial General Liability Insurance, All Star will ensure that the policies are endorsed to name the City of Compton and its respective elected and appointed officers, officials, employees, agents and volunteers as “additional insureds” with respect to liability arising out of the activities of All Star. Any failure to comply with reporting provisions of the policies shall not affect coverage provided to the City. Prior to City's execution of this Agreement, All Star will furnish certificates of insurance and endorsements to City.

Waiver of Subrogation. The policies shall contain a waiver of subrogation for the benefit of City.

12. Permits and Licenses. All Star, at its own expense, during the term of this Agreement, shall obtain and maintain all appropriate business and professional permits, licenses and certificates that may be required in connection with the performance of services by the All Star. Upon execution of this Agreement, the All Star shall show evidence of a business license permit in conformance with Section 9-1.2 of the Compton Municipal Code.

13. Maintenance of Records. All Star will maintain complete and accurate records with respect to costs incurred under this Agreement. All records will be clearly identifiable. All Star will allow a representative of City during normal business hours to examine, audit, and make transcripts or copies of records and any other documents created pursuant to this Agreement. All Star will allow inspection of all work, data, documents, proceedings, and activities related to the Agreement for a period of three (3) years, or longer if required by law, from the date of final payment under this Agreement.

14. Warranties. All Star represents and warrants (i) that All Star has no obligations, legal or otherwise, inconsistent with the terms of this Agreement or with All Star’s undertaking this relationship with City, (ii) that the performance of the services called for by this Agreement do not and will not violate any applicable law, rule or regulation or any proprietary or other right of any third party, (iii) that All Star will not use in the performance of his responsibilities under this Agreement any confidential information or trade secrets of any other person or entity and (iv) that All Star has not knowingly entered into or will enter into any agreement (whether oral or written) in conflict with this Agreement.

15. General Compliance with Laws. All Star will keep fully informed of federal, state and local laws and ordinances and regulations which in any manner affect those employed by All Star, or in any way affect the performance of the services by All Star. All Star will at all times observe and comply with these laws, ordinances, and regulations and will be responsible for the compliance of the services with all applicable laws, ordinances and regulations.

16. Termination. In the event of the All Star's failure to prosecute, deliver, or perform the services, after giving written notice of default and two (2) days to correct the same, then, in addition to any other remedies, City may terminate this Agreement for nonperformance by notifying All Star in writing. All Star has five (5) business days to deliver any documents owned by City and all work in progress to City address contained in this Agreement. City will make a determination of fact based upon the work product delivered to City and of the percentage of work that All Star has performed which is usable and of worth to City in having the Agreement completed. Based upon that finding City will determine the final payment of the Agreement. In the event City elects to terminate, City will have the right to immediate possession of all Work Product and work in progress prepared by All Star, whether located at the project site, at All Star's place of business, or at the offices of a subcontractor.

Spanish Translation/Interpretation – All Star Interpreting Service (City Clerk) FY 2023-2024
Resolution No. ___________
7 The City’s obligation is payable only from funds appropriated for the purpose of this Agreement. All funds for payments after the end of the current fiscal year are subject to the City’s legislative appropriation for this purpose. In the event this Agreement extends into succeeding fiscal year periods and the City Council does not allocate sufficient funds for the next succeeding fiscal year payments, this Agreement shall terminate immediately upon written notice from the City.

Either Party, upon tendering ten (10) calendar days written notice to the other Party, may terminate this Agreement for convenience. In this event and upon request of City, All Star will assemble the work product without charge and put it in order for proper filing and closing and deliver it to City. All Star will be paid for work performed to the termination date; however, the total will not exceed the lump sum fee payable under this Agreement. City will make the final determination as to the portions of tasks completed and the compensation to be made.

17. Covenants Against Contingent Fees. All Star warrants that All Star has not employed or retained any company or person, other than a bona fide employee working for All Star, to solicit or secure this Agreement, and that All Star has not paid or agreed to pay any company or person, other than a bona fide employee, any fee, commission, percentage, brokerage fee, gift, or any other consideration contingent upon, or resulting from, the award or making of this Agreement. For breach or violation of this warranty, City will have the right to terminate this Agreement for nonperformance, or, in its discretion, to deduct from the Agreement price or consideration, or otherwise recover, the full amount of the fee, commission, percentage, brokerage fees, gift, or contingent fee.

18. Jurisdiction, Venue and Governing Law. Any action at law or in equity brought by either of the Parties for the purpose of enforcing a right or rights provided for by this Agreement will be tried in a court of competent jurisdiction in the County of Los Angeles, State of California, and the Parties waive all provisions of law providing for a change of venue in these proceedings to any other county. This agreement will be governed by the laws of the State of California.

19. Testimony. All Star will testify at City's request if litigation is brought against City in connection with All Star's services under this agreement. Unless the action is brought by All Star, or is based upon All Star's actual or alleged negligence or other wrongdoing, City, upon prior written agreement with All Star will compensate All Star for time spent in preparation for testimony, testimony, and travel at All Star's standard hourly rates at the time of actual testimony.

20. Waivers. The waiver by either Party of any breach or violation of any term, covenant, or condition of this Agreement or of any applicable law will not be deemed to be a waiver of such term, covenant, condition or law or of any subsequent breach or violation of same or of any other term, covenant, condition or law. The acceptance by either Party of any fee or other payment which may become due under this Agreement will not be deemed to be a waiver of any preceding breach or violation by the other Party of any term, covenant, or condition of this Agreement or any applicable law.

21. Authority. The individuals executing this Agreement and the instruments referenced in it on behalf of All Star each represent and warrant that they have the legal power, right and actual authority to bind All Star to the terms and conditions of this Agreement.

Spanish Translation/Interpretation – All Star Interpreting Service (City Clerk) FY 2023-2024
Resolution No. ___________
8 22. Severability. If any term, provision, condition or covenant of this Agreement or its application to any party or circumstances shall be held, to any extent, invalid or unenforceable, the remainder of this Agreement, or the application of the term, provision, condition or covenant to persons or circumstances other than those as to whom or which it is held invalid or unenforceable, shall not be affected, and shall be valid and enforceable to the fullest extent permitted by law.

23. Amendments. This Agreement may be modified or amended only be written document executed by both All Star and City’s City Manager and approved as to form by the City Attorney. Such document shall expressly state that it is intended by the parties to amend the terms and conditions of this Agreement.

24. Confidentiality. All documents, reports, information, data, and exhibits prepared or assembled by All Star in connection with the performance of the Services pursuant to the Agreement are confidential until released by the City to the public, and the All Star will not make any of these documents or information available to any individual or organization not employed by the All Star or the City without the written consent of the City before any such release.

25. Entire Agreement. This Agreement, together with any other written document referred to or contemplated by it embody the entire Agreement and understanding between the parties relating to the subject matter of it. The City Manager is authorized, in consultation with the City Attorney, to agree to non-material amendments to this Agreement. Neither this Agreement nor any of its provisions may be amended, modified, waived or discharged except in a writing signed by both parties.

26. Notices. Any notices required or permitted under this Agreement shall be effective when delivered in person; and effective one (1) business day after delivery by facsimile transmission; and effective five (5) days after mailing by U.S. Mail, postage prepaid and properly addressed as follows:

To Provider: All Star Interpreting Service
1925 Vassar Avenue
Glendale, California 91204
Attn: Juan Carlos Morales, President & CEO
(213) 400-9225
(213) 400-0925 – Direct
(818) 547-0562 – fax
[email protected]
To City: City of Compton
205 South Willowbrook Avenue
Compton, California 90220
Attn: City Clerk
(310) 605-5530
(310) 639-4685 – fax
Copy to: City of Compton
205 South Willowbrook Avenue
Compton, California 90220
Attn: City Manager
Spanish Translation/Interpretation – All Star Interpreting Service (City Clerk) FY 2023-2024
Resolution No. ___________
9 In the event of any change of address, the moving party is obligated to notify the other party of the change of address in writing. Each party may amend, supplement and update the notice list to add, delete or replace any listed individuals; however, the amendment must be in writing.

27. Miscellaneous. No provision of this Agreement is to be interpreted for or against either party because that party or that party’s legal representative drafted such provision.

Should either party hereto, or any representative, successor or assign of either party hereto, resort to litigation to enforce the provisions of this Agreement, the party or parties prevailing in such litigation shall be entitled, in addition to such other relief as may be granted, to recover its or their reasonable attorney’s fees and costs in such litigation from the party or parties against whom enforcement is sought.

IN WITNESS WHEREOF, ALL STAR has executed this Agreement, and the CITY, by its City Manager, who is authorized to do so, has executed this Agreement.

ALL STAR INTERPRETING SERVICES
Dated: __________________ By ____________________________________ Juan Carlos Morales, President & CEO

CITY OF COMPTON
Approved by:

Dated: _______________ By ____________________________________ Willie Hopkins Jr., City Manager
Approved as to form:

By _______________________________ Dated: ______________ Eric Perrodin, City Attorney
ATTEST:

Dated: _______________ By ___________________________________ Vernell McDaniel, City Clerk

BiLingual Services International
All Language Assistance Network

ESTIMATE FOR INTERPRETING SERVICES
Prepared for: Calicia Godwin, Deputy City Clerk
City of Compton
205 S. Willowbrook Avenue
Compton, CA 90220
Phone: 310. 605. 5530 Email: [email protected]
Services requested: Spanish language interpreting services for City Council meetings Location, date, and time: TBD
In Person Fees:

Half-day session (up to 3 hours) $ 595.00 (per interpreter) Each additional hour or fraction thereof $ 195.00 (per interpreter) Headsets: $ 8.95 (per headset, if requested)
Two interpreters required if meeting is scheduled for more than 2.0 hours Teleconference by Zoom Fees: $ 495.00 (per interpreter) Half-day session (up to 3 hours) $ 165.00 (per interpreter) Two interpreters required if meeting is scheduled for more than 2.0 hours Rush Fee: 25% ADDITIONAL IF LESS THAN 4 (FOUR) BUSINESS DAYS NOTICE IS PROVIDED.

Mileage: If applicable.

Parking: Reimbursement if validation is not available.

Cancellation and Re-scheduling Policy: Less than 4 (four) business days notice is subject to the minimum session rate quoted above.

Billing Policy:
50% deposit required at booking, and balance due upon receipt of invoice. VISA/ MASTERCARD accepted for payment of the 50% deposit and/or balance due.

When paying by credit card, please fill out section below.

Amount: $ Name on Card:_______________________________
Expiration Date: Account Number:____________________ ___ CVV#: Address:____________________Zip code:__________ __ We take this opportunity to thank you for allowing us to be of service. Should this estimate for services meets with your approval, please indicate agreement by signing below. Please feel free to email our office at [email protected] if we can be of further assistance.

Client's Signature Date
H. M. Torres-Comas
BiLingual Services International Representative Date
 EXCELLENCE IN SERVICE 
SINCE1980
[email protected] www.bilingualservicesinternational.com WE SPEAK YOUR LANGUAGE!
Dear Valued Client,
I want to first thank you for coming to Reliable Translations for all your translation and interpreting needs! We are very excited to serve you and your team, and we look forward to fulfilling all your requests in a timely and efficient manner.

We have attached this Welcome Letter so you will know more about who we are, what we do and most importantly, how we are going to make your translations and interpreting experience fast, easy, and efficient with the best results possible.

WHO WE ARE
Reliable Translations is an established national Translations agency based in Glendale, CA (West) with offices in Nashville, TN (Central) and Clearwater, FL (East). We have been in business for over 12 years, and we serve the entire Continental United States with Translation and Interpreting services in ANY language(s) for any type of document(s) and for any type of meeting.

Reliable Translations Inc. New Client-Info Pack

WHAT WE DO
Our main focus at Reliable Translations is to make Translation and Interpreting services EASY and PAIN FREE for all our clients.

This means we have as our #1 goal your complete satisfaction with each and every Translation and/or Interpreting job you send our way. We believe that if we can take most of the work out of your hands and place it into ours, and then perform the request VERY well, you will be fully satisfied.

We want you to rest easy, knowing that all your Translation and Interpreting needs are fully taken care of, day in and day out, with the least amount of effort on your part because we have you fully covered. Our fast, easy, and efficient service was designed to be this way through 12 years of hard-won experience.

In short, we know how to make your life easier by providing excellent translation and interpreting services.

GENERAL INFORMATION
Prices: Answers to pricing questions will be provided by your Sales or Service Representative at your request.

Hours: Monday-Saturday for all clients from 8:30 AM to 6:00 PM Customer Service Hours: Email: 24 Hours a day, 7 days a week.

Phone: Monday-Friday, 8:30AM to 5:30PM
Main Office Physical Address:
121 West Lexington Dr., Suite L106D, Glendale, CA 91203 Main Phone: 818-484-8673 Sales: Ext. 700
Translations: Ext. 701
Interpreting: Ext. 702
Finance: Ext. 703
Website: www.ReliableTranslations.com
Below you will find answers to Frequently Asked Questions (FAQs). If you do not find the answer to your question here, please ask your service representative.

TRANSLATIONS
How do I place an order for a translation or translations? Written Translations: If you have a translation request, simply email it to [email protected] and attach the document(s), note the language or languages to be translated into and the date by which you need the translation completed and returned to you.

If there is any other information, reference material such as a glossary, or any other special requests for the translation or formatting, just include it in the email request. If your document is very large (10 MEG or larger), you can request a secure link by email that will allow you to upload your files safely with a simple drag and drop of the files.

Your service representative will usually get back to you in no more than 30 minutes confirming the request. If there is any missing information, the service representative will ask in the return communication. Other than that, we will get right on it and get it completed and right back to you! Can I make a translation request at any time and for a very short turnaround time?
YES, you can. In almost all cases we can meet your request. If we know we honestly cannot, we will inform you. But be assured we do have the resources to meet very tight turnaround times no matter the size of the request.

What is a RUSH request for a translation and what is the charge? A RUSH request is any request that requires a turnaround of 24 hours or less. Be advised, this definition can change depending on volume and the nomenclature (highly specialized such as scientific, medical, etc.).

Your service representative will let you know right away but be assured almost all RUSH requests can be fulfilled for the deadline and if that is not the case for any reason, you will be informed right away to work out the best solution. The charge for a RUSH translation is $0.06/word in addition to the standard price. Small documents incurring a flat rate base fee DO NOT receive any extra charge for RUSH.

What are FLAT RATE minimum charges?
Very small documents will have a flat rate minimum (Base) charge. The size of a flat rate document is variable depending on the language, but generally falls in the range of 250-400 words or if your document is larger than this minimum size, a per word rate for that language applies instead.

Flat rate charges for minimum word translations can vary slightly, so please always check with your Service Representative.

Can a translation order be cancelled?
No, translations are started almost immediately, and because translators are paid in full for translations once assigned, we do need to also charge in full for the translation after an allowed grace period of 20 minutes.

Does Reliable Translations use Machine-Translation Software or Google to Translate?
NO. Our Translations are 100% Human Generated and this is expressly stated in the Reliable Translations Contract with Linguists. 100% Human Generated Translations also ensure the target audience is receiving the communication in its intended form.

INTERPRETING
How do I Place an order for an Oral Interpreting request? Oral Interpreting: For an interpreting request simply email [email protected]. Please include the language(s) needed, the date, the starting time and ending time, and the type of meeting. If it is an on-site meeting, include the location with the complete physical address, or if it will be virtual (Zoom, Skype, etc.) include the Zoom link and any other needed information such as an agenda for the virtual event/meeting.

If you need written document translations to complement your event, such as a PowerPoint or printed agenda, let us know and we can get it translated.

Your Service Representative will contact you within 30 minutes of the request to confirm arrangements and make sure your interpreting service is fully set up! For any interpreting request, you can always call (818) 484-8673 Ext. 702 to discuss it with your Service Representative.

Can I schedule an interpreting job with very short notice? Is there an extra fee?
YES, you can schedule an interpreting job with as short a notice as just minutes before the event, if you would like.

NO, there would not be an extra fee.

The only problem with ordering on short notice would be the availability of Interpreters to cover it and simply if we can schedule them and get them there on time. In this case, as soon as you schedule the job, covered or not, Reliable Translations charges the full rate. So it is simply NOT advised to schedule interpreting events with any shorter notice than 24 hours prior to the event or meeting.

The BIGGER the event and more languages required, the longer the advance notice we advise. If there are any issues whatsoever with coverage, your Service Representative will let you know right away. But be assured we can cover pretty much anything you throw at us.

We just ask that you give us as much advance notice as possible, and the bigger the event and the more languages needed, any additional time given makes it easier for all parties involved.

What is the cancellation policy on Interpreting assignments? Any Interpreting Job received by Reliable Translations which is confirmed with you, the client, that is cancelled within 24 hours of the scheduled start time, is considered a late cancellation and the full job as scheduled will be charged.

What is Simultaneous Interpreting:

Simultaneous Interpreting means a linguist is interpreting a meeting or event while the speaker speaks (simultaneously to the speaker). For in-person meetings, this usually requires a transmitter and receivers for those hearing the interpreter. Simultaneous basically means “At the same time.” This style is used in almost all meetings and events where there is a speaker and multiple people are being interpreted for. It is even used for a single audience member if the speaker does not want to be interrupted while speaking.

What is Consecutive Interpreting?
This is interpreting during which the interpreter waits for the speaker to say about 2 or 3 lines. Then the speaker pauses so the interpreter can interpret those lines for the other party. This protocol is usually explained to the speaker, if necessary, before the event begins, so the speaker is aware to stop after a few lines, allowing the interpreter to interpret them. The interpreter can ask/answer questions back and forth or convey the answers to the speaker. This is common for medical environments, one on one conversations, and interviews of any kind.

Can I send a translation or interpreting request at ANY time? YES. You can email your request ANYTIME to the email addresses mentioned above. They will be answered as soon as they are received within 30 minutes during normal business hours Monday-Saturday. You may need to give it a little more time on a Sunday or after 6:30 PM PST. Besides that, you will always get an answer within 30 minutes. In fact, it is very common for our Service Representatives to answer request emails within 10 minutes! How is interpreting billed in terms of hours?
Reliable Translations does have a minimum number of hours for any interpreting job, which is based on the booked time. The billing requirements are listed in bullet points below:
• 1-hour minimum for telephonic interpreting
• A 1.5 hour minimum per language for any virtual event/meeting (Zoom, Skype, etc.).
• A 2-hour minimum for any ON SITE event/meeting (Physical location that the interpreter must travel to).
• For any virtual event using Simultaneous Interpreting, 2.5 hours or more requires 2 interpreters per language. Specialized scenarios such as medical, scientific, or specialized terminology may require a partner for an even shorter meeting, and this is determined by your Sales • Representative or Service Representative. Most scenarios are NOT specialized.
• For any ON SITE Simultaneous Interpreting, a meeting of 3 hours or more requires 2 interpreters per language.
• For ON SITE Simultaneous interpretation of 2.5 hours or more with no breaks, 2 or more interpreters per language will be required. • Consecutive Interpreting usually does not require 2 interpreters per language except under certain scenarios such as a large audience for which 2 or more interpreters per language may need to “roam” to handle “Question and Answer” sessions for people in the audience. • If an interpreting session runs beyond the originally booked ending time, we add charges in 15-minute increments, rounded to the nearest 15 minutes, for each interpreter on the assignment. (Please be sure to book enough time when you set up your assignment, since interpreters may have other booked assignments later that day that they must honor. They will continue if available.)
• For ASL (American Sign Language) we often need to book 2 interpreters for assignments even shorter than 2 hours. This language is physically taxing as well as mentally, so having an interpreting partner is needed more frequently. Check with your service representative and provide details of your request.

Are there any other charges for Interpreting services?
• There could be, and your Sales or Service Representative will let you know upfront what these would be. Below are some other possible charges:
• Mileage for ON SITE interpretation. This charge is usually for traveling distances of 25 miles or more each way. (We use the standard IRS mileage reimbursement rate announced yearly.)
• For On-Site Simultaneous Interpreting Reliable Translations charges for equipment rental if you are not providing the equipment for Interpreting.

For any virtual event, if a Technician for the virtual platform is needed, we do charge an hourly rate for the Technician. Where there are multiple languages, or multiple speakers in a virtual event, your Service • Representative can discuss any needed set up time for Interpreters to come online for testing of the set-up arrangements in coordination with staff and technician before the event commences.
• As noted above, overtime beyond the booked time is charged in 15- minute increments and will be added after the event.
• ASL could require a second “partner” interpreter at or even before the 2- hour mark.

Please also note: Any Interpreting job received within 24 hours of the scheduled start time and also confirmed within 24 hours of the scheduled start time which is then cancelled before the scheduled start time will be charged in full.

RELATED SERVICES
What additional language services do you provide?
• Certifications and notarizations of our translations where required for legal documents.
• Foreign language transcription of your audio or video files • Translation of a transcript to another language
• Subtitling
• Voiceovers
• Translation and voicing of navigation cues and messages for your phone system
• Foreign language layout services, such as in InDesign • Translation for web and for social media posts
• Dialogue consultation for film
RELATED FAQs
Does Reliable Translations outsource ANY of its interpreters or translators?
NO. Reliable Translations only uses Professionals in the field of Interpreting and Translations. Reliable Translations has a direct 17-page binding Contract with every linguist that we use. This alone ensures a professional level of quality for every job we do as we only pull from these resources.

Reliable Translations also does quality checks on every linguist to ensure a continued high level of quality.

Are there any extra charges or hidden fees after I get my initial quote? NO. Reliable Translations is unique in this field as our final quoted price is always the FINAL price. You will never incur ANY additional fees, hidden charges, or surcharges with Reliable Translations. If your assignment changes from your initial booking by running overtime, we charge the additional time in 15-minute increments, but we use the same hourly rate, not time and a half, or double time.

Other translation and interpreting companies sometimes quote a very low price, but by the time the job is completed or is in progress, the job has incurred many additional fees. This is something you will never experience with Reliable Translations.

How do I pay?
In your INITIAL sale (your first purchase) we will usually ask for a 50% deposit. All subsequent requests/work can be billed to your company or purchasing department. We do understand that many Government entities, Schools and Corporations only pay by invoicing and/or Purchase Order. In this case your Sales Representative will work out the best payment option for you on your initial quote/sale.

What if there is a problem with any Translation or Interpreting job? Immediately contact your Customer Service Representative and he or she will handle it right away.

Does Reliable Translations outsource its tech/customer support? NO. Reliable Translations has employees in 3 separate locations in the United States that cover all three regions (West, Central and East). After your initial sale/order, you will be set up with a Service Representative who will handle ALL your future job requests from that point forward and any service or tech questions.

You will have a dedicated Service Representative who is available by phone during business hours and email 7 days a week.

Can I call with a question at any time?
You can call (818) 484-8673 at any time, but the hours for our main line are limited to 8:30 AM to 6PM PST Monday through Friday with occasional phone availability on Saturday.

If you are calling outside those hours you may not get a Service Representative on the line and it would be better to email your request or call back during the regular business hours.

Is there anything else I need to know that is not covered here? If there are any questions you may have that are not covered here, your sales or service representative will help you right away. Please feel free to call ANYTIME or email ANYTIME. Our keyword is RESPONSIVENESS.

During regular hours we will be there for anything you need and outside those hours, please send us an email, and we will get back to you ASAP.

You can also call and leave a message if outside regular hours.

Reliable Translations is here to service you and your team to the highest standards possible. We very much look forward to taking care of all your translation and/or interpreting needs!

Our mailing address is:

Reliable Translations, Inc.
121 W. Lexington Drive, Suite L106D
Glendale, CA 91203
Category MINIMUM
CHARGE
On-Site Meetings Rate/hour 2 hours
Partner needed , if
simultaneous
interpreting will be
intensive.

Spanish $114 $228
Arabic $154 $308
ASL* $180 $360
Cantonese $154 $308
Farsi $154 $308
Hmong $192 $384
Italian $154 $308
Korean $154 $308
Mandarin $154 $308
Somali $192 $384
Russian $154 $308
Tagalog $154 $308
Vietnamese $180 $360
Other Languages - request quote
Zoom/Videoconference Meetings Rate/hour 1.5 hours / except ASL Partner needed , if simultaneous
interpreting will be
intensive.

Spanish $114 $171.0
Arabic $154 $231.0
ASL $180 $270.0
Cantonese $154 $231.0
Farsi $154 $231.0
Hmong $192 $288.0
Italian $154 $231.0
Korean $154 $231.0
Mandarin $154 $231.0
Russian $154 $231.0
Somali $192 $288.0
Tagalog $154 $231.0
Vietnamese $180 $270.0
Other Languages - request quote
Phone Conferences Rate/hour 1 hour
Spanish $ 114.00 $ 114.00
Arabic $ 154.00 $ 154.00
Cantonese $ 154.00 $ 154.00
Farsi $ 154.00 $ 154.00
Hmong $ 192.00 $ 192.00
Italian $ 154.00 $ 154.00
Korean $ 154.00 $ 154.00
Mandarin $ 154.00 $ 154.00
Russian $ 154.00 $ 154.00
Somali $ 192.00 $ 192.00
Tagalog $ 154.00 $ 154.00
Vietnamese $ 180.00 $ 180.00
Other Languages - request quote
We charge for additional time in 15 minute increments, rounded to the nearest 15 minutes.

Mileage will be charged at Standard IRS Reimbursement rate for the year if mileage is > 15 miles round trip.

Cancellation or no show with less than 24 hours' notice will incur the full charge for the booked time.

You are committing to the booked time. If the meeting or conference ends early, the booked time is still due.

WRITTEN TRANSLATIONS Professional Translator Calif Court Certified Spanish 0.18/word 0.28/word
Arabic $0.32 $0.40
Chinese $0.29 $0.40
Farsi $0.32 $40.00
Hmong $0.45 $0.55
Italian $0.25 $0.34
Korean $0.29 $0.40
Russian $0.28 $0.38
Somali $0.32 $0.42
Tagalog $0.27 $0.36
Vietnamese $0.29 $0.46
FLAT RATE MINIMUM OF $80.00 PER MOST LANGUAGES
Cancellations are not permitted on written translations since we are obligated to pay the translator in full once the job order is begun.

Calif Court Certified
JOSEPH W. MEDRANO & ASSOCIATES, INC.
1824 SOUTH SIXTH STREET
ALHAMBRA, CA 91803
A Professional Interpreting Service
(626) 576-5007
Proposal for City of Compton City Council Meetings
Simultaneous Interpreting Rates
Interpreter labor is assumed to be for a full day event, up to 6 hours with 2 interpreters.

Spanish Translation
Interpreter Summary
Spanish Conference
Interpreters (Up to 6 Hours)
*After 6 hours, add $525 for
each additional hour
Qty
2 Units
1 full day
Per Interpreter
$ 1600
Total cost
$ 3200*
*Note: If any documents are to be translated, please provide them at least 2 business days prior to the event in PDF format so our interpreters can prepare accordingly.

Payment Terms
Full payment is required 7 days prior to meeting date. If payment is not received, we will not provide interpreting services for the meeting.

Cancellation Policy
If the assignment is changed or cancelled, notification must be received within 72 hours/ 3 business days prior to the assignment start time excluding weekends and holidays (i.e. an assignment for 2 pm Tuesday must be cancelled by 2 pm the previous Thursday; an assignment for 10 am Wednesday must be cancelled by 10 am the previous Friday), otherwise full charges will apply. If, on the date of the assignment, the interpreter(s) is not used or the assignment does not go forward for any reason, full day charges will apply.

RESOLUTION NO. __________

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COMPTON

TO RECEIVE AND FILE INTERNAL CONTROL POLICIES RELATING TO INTERNAL AUDIT, WHISTLEBLOWER PROTOCOL, AND FRAUD.

WHEREAS, the City Controller’s Department has prepared an Internal Audit, Whistleblower Policy and Fraud Hotline Policy to address deficiencies and weaknesses in internal controls surrounding an Internal Audit, Whistleblower and Fraud Hotline practices that are performed within various departments of the City. These policies which are attached as Exhibit A include (a) provisions for proper separation of duties to avoid conflicts of interest, and (b) provisions for proper procedures to be put in place to ensure that appropriate staff perform their internal audit, whistleblower, and fraud hotline management functions effectively and efficiently. The provisions contained in the policies directly address audit findings that the City has received in the past from the State Auditor’s Office, the State Controller’s Office, as well as from its external auditors, Eadie and Payne, LLP.

WHEREAS, additionally, the Standard Operating Manual policies, and other financial policies and procedures currently in place to address these issues were not sufficient and it is proposed that they be appended or replaced with the attached policies.

Per staff review there were no existing policies that were previously adopted by the City Council that addressed these needs and therefore these do not conflict with already adopted policies on these matters.

WHEREAS, per the City’s FY2020 Single Audit Report, Finding No. 2014-108B is stated as follows:
#2014-108B: Policies and Procedures (General Applications) (MW) Criteria: Control activities are regularly evaluated to ensure that they are still appropriate and working as intended.

Condition: Outside the City Controller's Office, most of the employees that the SCO interviewed were unaware of control activities in place or how they are being applied.

Recommendation: We recommend that the City continue to review and update its Administrative Policies and Procedures manuals to ensure consistency with current processes and organizational structure; and perform periodic and ongoing reviews to ensure proper documentation, accuracy, and completeness in its financial transactions and records. When completed, the updated Administrative Policies and Procedures manuals should be readily available to all responsible employees. The manuals should clearly state the authority and responsibility of all employees, especially the authority to authorize transactions and the responsibility for the safekeeping of assets and records.

WHEREAS, this audit finding and recommendation demonstrated the need for the implementation of policies affecting internal controls.

WHEREAS, other findings and recommendations listed in the FY2020 Single Audit report demonstrate the need for many of the provisions contained in these policies, such as having risk identification procedures, risk analysis procedures, evaluation procedures, as well as how to avoid inciting repeated or new audit findings in the future.

WHEREAS, each of the findings and recommendations in the FY2020 Single Audit display deviation from at least one of the five elements of proper internal control. The five elements of proper internal controls are (1) Control Environment, (2) Monitoring Activities, (3) Risk Assessment, (4) Control Activities, and (5) Information and Communication. The provisions in these policies, if implemented properly by staff, will help minimize risk for the City as they cover a wide array of situations that pose a risk to proper internal control and the City’s financial position and operations. It is also important to know that policies

6. Resolution No. _______

Page 2 ends

2 may need to change to keep up with current environment or any unforeseen circumstances.

WHEREAS, training will be provided to staff so that they can understand the various provisions of the policy.

WHEREAS, it is recommended that the City Council adopt the attached Resolution to receive and file the attached policies.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF COMPTON DOES HEREBY RESOLVE AS FOLLOWS:

Section 1. That the City Council of the City of Council receive and file the following policies: (i) Internal Audit Policy; (ii) Whistleblower Policy; and (iii) Fraud Hotline Policy.

Section 2. That a copy of this Resolution shall be filed in the offices of the City Clerk, City Attorney, City Manager, and City Controller.

Section 3. That the Mayor shall sign and the City Clerk shall attest to the adoption of this Resolution.

ADOPTED this ____________ day of _____________, 2023.
________________________________

MAYOR OF THE CITY OF COMPTON
ATTEST:
________________________________

CLERK OF THE CITY OF COMPTON

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss

That said Resolution was adopted by the following vote, to wit:

AYES: COUNCILMEMBERS -
NOES: COUNCILMEMBERS -
ABSTAIN: COUNCILMEMBERS -
ABSENT: COUNCILMEMBERS -
____________________________________

CITY CLERK OF THE CITY OF COMPTON
0 CITY OF COMPTON

INTERNAL AUDIT OFFICE

POLICIES AND PROCEDURES MANUAL
July 6, 2023
1 CITY OF COMPTON

INTERNAL AUDIT POLICIES AND PROCEDURES

1. ORGANIZATION AND POLICY

1.1 Purpose

1.2 Mission

1.3 Independence

1.4 Responsibility

1.5 Audit Plan

1.6 Scope

1.7 Authority

1.8 Standards of Audit Practice

2. TYPES OF AUDIT SERVICES

2.1 Compliance Audits

2.2 Performance Reviews

2.3 Unannounced Audits

2.4 External Audit Assistance

2.5 Fraud, Waste and Abuse Investigations

2.6 Special Reviews

2.7 Requests for Internal Audit Services

3. METHOD OF OPERATION AND DOCUMENTATION

3.1 Working Papers

3.2 Audit Report

3.3 Audit Report Distribution

3.4 Audit Follow-up

3.5 Records Disposition

4. WHISTLEBLOWER POLICY

4.1 Objective

4.2 Reporting and Responsibility

4.3 Acting in Good Faith

4.4 Reporting Concerns
2 4.5 Handling Reported Violations

4.6 No Retaliation

4.7 Confidentiality

5. SPECIFIC AUDITS

5.1 Compliance Audits

5.2 Performance Reviews

5.3 Unannounced Audits

5.4 External Audit Assistance

6. Internal Audit Office Reporting Structure

7. Selection of Audit Areas

7.1 Selection based on Risk Assessment

7.2 Annual Audit Plan

7.3 Special Projects

7.4 Non-audit Service

7.5 Types of Non-audit Service

8. Fraud

8.1 Characteristics of Fraud

8.2 Fraud Examples and Audit Activities

8.3 Fraud Deterrence

8.4 Fraud Detection

8.5 Fraud Investigation

8.6 Reporting Fraud
3 INTRODUCTION:

The Internal Audit Office Policy and Procedures Manual defines how the Internal Audit Office shall achieve its mission. The audits performed by the Internal Audit Office will be conducted in conformity with the Institute of Internal Auditors International Standards for the Professional Practice of Internal Auditing (Standards), and in accordance with the United States Generally Accepted Government Auditing Standards (GAGAS). Investigation conducted by the Internal Audit Office will utilize the Generally Accepted Principles and Quality Standards for Investigations established by the Office of Inspector General (OIG). The City of Compton shall employ at least one Internal Auditor who will regularly review and test the accuracy and completeness of accounting and internal control systems. The Internal Auditor shall report to the City Controller and the Audit Committee. Using knowledge and professional judgment, the Internal Auditor provides an independent appraisal of financial, operational, and control activities. The Internal Auditor reports on the adequacy of internal controls, the accuracy and propriety of transactions, the extent to which assets are accounted for and safeguarded, and compliance with institutional policies and government laws and regulations. Additionally, the Internal Auditor is responsible for providing analysis, recommendations, counsel, and information concerning the activities reviewed.

1. ORGANIZATION AND POLICY

1.1 PURPOSE
This policy and procedure manual establishes the official policies and procedures for the Internal Audit Office of the City of Compton. It explains the purpose, authority and responsibility of the internal audit function and the duties of the Internal Audit Office. This manual describes the audit function, and documents how the City of Compton Internal Audit Office shall meet and comply with generally accepted government auditing standards (GAGAS) as set forth in the Government Auditing Standards, December 2011 Revision, commonly referred to as the Yellow Book, issued by the U.S. Government Accountability Office. The Audit Manual references GAGAS, and helps Office of the City Auditor staff plan, organize, and conduct required audits, and informs staff how to develop and report audit findings in accordance with Government Auditing Standards.

1.2 MISSION STATEMENT
The mission of the Internal Audit Office is to provide independent, objective assurance and consulting services designed to add value and improve the City of Compton’s operations. The Internal Audit Office helps the management team of the City of Compton to accomplish its objectives by bringing systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance process. To provide quality audit services in an independent, objective manner to assure financial and operational integrity, accountability, efficiency, effectiveness, and compliance with laws and regulations and agency policies and procedures.
4 The scope of work of the internal audit activity is to determine whether the organization’s network of risk management, control, and governance processes, as designed and represented by management, is adequate and functioning in a manner to ensure:
 Risks are appropriately identified and managed.
 Interaction with the various governance groups occurs as needed.  Significant financial, managerial, and operating information is accurate, reliable, and timely.  Employee’s actions are in compliance with policies, standards, procedures, and applicable laws and regulations.
 Resources are acquired economically, used efficiently, and adequately protected.  Programs, plans, and objectives are achieved.
 Quality and continuous improvement are fostered in the organization’s control process.  Significant legislative or regulatory issues impacting the organization are recognized and addressed properly.  Opportunities for improving management control, accountability, and the organization’s image may be identified during audits. These opportunities will be communicated to the appropriate level of management.

1.3 INDEPENDENCE
Independence is an essential element of objectivity. It is imperative that Internal Auditors maintain independence in appearance as well as in fact. Independence could be compromised if Internal Auditors participate directly in the development, installation, preparation or reconstruction of accounting systems, data, or records, or by engaging in activities that would normally be reviewed by Internal Auditors.

1.4 RESPONSIBILITY
The Internal Audit Office has the responsibility to:
• Develop a flexible, risk-based annual plan of Internal Audit Office work. • Implement the approved annual audit plan.
• Evaluate governance and risk management related to operations at City of Compton consistent with Internal Audit Policies and Procedures and with the approved Annual Audit Plan. This may include evaluating significant new or changing services, processes, operations, and control processes coincident with their development, implementation, and/or expansion.
• Report significant issues related to governance and risk management related to operations at City of Compton, including potential improvements, and provide information concerning such issues all the way through to resolution.
• Maintain a professional Internal Audit staff with sufficient knowledge, skills, and other competencies to meet the requirements of the policies and procedures stated in this document. 5 • Periodically provide information to the City Council and Audit Committee on Internal Audit Office activities and results relative to the Annual Audit Plan, as well as the sufficiency of the Internal Audit Office resources. • Inform the Audit Committee of significant emerging trends and successful practices in Internal Auditing. • Report the most critical issues to the Audit Committee, along with management’s progress toward resolving them. Critical issues typically have a reasonable likelihood of causing substantial financial or reputation damage to the City. For complex issues, the responsible manager may participate in the discussion. Such reporting is critical to ensure the function is respected, that the proper “tone at the top” exists in the organization, and to expedite resolution of such issues.

Opportunities for improving City of Compton operations may be identified by the Internal Audit Office. They will be communicated to the Audit Committee and the appropriate levels of management.

Internal Audit has no direct responsibility or any authority over any of the activities or operations it reviews.

Internal Audit is a managerial control that functions by measuring and evaluating the effectiveness of other controls. Management is not relieved of any assigned responsibilities because Internal Auditors perform the evaluative reviews with which they have been charged.

1.5 AUDIT PLAN
The Internal Audit Office has responsibility to develop a flexible, risk-based annual plan of work, considering the input of management, and submit that plan and significant interim changes to the Audit Committee for review and approval. The plan should include but not be limited to the following items:
• Compliance Audits
• Performance Reviews
• Unannounced Audits
• External Audit Assistance
• Fraud, Waste and Abuse Investigations
In order to determine a list of appropriate audits for the year, the Internal Audit Office begins by identifying possible audits. These items are then evaluated for the risks and possible benefits that are associated with each one. Priority is then given to higher-risk and higher-benefit projects, required audits and Council requests, subject to the skills and resources of the Internal Audit Office.

1.6 SCOPE
The scope of internal auditing encompasses the examination and evaluation of the adequacy and effectiveness of the organization's system of internal control and the quality of performance in carrying out assigned responsibilities. This enables the Internal Audit Office to determine whether the agency’s risk management, control, and governance processes, as designed and represented by management, are adequate and functioning in a manner to ensure:
• Risks are appropriately identified and managed.
• Financial, managerial, and operating information is accurate, reliable, and timely. 6 • Employee’s actions are in compliance with policies, standards, procedures, and applicable laws and regulations.
• That the City assets are acquired economically, used efficiently, and adequately protected. • Programs, plans, and objectives are achieved.
• Recommendations for improving management control, accountability shall be made to the appropriate level of management.

Internal Audit functions in an advisory capacity; it does not have authority to make operating decisions or to direct anyone to take action.

1.7 AUTHORITY
Management of the Internal Audit Office is authorized to:
• Have unrestricted access to all programs, records, property, and personnel as needed. • Allocate resources, set frequencies, select subjects, determine scopes of work, and apply the techniques required to fulfill its mission and responsibilities.
• Make copies of all required files for the purpose of the audit work.

Management and staff of the Internal Audit Office are NOT authorized to:
• Perform any operational duties for City of Compton.
• Make management decisions external to the Internal Audit Office. The Council, Directors and management have primary responsibility for control of City of Compton decisions. • Initiate or approve fiscal transactions external to the Internal Audit Office. • Direct the activities of any City of Compton employee not employed by the Internal Audit Office/City Controller’s Office, except to the extent such employees have been appropriately assigned to auditing teams or to otherwise assist the internal auditors.
• Make changes to existing departmental records

1.8 STANDARDS OF AUDIT PRACTICE
The Internal Audit Office is guided by the City of Compton Code of Ethics and will meet or exceed the Standards for the Professional Practice of Internal Auditing established by The Institute of Internal Auditors.

It is the policy of the Office of the City Auditor to follow generally accepted government auditing standards (GAGAS), as provided in Government Auditing Standards, December 2011 Revision, issued by the U.S.

Government Accountability Office—more commonly referred to as the Yellow Book.

This section documents the four general standards and provides guidance for performing financial audits, attestation engagements, and performance audits. These general standards deal with:
• Independence
• Professional Judgment
• Competence
• Quality Control and Assurance
7 2. TYPES OF AUDIT SERVICES
The following are general descriptions of the types of services provided by the Internal Audit Office. The annual audit plan can include any combination of these types.

2.1 COMPLIANCE AUDITS
Compliance audit determines whether, and to what degree there is conformance to certain specific requirements of policy, procedures, standards, or laws and governmental regulations. The Internal Audit Office may conduct compliance audits, which are generally performed to ensure compliance with Federal or State laws and/or requirements of any City agreements. These can include reviews of management or third party or vendor practices and financial data to determine the extent to which a unit complies with applicable laws, government regulations and standards, contracts, and policies and procedures.

2.2 PERFORMANCE REVIEWS
The Internal Audit Office may conduct performance audits in order to provide an independent assessment of the performance of the organization, a program or activity. Performance audits provide information to improve risk management and control systems within the various areas by evaluating compliance with policies and procedures. Performance audits include, but are not limited to, reviews of program procedures and operations to determine whether:
• Duties and responsibilities are being performed in the most efficient and economical (cost effective) manner • Activities are properly authorized by appropriate personnel • Management has the capacity to ensure compliance with applicable laws, regulations, contracts and policies • Operations actually conform in all material respects to applicable laws, government regulations and standards, contracts, and policies and procedures.

2.3 UNANNOUNCED AUDITS
The Internal Audit Office may conduct unannounced audits, which are an effective way to prevent or detect fraud. These audits could include reviews of petty cash, incentive and bus tokens, cash receipts/deposits, fixed asset additions/deletions, employees and their benefits verification, and operating parts and supplies inventory etc.

2.4 EXTERNAL AUDIT ASSISTANCE
The Internal Audit Office may provide audit assistance to the external auditors/monitors as well as City Controller’s office during any City of Compton external audits/monitoring visits. Internal Audit will review all resulting management letter comments to determine if there is any impact upon the annual Internal Audit Plan.
8 2.5 FRAUD, WASTE AND ABUSE INVESTIGATIONS
Loss/Fraud investigations are conducted to determine existing control weaknesses, assist in determining the amount of loss/fraud, waste, and abuse and recommend corrective measures to prevent or detect subsequent recurrences. The Internal Audit Office will investigate all credible fraud, waste and abuse tips that could affect the organization and that can be handled within the expertise of the Internal Audit staff. However, allegations of a serious criminal act (e.g., theft, robbery, assault, violence etc.) should be promptly reported to the appropriate officials and proper law enforcement agency. Refer to Policies and Procedures #4 below (Whistleblower Policy) for further information.

2.6 SPECIAL REVIEWS
The Internal Audit Office may conduct special reviews, which are audit activities that result from requests to Internal Audit from the Audit Committee, the City Council or other management. Special reviews are carried out in conformance with the specifications and concerns of the requestor. These include reviews and analyses of particular areas of a program's operation to provide an independent appraisal of its effectiveness, efficiency, adequacy of internal control and compliance with appropriate regulations. For example, special reviews might be undertaken to consult with management on specific financial or performance questions.

This could also involve Assets verification or Information Technology. To verify accountability, physical safeguards, and valid use of distributed assets. To evaluate the accuracy, effectiveness, efficiency and security of electronic and information processing systems, etc.

2.7 REQUESTS FOR INTERNAL AUDIT SERVICES
Program Directors or Managers requiring the services of the Internal Audit Office should direct all such requests, preferably in writing, to the Internal Audit Office, the City Controller or Audit Committee and it will be determined whether the requested assistance can be provided and when it can be scheduled.

3. METHOD OF OPERATION AND DOCUMENTATION
The Internal Audit Office plans to use the following procedures when conducting most reviews/audits; however, performing all steps for every review/audit would be impractical, for instance, audit reports will not be issued for reviews that are performed weekly. The practicality of performing all steps will be determined as required.

3.1 WORKING PAPERS
The Internal Audit Office must document relevant information (on paper or in electronic format) to support the conclusions and results of engagements; therefore, Internal Auditors will prepare working papers whenever an engagement is being conducted. Working papers document the information obtained, the analyses made, and the support for the conclusion and engagement results. Internal audit management reviews the prepared working papers. Engagement working papers generally:
• Aid in the planning, performance, and review of engagements • Provide the principal support for engagement results
9 • Document whether engagement objectives were achieved • Support the accuracy and completeness of the work performed • Provide a basis for the internal audit activity’s quality assurance and improvement program • Facilitate third-party reviews
The organization, design, and content of engagement working papers depend on the engagement’s nature and objectives and the organization’s needs. The Internal Audit Office must maintain a good system of filing/indexing for working papers, so that they can be easily located if needed.

3.2 AUDIT REPORT
Upon completion of fieldwork, the Internal Auditor will prepare an original draft of the audit report. The report will communicate to management of the program audited, in a clear and concise manner, the results of the audit or review. The format of the report will depend upon the type of audit performed. When preparing and completing the Audit Report, the Internal Audit Office will follow the steps listed below:
• The Internal Audit Office will review the original draft and make any changes deemed appropriate. • A copy of the resulting draft normally will be submitted to appropriate management (usually management of the program that was audited).
• Internal Audit and appropriate management may hold a conference to discuss the draft report. Changes to the draft report may result from this "exit" conference. In some instances, holding an “exit” conference may not be possible or may not be an efficient use of time. In these cases, management will be responsible for contacting the Internal Audit Office with any questions, comments or concerns that they may have. • Official written responses to specific audit report recommendations will be requested from appropriate management to be included in the final and issued version of the report. The responses should include the degree of agreement or acceptance of each recommendation. The preferred responses are:
* We concur." Management is in full agreement with the recommendation; or "We partially concur." Management is in agreement with a portion of the recommendation; * "We concur with reservations." Management is in agreement with the recommendation, but there are circumstances that could affect its implementation which have to be resolved; and * "We do not concur." Management is in total disagreement with the recommendation. * Management is encouraged to provide an explanation in support of the positions taken, if considered necessary.
* Responses should be accompanied by a target implementation date and the individual or position responsible for implementation.

Two weeks are usually allowed for management to provide written responses to the recommendations. If management does not appear to make a good faith effort to provide responses, the final version of the report may be issued without responses at the discretion of the Internal Audit Office. 10 3.3 AUDIT REPORT DISTRIBUTION
The normal report distribution will be to the Audit Committee (at the next meeting), the Council and senior program management. Any other programs or other entities identified in the report may be included in the distribution.

3.4 AUDIT FOLLOW-UP
Within twelve months after the issuance of an audit report, the Internal Audit Office shall initiate a follow-up review to determine the extent of actions subsequently taken by management in response to the findings and recommendations included in the report. The distribution of the follow-up report shall be the same as that of the original report.

3.5 RECORDS DISPOSITION
The Internal Audit Office shall retain for the required number of years a complete file of each audit report and each report of other examinations, investigations, surveys and reviews made under its authority in accordance with any applicable Federal and/or contract regulations. The file should include audit working papers and other supportive material directly pertaining to the report. Files which contain confidential personnel information will be kept secure for a period of five years.

4. WHISTLEBLOWER POLICY
This policy governs reporting and investigation of allegations of suspected improper accounting activities.

Acts of fraud, waste, and abuse are considered a deliberate act or failure to act with the intention of obtaining an unauthorized benefit. Examples of such conduct include, but are not limited to:
• Forgery or alteration of documents;
• Unauthorized alteration or manipulation of computer files; • Fraudulent financial reporting;
• Pursuit of a benefit or advantage in violation of City’s Policies and Procedures; • Misappropriation or misuse of City’s resources, such as funds, supplies, or other assets; • Authorizing or receiving compensation for goods not received or services not performed; and • Authorizing or receiving compensation for hours not worked

4.1 OBJECTIVE
City of Compton is committed to operating in compliance with all applicable laws, rules and regulations, including those concerning accounting and auditing, and prohibits fraudulent practices by any of its Council members, officers, or employees. This policy serves to outline procedures for employees to report actions that an employee reasonably believes violate a law or regulation or that constitutes fraud. This policy applies to any matter which is related to City of Compton business. In addition, it is the objective of the City of Compton to establish a policy that protects any person reporting organizational wrongdoing, from retaliation, harassment, or adverse employment consequences.
11 4.2 REPORTING AND RESPONSIBILITY
Each employee of the City has an obligation to report in accordance with this Whistleblower Policy any act believed to violate a law or regulation or constitute fraud.

4.3 ACTING IN GOOD FAITH
Anyone reporting a concern must act in good faith and have reasonable grounds for believing the information reported indicates a violation of the law, or constitutes an inappropriate accounting or financial practice. The act of making allegations that prove to be unsubstantiated, and that prove to have been made maliciously, recklessly, or with the foreknowledge that the allegations are false, will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment.

4.4 REPORTING CONCERNS
City of Compton employees with any concerns or information pertaining to fraud, waste, or abuse are encouraged to anonymously speak with someone at the City’s Fraud Hotline or speak with someone in Internal Audit or Human Resources.

4.5 HANDLING OF REPORTED VIOLATIONS
All reports will be addressed and investigated by Internal Audit or City appointed personnel. Appropriate corrective action will be recommended to the City Council through the Audit Committee, if warranted by the investigation.

4.6 NO RETALIATION
The Whistleblower Policy is intended to encourage and enable employees to raise concerns within the organization for investigation and appropriate action. With this goal in mind, no employee who, in good faith, reports a concern shall be subject to retaliation or adverse employment consequences related to whistleblower complaints. Moreover, an employee who retaliates against someone who has reported a concern in good faith is subject to discipline up to and including termination of employment.

4.7 CONFIDENTIALITY
All reports on concerns, and investigations pertaining thereto, shall be kept confidential to the extent practical. Disclosure of reports of concerns to individuals not involved in the investigation will be viewed as a serious disciplinary offense and may result in discipline, up to and including termination of employment. 12 5. SPECIFIC AUDIT PROCEDURES

5.1 COMPLIANCE AUDITS
Internal Audit staff will perform examinations of programs and test compliance with terms, provisions, and requirements of grant agreements. The frequency of conducting program audits will be based upon adequacy of staffing, time, and resources. Formal steps listed in Policy and Procedures 3.1-3.5 are followed.

The review of programs ensures that:
• Programs are operating efficiently
• Programs have sufficient controls in place to prevent fraud, abuse or waste. • Program reports are completed accurately and timely
• Grant expenditures are allowable, allocable, and reasonable • Participants/client files are completed accurately and timely • Federal Grants comply with OMB A-133 compliance requirements.

5.2 PERFORMANCE REVIEWS
Bank Reconciliations
Frequency: Quarterly
Bank reconciliations are completed monthly by the Controller’s Office to ensure that no material differences between the bank balance and the general ledger balance exist. The Internal Audit Office will review the bank reconciliations quarterly to ensure that:
• Variances are reasonable
• Reconciliations are completed in a timely manner
• Balances reflected on the reconciliations are accurate Additionally, any unusual or material reconciling items will be investigated; reconciling items should be traced to supporting documentation. Explanations of these types of items must be reasonable and complete.

Payroll Timesheet Review
Frequency: Reviews are completed every pay period, and each department is reviewed at least once each quarter.

Each pay period, two to three department timesheets are selected for review. Timesheets are reviewed for:
• Accuracy of hours calculated
• Appropriate signatures (employee, management, etc.)
• Agreement to the Employer Contribution Reports (ECR) and MOUS’ All exceptions should be tagged and reported to Payroll. 13 Payroll Review
Frequency: Annually or as needed
A review of payroll should be completed annually, provided that there is adequate staffing, time and resources. Formal steps listed above in this Policy number 3.1 to 3.5 are followed.

The review of payroll includes audits of the following areas:
• The proper functioning of payroll and personnel processes and operations • Calculation of earnings, special payments, employee benefits and employee taxes • Compliance with applicable federal/state laws relating to employment taxes, tax and non-tax reporting requirements
• Accounting for payroll transactions (properly classified and posted to GL) Mileage Review
Frequency: A reasonable number of mileage payment documentation are haphazardly selected and reviewed quarterly. Mileage and expenses calculated are traced from the mileage sheet and agreed to the GL. The bases of mileage payment calculation is reviewed to ensure legality and accuracy. There may be re-computation of the mileage and the reason for such expenses should be obtained. The outcome should be reported to the City Controller.

AP Check Review
Frequency: Weekly
All checks over $25,000 are reviewed, and an additional 25 checks are haphazardly selected for review.

Checks are reviewed to ensure the following:
• All checks greater than $25,000 have all required signature • All checks on the check listing are accounted for
• Proper support is attached as backup for each check. Support includes invoices, contract agreements, bids, etc.
• Receipt of goods or performance is indicated
All exceptions should be tagged and reported to the City Controller.

AP EFT Review
Frequency: Every other week
All EFTs over $25,000 are reviewed, and an additional 25 EFTs are haphazardly selected for review. EFTs are reviewed to ensure the following:
• Proper support is attached as backup for each EFT. Support includes invoices, contract agreements, bids, etc. 14 • Receipt of goods or performance is indicated
• Vendor name on the EFT agrees to the attached EFT backup • Account and Project coding are appropriate
• Invoices/contracts are authorized by appropriate individuals, and the invoice/contract amount is within the authorized signer’s limit
All exceptions should be tagged and reported to the City Controller.

Fixed Assets Inventory
Frequency: Every other year
Once every two years, all fixed assets should be observed. The observation ensures that recorded assets exist, that fixed assets which have been disposed of get removed from the system and that any unrecorded assets get entered into the fixed asset system.

The Internal Audit Office will obtain the fixed asset inventory listing from financial system prior to observing fixed assets. The fixed asset inventory list includes information about the fixed assets such as location, description, tag number, date of acquisition, cost and last date of observation. The location, description and tag number on the inventory list is then matched to the physical asset, and any differences are noted.

After an asset is observed, the fixed asset system is updated to reflect this. The auditor will enter into the accounting system the date and location where the asset was observed. Additionally, any changes to fixed assets will be updated in the accounting system at this time, such as a change in location. For any assets that cannot be observed/located, a follow-up review and inquiry should be performed to determine if there is a reasonable explanation for the lack of observation, such as disposal of the asset. Any findings will be reported in a memo to the City Controller
Accounts Payable Review
Frequency: Annually or as needed
A review of accounts payable should be completed annually, provided that there is adequate staffing, time and resources. Formal steps listed in this Policy and Procedures Manual #3:1-.5 shown above are followed.

The review of accounts payable includes audits of the following areas:
• Determine if adequate controls exist to provide reasonable assurance that payments cannot be made to an incorrect vendor
• Determine if adequate controls exist to provide reasonable assurance that payment of invoices are made in a timely manner to the vendor
• Determine if adequate controls exist to provide reasonable assurance that correct payment is made to the vendor
15 • Determine if adequate controls exist to provide reasonable assurance that duplicate payments cannot be made to the vendor
Accounts Payable New Vendor Review
Frequency: Twice a year
A review of the AP New Vendor process should be completed twice a year. The set up process of new vendors and related internal controls is reviewed. The review ensures that appropriate documentation is obtained for each new vendor and that only authorized personnel have the ability to set up/delete/edit vendors in the system.

Working papers are completed in order to record the processes and documents that are reviewed.

Information Systems Audits
The Internal Audit Office may conduct information systems audits, which determine whether existing or new computer applications and hardware function in an accurate and efficient manner, and include adequate internal controls. These audits could include reviews of general controls which affect all computer applications. Examples include computer security, disaster recovery, program change controls and quality control procedures.

5.3 UNANNOUNCED AUDITS
Petty Cash Review
Frequency: Twice a year
A review of petty cash is performed twice a year for all custodians having a balance of $100 or more in petty cash. The petty cash review consists of counting cash and ensuring that receipts are retained and expenditures are appropriate. In addition to counting and documenting the amount of petty cash, the internal auditor will keep a record of all receipts on hand making sure to include the amount, date and location where the petty cash was spent. After the petty cash form is filled out completely, signatures from both the internal auditor and custodian are required.

After all petty cash counts are completed, the petty cash forms are reviewed for any significant findings.

Findings include a large variance between the cash counted and the amount recorded in the general ledger, missing receipts, cash not being kept in a secure location or any other item the internal auditor deems significant. Any findings are reported in a memo directed to the City Controller.

5.4 EXTERNAL AUDIT ASSISTANCE
Program-Specific Audits (CDBG, Home, DOJ, LHA etc.)
Frequency: Annually
Internal Audit will provide assistance to the external auditors conducting the annual program-specific audits.

This assistance includes performing account analysis and maintaining working papers. 16 The Internal Audit Office may be responsible for any of the following:
• Reviewing participant files for completeness and accuracy • Gathering fixed asset information
• Gathering documentation requested by the external auditor • Reviewing External Audit Program-Specific Audit Drafts Single-Audit Schedules
Frequency: Annually
Internal Audit will provide assistance to the external auditors conducting the annual Single Audit (OMB A133). This assistance includes performing account analysis and maintaining working papers.

The Internal Audit Office may be responsible for any of the following:
• Review and analyze program abstracts provided by the Controller’s Office • Prepare the Schedule of Federal Awards
• Prepare Debt Covenant Testing (if needed)
• Prepare Debt Service Coverage Ratio (if needed)
• Prepare and analyze account schedules
• Prepare the Schedule of Rents
• Prepare the Accounts Receivable Analysis
• Prepare the Account Confirmation Letters
• Prepare Fixed Asset Roll forward report
• Gather documentation requested by the external auditor • Prepare the Federal Audit Clearinghouse form SF-SAC for submission • Review External Auditor’s Single Audit Draft
• Prepare the distribution list for the Single Audit
The Internal Audit Office plans to develop additional audit procedures in the future based upon organizational needs, management requests and workload of the Internal Audit Office. All additional procedures will be added to Section 5. Furthermore, Internal Audit reserves the right to update any of the specific audit procedures (included in Sec. 5) as needed.

6. INTERNAL AUDIT OFFICE REPORTING STRUCTURE

6.1 The Internal Auditor shall report administratively to the Audit Committee, and functionally to the City Controller and Audit Committee. In addition, the Internal Audit Office shall have the support of senior management. (GAGAS 3.57; IIA 1110, 1130)

6.2 Functional reporting to the City Controller and Audit Committee helps assure Internal Audit’s independence, authority, ensures broad audit coverage, adequate communication, and appropriate engagement recommendations (GAGAS 3.20, 8.26; IIA 1130). The Audit Committee duties shall include:
• Approval of the City of Compton Internal Audit Policy and Procedure. (IIA 1000) • Approval of the internal audit risk assessment and related audit plan. 17 • Meet with the Internal Auditor without the presence of management. The Internal Auditor shall have open and direct access to the Audit Committee and regularly attend committee meetings (IIA 1111). • Inquire of management and the Internal Auditor to determine if there are budgetary or scope limitations that may impede the Internal Audit Office’s ability to execute their responsibilities (IIA 1110).

7.0 HOW INTERNAL AUDIT OFFICE SELECTS AREAS TO AUDIT
The Internal Audit Office uses different methods in determining which areas to audit. Audit engagements are primarily chosen based on the annual risk assessment, which results in the annual audit plan. Information is gathered throughout the year by the Internal Auditor to help conduct the risk assessment. Additionally, the Internal Auditor conducts interviews with senior management and other stakeholders in order to help identify and consider their expectations when developing the annual risk-based audit plan (IIA 2010.A2).

Contingency audit hours are available to conduct special projects assigned by the City Manager and/or Financial Oversight and Audit Committee, which may include fraud investigations (IIA 2010.C1).

7.1 Selection Based On Risk Assessment
The primary method of selecting an area to audit is by performing a risk assessment. A risk assessment uses several risk criteria to evaluate risk. Examples of criteria include; management interest; financial impact, length of time since the department’s last audit; and changes within the department. The potential audit areas are scored using the criteria. The areas with the highest score are ranked as the greatest risk potential. These areas are given the highest priority when generating the annual audit plan. The Risk Areas are: Management Interest, High Level Decentralization, Legal Claims, Strategic Risk, Compliance Risk, Budget Risk, Reputation Risk, Time Last Audited, and Change in Management. See attachment “A” Risk Assessment for an example (IIA 2010).

7.2 Annual Audit Plan
Internal Audit Plan is the list of Audit engagements to be conducted each fiscal year to ensure efficient and effective conduct of the audit. Each fiscal year Internal Audit Office prepares the annual audit plan and presents it to the Audit Committee and Executive Management for approval. The Annual Audit Plan identifies audit projects for the year. It also outlines the resources in staff and time required for each project.

The Internal Auditor must review and adjust the plan, as necessary, in response to changes in the City risk, operations, programs, systems, and controls (IIA 2010). The Annual Audit Plan may be amended during the fiscal year for requested audits, projects, or changes in priorities. Internal Audit plan should include certain common elements:

Define the audit universe (by division, location department, grants etc.) Conduct a risk assessment
Prioritize audits based on risk assessment
Determine available resources to conduct the audit
Prepare the audit plan for the define period
Assign resources for engagement planning
18 7.3 Special Projects
On occasion, the Internal Audit Office will deviate from the Annual Audit Plan schedule to work on special projects that require immediate attention, for example fraud, areas of special interest to management, and consulting engagements. The auditor should consider accepting proposed engagements based on engagement’s potential to improve management of risk, add value, and improve the City’s operation (2010.C1).

7.4 Non-audit Services
Non-audit (also known as consulting or advisory) are advisory in nature and are generally performed at the specific request of an engagement client. The nature and scope of the consulting engagement are subject to agreement with the client. The agreed upon scope will be documented in an Engagement Letter or in a documented meeting memo.

Non-audit services may be accepted dependent upon availability of resources and impact to the completion of the audit plan. The Internal Auditor should consider accepting proposed consulting engagements based on the engagement’s potential to improve management of risks, add value, and improve the organization’s operations (IIA 2010.C1). Those engagements that have been accepted must be included in the plan under Contingency Hours. Non-audit services must not be done as a substitute to completing an audit listed in the Audit Plan.

If internal auditors have potential impairments to independence or objectivity relating to proposed non-audit services, disclosure must be made to the engagement client prior to accepting the engagement. (GAGAS

3.83, 5.10; IIA 1130.C2)
In determining whether providing a non-audit service would create a threat to independence, the auditor should determine that the audited entity has designated an individual who possesses suitable skill, knowledge, or experience, and that the individual understands the services to be performed sufficiently to oversee them. The auditor should document consideration of management’s ability to effectively oversee non-audit services to be performed (GAGAS 3.73) by utilizing the Auditor’s Objectivity Statement for (The auditor shall perform a balanced assessment of all relevant circumstances) The Internal Auditor must decline the non-audit services or obtain competent advice and assistance if the internal audit staff lacks the knowledge, skills, or other competencies needed to perform all or part of the engagement. (IIA 1210.C1).

7.5 There are three types of non-audit services:
1) Services that impair independence – the Internal Audit Office must not engage in any of the activities:
19 • Maintaining or preparing the audited entity’s records; • Posting transactions to the entity’s financial records; • Determining account balances or capitalization criteria; • Providing payroll services that are subject to audit and /or involve in making management decisions.
• Designing, developing, installing, or operating the entity’s accounting or information Systems.
• Developing an entity’s performance measurements system when the system is material or significant to the audit.
• Developing an entity’s policies, procedures, and internal controls. • Carrying out internal audit functions when performed by external auditors; and • Sit on the source selection as a voting member.
2) Services that do not impair independence:

When providing non-audit services, the Internal Audit Office must evaluate whether providing non-audit services creates independence impairment either in fact or appearance with respect to the entities they audit, by applying the following overarching principles:
• The Internal Audit Office must not provide non-audit services that involve performing management functions or making management decisions Internal Auditor’s function is to assist management in establishing or improving risk management processes, and must refrain from assuming any management responsibility by actually managing risk(GAGAS 3.76; IIA 2120.C3); and • The Internal Audit Office must not audit their own work, therefore, the non-audit services must not produce something that would need to be audited in the future. The Internal Audit Office must not provide non-audit services in situations where the non-audit services are significant to the subject matter of audits. An independence evaluation must be documented in all non-audit services project files. (GAGAS 3.83) 3) Services that will not impair independence if safeguards are used:

The following non-audit services can be provided by the Internal Audit Office staff as long as the Internal Audit Office complies with the supplemental safeguards (GAGAS 3.84). • Basic accounting assistance;
• Limited payroll services;
• Advisory services on Information Technology;
• Assist in evaluating potential candidates (panel of at least three); • Preparing routine tax filings based on information provided by the entity; and • Can participate as a non-voting member in an advisory role but not as a voting member.

For allowable non-audit services, the following safeguards must be complied with (GAGAS 3.86, 3.107). a) Document that the overarching independence principles have not been violated; 20 b) Establish an understanding with the auditee regarding objectives, scope of work, product or deliverables and management’s responsibility for (1) the subject matter of the non-audit services, (2) the substantive outcome of the work, and (3) making any decisions that involve management functions related to non-audit service and accepting full responsibility for such decision (GAGAS 3.77, 3.98; IIA 2201.C1). c) Do not reduce the scope and extent of the audit work below the level that would be appropriate.

Non-audit services project requirements:

For all non-audit services, auditors must:
• Address risk, controls, consistent with engagement’s objectives and be alert to the existence of other significant risks, and control issues (GAGAS 3.116; IIA 2120.C1, 2220.C2); • Ensure that the scope of the engagement is sufficient to address the agreed-upon objectives. If internal auditors develop reservations about the scope during the engagement, these reservations must be discussed with the client to determine whether to continue with the engagement (IIA 2220.C1); • Consider needs and expectations of clients, including the nature, timing and communication of engagement results (IIA 1220.C1);
• Consider relative complexity and extent of work needed to achieve the engagement’s objectives; and • Consider cost of the consulting engagement in relation to potential benefits (IIA 1220.C1). • Incorporate knowledge of risk gained from consulting engagement into their evaluation of the organization’s risk management processes (IIA 2120.C2); • Incorporate knowledge of controls gained from consulting engagements into evaluation of the organization’s control processes (IIA 2130.C1);
• Evaluate possible management participation threats that could impair independence and any applied safeguards (GAGAS 3.98).

For all non-audit services, auditors must:
• Address risk, controls, consistent with engagement’s objectives and be alert to the existence of other significant risks, and control issues (GAGAS 3.116; IIA 2120.C1, 2220.C2) • Ensure that the scope of the engagement is sufficient to address the agreed-upon objectives. If internal auditors develop reservations about the scope during the engagement, these reservations must be discussed with the client to determine whether to continue with the engagement (IIA 2220.C1) • Consider needs and expectations of clients, including the nature, timing and communication of engagement results (IIA 1220.C1).
• Consider relative complexity and extent of work needed to achieve the engagement’s objectives; and • Consider cost of the consulting engagement in relation to potential benefits (IIA 1220.C1). • Incorporate knowledge of risk gained from consulting engagement into their evaluation of the organization’s risk management processes (IIA 2120.C2). • Incorporate knowledge of controls gained from consulting engagements into evaluation of the organization’s control processes (IIA 2130.C1).
• Evaluate possible management participation threats that could impair independence and any applied safeguards (GAGAS 3.98).
21 Non-audit services objectives must:
• Be consistent with the organization’s values, strategies, and objectives (IIA 2210.C2). • Address governance, risk management, and control processes to the extent agreed upon with the client (GAGAS 3.76; IIA 2210.C1).

Work programs for non-audit services may vary in form and content depending upon the nature of the engagement. (IIA 2240.C1
The Internal Audit Office must monitor the disposition of consulting results to the extent agreed upon with the client (IIA 2500.C1). Communication of the progress and results may vary in form and content depending upon the nature of the engagement (GAGAS 6.48; IIA 2410.C1). The Internal Auditor is responsible for communicating the final results of the consulting engagements to clients (IIA 2440.C1). During engagements, governance, risk management, and control issues may be identified. Whenever these issues are significant to the organization, they must be communicated to senior management and the Audit Committee (IIA 2440.C2).

8.0 FRAUD
Internal Auditors must have sufficient knowledge to evaluate the risk of fraud and the manner in which it is managed by the organization, but are not expected to have the expertise of a person whose primary responsibility is detecting and investigating fraud (IIA 1210.A2). If during the course of performing an engagement, significant deficiencies; material weaknesses; instances of fraud, noncompliance with provisions of laws, regulations, contracts, or grant agreements; or abuse come to the auditors’ attention that warrant the attention of those charged with governance, auditors should communicate such matters to the Chief Internal Auditor (GAGAS 8.25). The Internal Auditor will contact the City Manager, appropriate senior management members, and applicable external parties to determine whether an audit or investigation in the suspected areas of wrongdoing is appropriate. (GAGAS 9.45).

8.1 Characteristics of Fraud
Fraud encompasses an array of irregularities and illegal acts characterized by intentional deception. It can be perpetrated for the benefit of, or to the detriment of, the organization; and by persons outside as well as inside the organization.

Periodic audit training, distribution of audit publications, and other communication methods are in place to apprise auditors of the nature of fraud and the control environment in which fraud may occur.

Fraud designed to benefit the organization generally produces benefit by exploiting an unfair or dishonest advantage that also may deceive an outside party. Perpetrators of such frauds usually benefit indirectly, since the personal benefit usually accrues when the organization is aided by the act. 22 Audit activities are specifically designed in a manner, which provides review of the control environment and the inherent potential for fraud. Audit risk analysis and audit selection is based on the degree of change and "pressure" in operating units. Where appropriate, financial and operating systems are tied to related accounting and reporting information to validate propriety.

8.2 Fraud Examples and Related Audit Activity
 Sale or assignment of fictitious or misrepresented assets.

Asset audits include steps to validate asset accounting and evaluate the propriety of asset purchases, transfers and disposals.
 Improper payments such as illegal political contributions, bribes, kickbacks, and payoffs to government officials, intermediaries of government officials, customers, or suppliers.

Certain audits (e.g., purchasing) review control environments in order to detect unwarranted potential for personal benefit. Government compliance reviews includes specific control steps to evaluate potential illegal relationships and payments.  Intentional, improper misrepresentation or valuation of transactions, assets, liabilities, or income.

Revenue cycle, disbursement cycle, and asset audits include validation steps for proper valuation and recognition.
 Intentional, improper transfer pricing (e.g., valuation of goods exchanged between related entities or departments). By purposely structuring pricing techniques improperly, management can improve the operating results of an organization involved in the transaction to the detriment of the other organization.

The audit will include analysis of inter-fund accounting and pricing. Certain government compliance audits may also focus on the propriety of costs for inter-fund or inter departmental transfers.
 Intentional, improper related party transactions in which one party receives some benefit not obtainable in an "arm's length" transaction.

Organization control review steps in audits may be concerned with related party risk. When a specific concern is identified, audit or investigation work may be performed.  Intentional failure to record or disclose significant information to improve the financial picture of the organization to outside parties.
23 External reporting practices are reviewed in detail by the external auditors, and internal auditors may assist in the year-end close external audit to support this objective. Validating the integrity of accounting and financial reporting accuracy are common program steps in audits.  Prohibited business activities such as those which violate government statutes, rules, regulations or contracts.

Government compliance audits and reviews evaluate preventative and detective controls and related compliance under applicable laws, regulations, rules, and contracts.  Fraud perpetrated to the detriment of the organization generally is for the direct or indirect benefit of an employee, outside individual, or another firm. Some examples are:

Acceptance of bribes or kickbacks.

Diversion to an employee or outsider of a potentially profitable transaction that would normally generate profits for the organization.

Embezzlement, as typified by the misappropriation of money or property, and falsification of financial records to cover up the act, thus making detection difficult.

Intentional concealment or misrepresentation of events or data. Claims submitted for services or goods not actually provided to the organization.

Auditors will receive periodic training in the area of fraud indicators and related methods, and all auditors should remain aware of the potential for fraud in all of the noted areas such as bribes, kickbacks, diversion, embezzlement, concealment and misrepresentation. System reviews in the core business cycles (revenue, disbursement, conversion/inventory/cost, payroll/benefits, and capital assets) will evaluate the overall control environment and related potential for fraudulent actions to take place. When a specific concern is identified from the normal audit process or by an employee or management concern, auditors may become involved in audit or investigative work in these areas (IIA 1210.A2).

8.3 Fraud Deterrence
Deterrence consists of those actions taken to discourage the perpetration of fraud and limit the exposure if fraud does occur. The principal mechanism for deterring fraud is control. Management is responsible for the maintenance of an effective control environment. Auditors are tasked to evaluate the control environment at audited locations to determine the adequacy of internal control in selected systems.

Internal auditing is responsible for assisting in the deterrence of fraud by examining and evaluating the adequacy and the effectiveness of controls, commensurate with the extent of potential exposure/risk in the various segments of the entity's operations (IIA 2120.A2). In carrying out this responsibility, internal auditing should, for example, determine whether:
24 - The organizational environment fosters control consciousness.

The organizational environment is considered along with other appropriate factors in the risk analysis process leading to audit selection and audit program development. - Realistic organizational goals and objectives are set.

Audit actions such as system reviews evaluate the adequacy of the total system of the internal controls including review of strategic plans, annual plans, and quarterly budgets. - Written corporate policies (e.g., code of conduct) exist that describe prohibited activities and the action required whenever violations are discovered.

Certain audits include evaluation of location practices and supporting controls versus established Standards of Business Conduct.
- Appropriate authorization policies for transactions are established.

Authorization practices are commonly audited including procedure reviews, management interviewing to determine authorization expectations and detailed compliance testing to determine authorization compliance.
- Policies, practices, procedures, reports and other mechanisms are developed to monitor activities and safeguard assets, particularly in high-risk areas.

Audit objectives commonly include adequacy and compliance reviews of policies, procedures, reports and monitoring activities. Asset safeguarding practices are evaluated in normal internal control review and during asset audits.
- Communication channels provide management with adequate and reliable information.

Two-way communication and reporting is commonly evaluated, and certain information system audits include tests for information adequacy and usefulness. - Recommendations need to be made for the establishment or enhancement of cost-effective controls to help deter fraud.

Whenever appropriate, potential risk/impact/effect statements in audit reports highlight irregularity risks. All recommendations are written with cost justification in mind. Often the audit client is contacted to establish cost/benefit impacts.

8.4 Fraud Detection
25 Detection consists of identifying indicators of fraud sufficient to warrant recommending an investigation.

These indicators may arise as a result of controls established by management, tests conducted by auditors, and other sources both within and outside the organization. Auditors should:
 Have sufficient knowledge of fraud to be able to identify indicators that fraud might have been committed. This knowledge includes the characteristics of fraud, the techniques used to commit fraud, and the types of frauds associated with the activities audited.  Be alert to opportunities, such as control weaknesses, that could allow fraud. If significant control weaknesses are detected, additional tests conducted by internal auditors should include tests directed toward identification of fraud indicators with the concurrence of the CAE (IIA 2120.C1).

If significant control weaknesses are detected, additional tests may be performed to identify other indicators of fraud (GAGAS 8.72). All audit and investigation activity will be carefully coordinated with the approval/involvement of the City Attorney’s Office and Law Enforcement as appropriate.

The Internal Auditors will review potential fraud indicators derived from fieldwork or from employee or management contact, and work with the City Manager and/or City Attorney’s Office to determine if investigative or further audit work is appropriate by members of the Internal Audit Office. - Internal auditors are not expected to have knowledge equivalent to that of a person whose primary responsibility is detecting and investigating fraud. Also, audit procedures alone, even when carried out with due professional care, do not guarantee that fraud will be detected.

8.5 Fraud Investigation
Avoiding interference with investigations or legal proceedings is important in pursuing indications of fraud, noncompliance with provisions of laws, regulations, contracts, or grant agreements, or abuse. Laws, regulations, or policies may require auditors to report indications of certain types of fraud, noncompliance with provisions of laws, regulations, contracts, or grant agreements, or abuse to law enforcement or investigatory authorities before performing additional audit procedures. When investigations or legal proceedings are initiated or in process, auditors should evaluate the impact on the current examination engagement. In some cases, it may be appropriate for the auditors to work with investigators or legal authorities, or withdraw from or defer further work on the examination engagement or a portion of the examination engagement to avoid interfering with an ongoing investigation or legal proceeding. (GAGAS

8.28, 8.29)
Investigation consists of performing extended auditing procedures necessary to determine whether fraud, as suggested by the indicators, has occurred. It includes gathering sufficient evidential matter about the specific details of a discovered fraud. Internal auditors, lawyers, investigators, security personnel, and other specialists from inside or outside the City are the parties that usually conduct or participate in fraud investigations.
26 When an investigation is deemed necessary, Internal Auditor will confer with the City Manager and Audit Committee leading to a decision as to the appropriate mix of internal or external resources to complete the investigation based on required expertise or competency.

Auditors involved in a fraud investigation assess the probable level and the extent of fraud within the City to help ensure auditors avoid providing information to, or obtaining misleading information from, persons who may be involved. If it is determined that internal auditors will be involved in an investigation, the Internal Auditor determines the knowledge, skills, and disciplines needed to effectively carry out the investigation. It is most common for the Internal Auditor or a Supervisor or Manager to be personally involved in the investigation to help assure the most effective and professional results. Outside resources may be used in an internal investigation.

The Internal Audit Office will coordinate its activities internally and with other components of the City to assure effective and efficient use of available resources.

A written program will be used to detail carefully designed procedures to attempt to identify the perpetrators, extent, techniques, and cause of fraud.

Auditors involved in the investigations must be cognizant of the rights of alleged perpetrators and personnel within the scope of the investigation and the reputation of the City itself.

Once a fraud investigation is concluded, Internal Audit assesses the facts in order to:
- Determine if controls need to be implemented or strengthened to reduce future vulnerability. - Help meet the internal auditor's responsibility to maintain sufficient knowledge of fraud and thereby be able to identify future indicators of fraud.

8.6 Reporting Fraud
If the Internal Audit Office receives a credible allegation or other evidence of a significant and immediate danger to the health or safety of people or property, the Internal Audit Office will inform appropriate individuals as soon as possible, consistent with confidentiality requirements. The form, nature, and timing of appropriate fraud investigation communication to City Controller and external parties will be predetermined by the Internal Auditor.

A preliminary or final report may be drafted at the conclusion of the detection phase. The report should include the Internal Auditor's conclusion as to whether sufficient information exists to conduct an investigation. It should also summarize findings that serve as the basis for such decision.

When the incidence of significant fraud has been established to a reasonable certainty, the City Manager will be notified immediately.

If fraud investigation results are determined to materially affect the reported financial statement results, the Internal Auditor will advise the City Controller. Significant misstatements would be included in the category of important control issues communicated to top management as appropriate. 27 Written reports are issued to communicate the results of Internal Audit involvement in the investigation phase. It will include findings, conclusions, recommendations and, where appropriate, corrective action taken.

If management fails to satisfy legal or regulatory requirements to report such information to external parties specified in law or regulation, the Internal Audit Office will first communicate the failure to report such information to the Audit Committee. If the audited entity still does not report this information to the specified external parties as soon as practicable after the auditors’ communication with the Audit Committee, then the Internal Audit Office will report the information directly to the specified external parties. (GAGAS 9.45a).

If management fails to take timely and appropriate steps to respond to known or likely fraud, noncompliance with provisions of laws, regulations, contracts, or grant agreements, or abuse that (1) is likely to have a material effect on the subject matter or an assertion about the subject matter and (2) involves funding received directly or indirectly from a government agency, auditors should first report management’s failure to take timely and appropriate steps to the Audit Committee. If the City still does not take timely and appropriate steps as soon as practicable after the auditors’ communication with the Audit Committee, then the auditors should report the entity’s failure to take timely and appropriate steps directly to the funding agency. (GAGAS 9.45b)

CITY OF COMPTON

FRAUD POLICY
pg. 2
SEPTEMBER 27, 2023
pg. 1
Table of Contents
1 Audit Committee Organizational Chart
2 Introduction
2 Purpose
3 Audit Committee
3 Definitions
4 Scope
5 Examples of Fraudulent Behavior
6 Responsibility
9 Procedures for Reporting Suspected Wrong Doing
10 Investigation and Action
11 Fraud, Waste and Abuse Hotline
12 Appendix A – Types of Fraud
pg. 2

ORGANIZATIONAL CHART FOR FRAUD AND INVESTIGATION REPORTING

CITY COUNCIL

AUDIT COMMITTEE
AUDIT COMMITTEE MEMBERS SELECTED PER RESOLUTION NUMBER 25,220

COUNCIL PERSON COUNCIL PERSON ALTERNATE MEMBER

CITY MANAGER CITY CONTROLLER RESIDENT MEMBER

INTERNAL

AUDITOR
LAW

ENFORCEMENT AGENCY

FRAUD HOTLINE

FRAUD INVESTIGATOR

EMPLOYEES

CITY MANAGER CITY ATTORNEY

HEAD OF DEPARTMENTS
pg. 3
Introduction:

City of Compton (“City”) is committed to protecting its assets against risk of loss or misuse. The City upholds a zero-tolerance approach regarding fraud and corruption. The City will identify and promptly investigate any suspected fraudulent or related dishonest activity. The City will take appropriate disciplinary and legal actions to include the possibility of termination of employment, restitution, and forwarding information to the appropriate authorities for prosecution. Any allegations of fraud will be taken seriously, with no exceptions. All individuals, regardless of position, title, or tenure with the City of Compton are expected to remain vigilant and report any suspicious activity to the City Fraud Hotline. This policy is required to raise awareness of fraud within the City of Compton, to define roles and responsibilities for detecting and preventing fraud, to reinforce personal responsibility and accountability, to detail the procedures for reporting and investigating suspected fraud, and to better understand the limitations in existing control procedures that allow fraud to occur.

Purpose
The purpose of this policy is to promote a culture founded on fraud prevention, awareness, and accountability, and clarify acts that are considered to be suspicious. The policy supports a culture of operating within a comprehensive framework of internal controls, complete with documented and formalized policies, procedures, processes, and other supporting safeguards as needed. The policy provides guidance to prevent, detect, report, and investigate fraud when fraudulent acts are suspected and subsequently proven. An organizational fraud risk management policy defines fraudulent behavior, establishes that fraudulent behavior is unacceptable, helps safeguard City resources through improved management of fraud risk, and provides guidelines for the development, implementation, and monitoring of internal controls that aid in the detection and prevention of fraud. This policy delineates management’s responsibility for instituting and maintaining a system of internal control to prevent and detect fraud, misappropriations and other irregularities, and to be alert for any indications of such misconduct.

This policy has been established to ensure employees are aware of the following:

1. The types of acts considered to be fraudulent,

2. Procedures for reporting suspected fraudulent acts,

3. Steps to be taken when fraud or other related dishonest activities are suspected

4. Consequences to expect when a dishonest act is reported.

The impact of misconduct and dishonesty may include:
• The actual financial loss incurred
• Damage to the reputation of the City and its employees • Negative publicity
• The cost of investigation
• Loss of employees
• Loss of customers
pg. 4
• Damaged relationships with our contractors and suppliers • Litigation
• Damaged employee morale
The City’s goal is to establish and maintain a business environment of fairness, ethics and honesty for its employees, customers, suppliers and anyone else with whom the City has a relationship. To maintain such an environment requires the active assistance of every employee and manager every day.

Audit Committee:

On January 31, 2018, the City of Compton received a draft report from the State Controller's Office (SCO) review of the City's administrative and internal accounting controls system for the Fiscal Years (FY) 2013-14, FY 2014-15 and FY 201516. As part of this report, the SCO referenced the Los Angeles County Civil Grand Jury's 2012 report that recommended charter cities within Los Angeles County to establish formal finance and audit committees. The Government Finance Officers Association (GFOA) Best Practices on Audit Committee (2008) makes the following recommendations (in part) regarding the establishment of audit committees by state and local governments.

The audit committee should be formally established by charter, enabling resolution, or other appropriate legal means and made directly responsible for the appointment, compensation, retention, and oversight of the work of any independent accountants engaged for the purpose of preparing or issuing an independent audit report or performing other independent audit, review, or attest services. Likewise, the audit committee should be established in such a manner that all accountants thus engaged report directly to the audit committee. The written documentation establishing the audit committee should prescribe the scope of the committee's responsibilities, as well as its structure, processes, and membership requirements. The audit committee should itself periodically review such documentation, no less than once every five years, to assess its continued adequacy.

Resolution number 25,220 requires that the Audit Ad Hoc Committee consists of two (2) appointed members of the City Council (inclusive of the Mayor), the City Controller, the City Manager and one member/resident from the public. The City's Internal Auditor will serve as the designated staff member liaison and coordinator and will attend the meetings.

Definitions:

1. Fraud - is defined as an intentional deception designed to obtain a benefit or advantage or to cause some benefit that is due to be denied.

2. Waste - is the loss or misuse of City resources that results from deficient practices, system controls, or decisions.
pg. 5

3. Abuse - is the intentional, wrongful, or improper use of resources or misuse of rank, position, or authority that causes the loss or misuse of resources, such as tools, vehicles, computers, copy machines, etc.

4. Theft - is defined as the act of taking something from someone unlawfully.

5. Employee – In this context, employee refers to any individual or group of individuals who receive compensation, either full- or part-time, from the City. The term also includes any volunteer who provides services to the City through an official arrangement with the City or a City organization.

6. Manager or Management – In this context, manager or management refers to any administrator, manager, director, supervisor, or other individual who manages or supervises funds or other resources, including human resources.

7. Fraud Investigator – In this context, Fraud Investigator refers to any person or persons assigned by the Audit Committee to investigate any fraud or similar activity.

8. Internal Auditor – Internal auditor refers to a staff of the City Controller’s Office who may be assigned to investigate any reported act to determine whether in actual fact, a fraudulent act has occurred and advice the Audit Committee for any subsequent action.

9. External Auditor – In this context, External Auditor refers to independent audit professionals who perform annual audits of the City’s financial statements.

10. Retaliation – Unlawful discrimination that occurs when an employee is harassed or suffers an adverse employment action for assisting in an investigation of unlawful or fraudulent employment practices. Also referred to as unlawful retaliation or retaliatory harassment.

Scope
This policy applies to all members of the City workforce, including staff, interns, and temporary employees, independent contractors, appointed commission members and elected officials. This policy also applies to third parties and grant recipients who receive City services or funding. It also applies to volunteers who provides services to the City through an official arrangement with the City or a City department
Management is responsible for the detection and prevention of fraud, misappropriations, and other irregularities. Each member of the management team shall be familiar with the types of improprieties that might occur within their areas of responsibility and be alert for indications of fraud. See Diagram 1 for an overview of fraud detection and prevention processes.

Diagram 1 – Fraud Detection and Prevention Processes
pg. 6
Examples of Fraudulent Behavior
Fraud – Fraud and other similar irregularities include but are not limited to:

1. Disbursement Fraud: This is when a person is paid for fictitious goods or services, inflated invoices, or invoices for personal purchases. Additionally it includes claim for reimbursement of expenses that are not job-related or authorized by the current Purchasing Policy, Travel Policy and/or applicable Administrative policy or governing law.

2. Forgery or unauthorized alteration of documents (checks, promissory notes, time sheets, independent contractor agreements, purchase orders, budgets, etc.).

3. Misappropriation fraud involves stealing cash, or asset (Supplies, Inventory, Equipment or Information) belonging to the City. In many cases the perpetrator tries to conceal the theft usually by adjusting the records.

4. Skimming fraud occurs when cash is stolen from the City before it is recorded in the book of accounts and records. Sometimes with intent to pay it back in the future.

5. Financial Statement fraud involves misrepresentation of the financial statement, often by overstating assets or revenue or understating liabilities or expenses. pg. 7

6. Corruption involves misuse of entrusted power for private gain. Corruption includes bribery and other improper uses of power. It includes embezzlement, favoritism, patronage, nepotism, dishonesty, blackmail, cronyism, etc.

7. Bribery is fraud that involves offering, giving, receiving or soliciting for anything of value to influence an outcome. Bribes may be offered to key employees or managers such as purchasing agents who have discretion in awarding contracts.

8. Expense reimbursement fraud involves payment for fictitious or inflated expenses, authorizing or receiving payment for goods not received or services not performed.

9. Related-party activity involves a situation where benefit is given to a person that is obtainable in a normal arm’s-length transaction.

10.Computer-related activity involving unauthorized alteration, destruction, forgery, or manipulation of data or misappropriation of City-owned software.

11.Any apparent violation of Federal, State, or local laws related to dishonest activities or fraud.

12.Seeking or accepting anything of material value from those doing business with the City including vendors, consultants, contractors, lessees, applicants, and grantees.

Responsibilities:

A. City Council, Council Mayor, and City Counsel Responsibilities:
 If a Council member has reason to suspect that a fraud has occurred, they shall immediately contact the City Manager or Audit Committee, or make a direct report through the Fraud Hotline.
 If it’s a matter that involves the City Manager, the Council should report such matter through the Fraud Hotline.
 The Council shall not attempt to investigate the suspected fraud or discuss the matter with anyone else other than the City Manager or the report through Fraud Hotline respectively.  The alleged fraud or audit investigation shall not be discussed with the media by any person other than through the City Manager in consultation with the City’s Legal Counsel and the Internal Auditor.

B. Management Responsibilities
 According to the City’s Municipal Code section 2-2.7. Powers and Duties. [Added by Ord. #1335, 2-1006 --- 2-1006.12], Section “j.”, it says, “Investigations and Complaints. It shall be the duty of the City Manager to make investigations into the affairs of the City, and any department or division thereof, and any contract or the proper performance of any obligations of the City.”
 Management is responsible for being alert to and reporting fraudulent or related dishonest activities in their areas of responsibility to the City Manager. pg. 8
 Each manager should be familiar with the types of improprieties that might occur in his or her area and be alert for any indication that improper activity, misappropriation, or dishonest activity is or was in existence in his or her area.
 When an improper activity is detected or suspected, management should determine whether an error or mistake has occurred or if there may be dishonest or fraudulent activity.  If management determines that a suspected activity may involve fraud or related dishonest activity, they should alert the City Manager or call the Fraud Hotline.  Management should not attempt to conduct individual investigations, interviews, or interrogations. However, management is responsible for taking appropriate corrective actions to ensure adequate controls exist to prevent reoccurrence of improper actions.  Management should support the City’s responsibilities and cooperate fully with the Internal Auditor/Fraud Investigator, other involved departments, and law enforcement agencies in the detection, reporting, and investigation of criminal acts, including the prosecution of offenders.  Management must give full and unrestricted access to the Fraud Investigator or Internal Auditor for all necessary records and personnel. All City furniture and contents, including desks and computers, shall be open for inspection at any time. There is no assumption of privacy.
 In dealing with suspected dishonest or fraudulent activities, great care must be taken.

Therefore, management should avoid the following:
a. Incorrect accusations.
b. Alerting suspected individuals that an investigation is underway. c. Treating employees unfairly.
d. Making statements that could lead to claims of false accusations or other offenses.  In handling dishonest or fraudulent activities, management has the responsibility to:
i) Make no contact (unless required by law) with the suspected individual to determine facts or demand restitution. Under no circumstances should there be any reference to “what you did”, “the crime”, “the fraud”, “the misappropriation”, etc. ii) Avoid discussing the case, facts, suspicions, or allegations with anyone outside the City, unless specifically directed to do so by the City Attorney. iii) Avoid discussing the case with anyone inside the City other than employees who have a need to know such as the City Manager, Internal Auditor, or City’s Legal Counsel or law enforcement personnel.
iv) Direct all inquiries from the suspected individual, or his or her representative, to the City Manager or City Attorney’s office. All inquiries by an attorney of the suspected individual should be directed to the City Attorney’s office. All inquiries from the media should be directed to the City Manager.
v) Take appropriate corrective and disciplinary action, up to and including dismissal, after consulting with the City Manager, in conformance with the City’s Personnel Policies and Procedures or the appropriate Memorandum of Understanding.

C. Employee Responsibilities
pg. 9
 A suspected non fraudulent incident or practice observed by, or made known to, an employee must be reported to the employee’s supervisor for reporting to the proper management official.  When the employee believes the supervisor may be involved in the inappropriate activity, the employee shall make the report directly to the next higher level of management and/or the City Manager. If the City Manager is suspected then the employee should call the fraud hotline.  The reporting employees shall refrain from further investigation of the incident, confrontation with the alleged violator, or further discussion of the incident with anyone, unless requested by the City Manager, Internal Auditor, City’s Legal Counsel or law enforcement personnel.  Every employee is responsible for reading and obtaining an understanding of this Policy.

Employees uncertain about the application or interpretation of the contents of this Policy should obtain clarification from their immediate supervisor.

D. Internal Auditor Responsibilities
 Upon assignment by the City Manager and/or City Controller and/or Audit Committee, the Internal Auditor or Fraud Investigator will promptly investigate the fraud case. i. Throughout the investigation, the City Manager and the Internal Auditor will inform the Audit Committee of pertinent investigative findings.  In all circumstances where there appears to be reasonable grounds for suspecting that a fraud has taken place, the Internal Auditor, in consultation with the City Attorney, will contact the Police Department.
 The Internal Auditor shall be available and receptive to receiving relevant, confidential information to the extent allowed by law.
 If evidence is uncovered showing possible dishonest or fraudulent activities, the Internal Auditor will proceed as follows:
i. Discuss the findings with City Controller and/or City Manager and the head of the Department.
ii. Advise the City Controller, if the case involves staff members, to meet with the City Manager (or his/her designated representative) to determine if disciplinary actions should be taken.
iii. Report to the External Auditor such activities in order to assess the effect of the illegal activity on the City’s financial statements.
iv. Coordinate with the City’s Risk Management Division regarding notification to insurers and filing of insurance claims.
v. Take immediate action, in consultation with the City Attorney’s office, to prevent the theft, alteration, or destruction of evidentiary records. Such action shall include, but is not limited to:
1 Removing the records and placing them in a secure location or limiting access to the location where the records currently exist.
pg. 10
2 Preventing the individual suspected of committing the fraud from having access to the records.
 In consultation with the City Attorney and the Police Department, the City Manager and/or the Internal Auditor may disclose particulars of the investigation with potential witnesses if such disclosure would further the investigation.
 If the Internal Auditor is contacted by the media regarding an alleged fraud or audit investigation, the Internal Auditor shall direct the requester to the City Manager/City Controller and the City Attorney, as appropriate, and shall not release any information.  At the conclusion of the investigation, the City Manager and/or the Internal Auditor will document the results in a confidential memorandum report to the Audit Committee. If the report concludes that the allegations are founded, the City Attorney’s office will be involved and the report will be forwarded to the Police Department.  Unless exceptional circumstances exist, a person under investigation for fraud is to be given notice in writing of essential particulars of the allegations following the conclusion of the audit. Where notice is given, the person against whom allegations are being made may submit a written explanation to the Audit Committee through the Internal Auditor no later than seven calendar days after notice is received.
 The Internal Auditor will be required to make recommendations to the appropriate department for assistance in the prevention of future similar occurrences.  Upon completion of the investigation, including all legal and personnel actions, all records, documents, and other evidentiary materials, obtained from the department under investigation will be returned by the Internal Auditor to that department.

Procedures for Reporting Workplace Wrong Doing
A. Employees can report wrongdoing in a safe and confidential manner, and without fear of retaliation, as follows:
 If an employee is aware of any acts of wrongdoing, an employee is encouraged to discuss his or her complaint with his or her immediate supervisor.  If an employee is unable to discuss the complaint with his or her immediate supervisor or if his or her immediate supervisor is the source of the problem, condones the problems or ignores the problem, the employee should immediately contact his or her Department Head.  If neither of the above alternatives is satisfactory the employee should immediately contact the Human Resources or the City Manager regarding their complaint.

In no circumstances is an employee required to confront the person who is the source of the complaint before notifying any of the individuals listed above B. Employees will be granted whistle-blower protection when acting in accordance with this policy. When informed of a suspected impropriety, neither the City nor any person acting on pg. 11
behalf of the City shall treat the staff contrary to the provisions of the Workplace Harassment Policy as contained in Policy # (3.13 of 2012): It includes:
 Dismissal or threatening to dismiss the employee reporting the impropriety  Disciplining, suspending, or threatening to discipline or suspend that employee  Impose any penalty upon that employee
 Intimidate or coerce an employee for that employee’s role in reporting the suspected impropriety.
 Instances of fraud, waste or abuse can be reported anonymously and without fear of retribution by using the City of Compton Fraud Hotline.

This section is intended to protect employees from retaliation for reporting suspected improprieties. It shall not be construed as absolving an employee of responsibility for his or her own fraudulent activity; any such fraudulent activity shall be subject to disciplinary and/or legal action. Violations of the whistle-blower protection will result in discipline up to and including dismissal.

Investigation and Action
According to the City’s Municipal Code section 2-2.7. Powers and Duties. [Added by Ord. #1335, 2-1006 --- 2-1006.12], Section “j.”, it says, “Investigations and Complaints. It shall be the duty of the City Manager to make investigations into the affairs of the City, and any department or division thereof, and any contract or the proper performance of any obligations of the City.” The City Controller’s office as stated in the Financial Policies and Procedures Manual Section 3:

Policy 3.4 has the primary obligation of investigating reported incidents of fraud within the City of Compton in accordance with the procedures defined in this policy. All fraud allegations and collected information shall be reviewed by the Internal Auditor to determine if there is adequate “predication” or “probable cause” to proceed with an investigation. The Internal Auditor may conduct the investigation, collaborate with management, other internal or external investigators, and/or City Attorney’s Office, or any other appointed by the Audit Committee and/or City Manager. The City Manager in consultation with the City Attorney may refer the matter to the appropriate law enforcement agency as may be required. The Internal Auditor does not participate in employee disciplinary action which is the responsibility of the City Manager and Human Resources Director in compliance with collective bargaining agreements, contracts and the City’s Code of Conduct.

Conclusions to fraud investigations are supported with evidence that is relevant, reliable and sufficient. Investigators shall be alert to the possibility of conjecture, unsubstantiated opinion and bias of witnesses and others, and shall consider both exculpatory and inculpatory evidence. pg. 12
Professional Ethics makes clear that an investigator’s report may conclude on a person’s conduct; however, conclusions may not include the investigator’s opinion regarding the legal guilt or innocence of any person or party. That determination is made by a judge or jury.

There are four possible outcomes to a fraud investigation: substantiated; unsubstantiated; unsolved; unfounded.
• Substantiated: there is sufficient evidence to conclude that the alleged facts occurred, that these facts could constitute wrongdoing, and that the identified subject committed them. • Unsubstantiated: there is insufficient evidence to conclude whether the alleged facts occurred and/or the facts could constitute wrongdoing, and/or whether the identified subject committed them.
• Unsolved: there is sufficient evidence to conclude that the alleged facts occurred, that the facts could constitute wrongdoing, but the subject did not commit them (i.e. she/he was cleared) or was never identified.
• Unfounded: there is sufficient evidence to conclude that the alleged facts did not occur, or the established facts did not constitute wrongdoing.

Internal control weaknesses, deficiencies or gaps may be identified during a fraud investigation. A minor internal control issue may be included in the investigative report for management’s consideration. A significant internal control matter may result in a new audit issue requiring a management action plan, or an audit around the deficient process may be added to the Audit Plan with the audit committee approval.

Fraud, Waste and Abuse Hotline
The Internal Auditor shall provide the necessary procedures and policies to govern the effective management of the City’s fraud, waste and abuse hotline as passed by City Council. This policy will be updated whenever a new vendor is contracted to provide the service. The anonymous Hotline is presently hosted by Ethico LLC. https://www.Ethico-services.com/cityofcompton.

Hotline matters that are not within the jurisdiction of the Internal Auditor’s Office (such as HR) complaints, or matters under State purview) shall be referred to the appropriate office or investigator. Occasionally the Internal Auditor’s Office through Fraud Hotline receives reports that are not related to fraud allegations, i.e. Human Resources.

Other Fraud Hotline Reports Not Related to Fraud Allegations pg. 13

1. The City Manager will determine how best to investigate the suspected activity; typically, either the Department Head or the HR Manager, or a designated representative, will be assigned to conduct the investigation.

2. At the conclusion of the investigation, the investigator will report to the Department Head, City Manager, and HR Manager.

3. If evidence is uncovered showing possible dishonest or fraudulent activities, the City Manager shall proceed as follows:
a Advise management, if the case involves staff members, to meet with the HR Manager (or his/her designated representative) to determine if disciplinary actions should be taken. b Report to the City Controller such activities in order to assess the effect of the illegal activity on the City’s financial statements.
c Coordinate with the City’s Risk Manager regarding notification to insurers and filing of insurance claims.
d Take immediate action, in consultation with the City Attorney, to prevent the theft, alteration, or destruction of evidentiary records. Such action shall include, but is not limited to:
i. Removing the records and placing them in a secure location or limiting access to the location where the records currently exist.
ii. Preventing the individual suspected of committing the fraud from having access to the records.

4. The City Manager, following review of investigation results, will take appropriate action regarding employee misconduct. Disciplinary action may include referral of the case to the City Attorney’s Office for possible prosecution.

5. The City will pursue every reasonable effort, including court ordered restitution, to obtain recovery of City losses from the offender or other appropriate sources. pg. 14
February 6, 2023
TO: HONORABLE MAYOR AND COUNCIL MEMBERS
FROM: CITY CONTROLLER
SUBJECT: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COMPTON

TO RECEIVE AND FILE INTERNAL CONTROL POLICIES RELATING
TO INTERNAL AUDIT, WHISTLEBLOWER PROTOCOL, AND FRAUD.

SUMMARY
The City Controller’s Department has prepared a policy for Internal Audit operations, Whistleblower protocol and for Fraud to address deficiencies and weaknesses in internal controls surrounding various operations that are performed within various departments of the City.

BACKGROUND:

The Internal Audit Policy, Whistleblower Protocol Policy, and the Fraud Policy which are attached as Exhibit A include (a) provisions for proper separation of duties to avoid conflicts of interest, and (b) provisions for proper procedures to be put in place to ensure that appropriate staff perform their internal audit functions effectively and efficiently. The provisions contained in the policies attached directly address audit findings that the City has received in the past from the State Controller’s Office as well as from its external auditors, Eadie and Payne, LLP.

Additionally, the City’s Standard Operating Manual policies, and other financial policies and procedures currently in place to address these operations were not sufficient and they will be proposed to be appended or replaced with the attached policies. Per our review there were no existing policies that were previously adopted by the City Council that addressed these needs and therefore these do not conflict with already adopted policies on these matters.

Per the City’s FY2020 Single Audit Report, Finding No. 2014-108B is stated as follows:
2014-108B: Policies and Procedures (General Applications) (MW) Recommendation: We recommend that the City continue to review and update its Administrative Policies and Procedures manuals to ensure consistency with current processes and organizational structure; and perform periodic and ongoing reviews to Staff Report – Resolution Receive and
File Internal Control Policies
February 6, 2023, Page 2 of 3
ensure proper documentation, accuracy, and completeness in its financial transactions and records. When completed, the updated Administrative Policies and Procedures manuals should be readily available to all responsible employees. The manuals should clearly state the authority and responsibility of all employees, especially the authority to authorize transactions and the responsibility for the safekeeping of assets and records.

This audit finding and recommendation demonstrated the need for the implementation of policies affecting internal controls. To help implement this and other recommendations shown within Exhibit B of this agenda report, City staff developed the internal audit policies being presented.

The City’s external auditors’ (Eadie and Payne) recommended that the City Controller’s proposed policies be brought to the City Council for “receive and file” action before they are fully implemented by the City Manager through the Standard Operating Manual (SOM) amendment process.

STATEMENT OF THE ISSUE:

The audit findings described above, and also those shown in Exhibit B, display the City’s deviation from at least one of the five elements of proper internal control. The five elements of proper internal controls are (1) Control Environment, (2) Monitoring Activities, (3) Risk Assessment, (4) Control Activities, and (5) Information and Communication. The provisions in these policies, if implemented properly by staff, will help minimize risk for the City as they cover a wide array of situations that pose a risk to proper internal control and risk to the City’s financial position and operations. It is also important to note that the policies may need to change to keep up with the current environment or any unforeseen circumstances.

The policies that are being proposed apply to all City departments, and they cannot be fully implemented until the City Manager conducts the Standard Operating Manual amendment process, which may include communications with City Bargaining Units.

Further, training sessions need to be conducted to complete the implementation of the policies.

Purpose of the Policies: The purpose of the Fraud Policy is to promote a culture founded on fraud prevention, awareness, accountability, and to clarify acts that are suspicious or fraudulent. The Internal Audit policy establishes the official policies and procedures for the Internal Audit Office of the City of Compton. The Whistleblower Policy within the Fraud Policy is intended to put a protocol in place for encouraging and enabling employees to report concerns over any act believed to violate a law or regulation or that constitutes fraud and the right of protection over such reporting.

Staff Report – Resolution Receive and
File Internal Control Policies
February 6, 2023, Page 3 of 3
FISCAL IMPACT:

The fiscal impact of these policies is to improve the City’s internal controls surrounding Internal Auditing, Fraud Hotline protocols, monitoring, information and communication, control environment, control activities, and risk assessment. When these policies are implemented, the result will be a more favorable impact on the financial position of the City. Additionally, when these policies are fully implemented, a result of having less audit findings will be expected.

ALTERNATIVE:

The result of not receiving and filing these policies would be the continuance of not having sufficient guidance for staff for proper internal control policies and procedures in the areas of Internal Audits. This would result in reoccurrence of audit findings.

RECOMMENDATION:

It is recommended that the City Council adopt the attached Resolution to receive and file the attached policies.

SHARON RAHBAN NAVIZADEH,

CITY CONTROLLER
APPROVED FOR FORWARDING:

WILLIE A. HOPKINS, JR.

CITY MANAGER

EXHIBIT B
STAFF REPORT – RESOLUTION RECEIVE AND FILE INTERNAL CONTROLPOLICIES Other findings and recommendations listed in the FY2020 Single Audit report demonstrate the need for many of the provisions contained in these policies, such as how to avoid inciting repeated or new audit findings in the future. Other specific audit finding recommendations are listed below according to their finding number, which has been obtained from the FY2019-2020 Single Audit report:
#2020-006 – Internal Audits (MW):

Recommendation: We recommend that City Council and City Management establish and reinforce policies and procedures that promote cooperation of all departments and educate them on the importance of checks and balances within departments across the City.
#2014-093B and -095B – Assignment of Authority and Responsibility (MW):

Recommendation: We recommend the City assess its current processes and implement policies and procedures to segregate incompatible functions. #2014-100B – Risk Identification (MW)
Recommendation: We recommend that the City start doing risk assessments to be able to identify and properly address risks.
#2014-101B: Risk Identification (SD)
Recommendation: We recommend that the City put mechanisms in place to aid in anticipating, identifying, and reacting to routine events that affect the achievement of objectives.
#2014-102B: Risk Identification (SD)
Recommendation: We recommend the City put mechanisms in place to aid in identifying external factors that affect the achievement of objectives. #2014-103B: Risk Identification (SD)
Recommendation: We recommend that the City assess other factors that may contribute to or increase risk of which the City is exposed. #2014-104B: Risk Identification (SD)
Recommendation: We recommend that City Management identify risks on a Citywide level, as well as for each significant activity level of the City. #2014-106B: Risk Analysis (SD)
Recommendation: We recommend the City develop and establish an approach for risk management and control. The City should also formalize in City Policies how much risk can be prudently accepted.
#2014-107B: Policies and Procedures (General Applications) (MW) Recommendation: We recommend that the City update its formal Policy and Procedures manual to incorporate the recently implemented internal control procedures, and complete these updates as soon as possible. #2014-110B – Common Categories of Control Activities (SD) Recommendation: We recommend that City management review performance reports to gain an understanding where additional training or other corrective actions are necessary.
#2014-111B: Common Categories of Control Activity (MW)
Recommendation: We recommend that the City assess its current processes and implement policies and procedures to segregate incompatible functions. #2014-114B: – Common Categories of Control Activities (MW) Recommendation: We recommend that City Management and department heads evaluate if proper segregation of duties are in place. If not, mitigating controls should be developed and implemented to decrease the risk of error or inappropriate actions.
#2015-115B: – Common Categories of Control Activities (SD) Recommendation: We recommend that the City continue to review and update its Administrative Policies and Procedures manuals to ensure consistency with current processes and organizational structure; and perform periodic and ongoing reviews to ensure proper documentation, accuracy, and completeness in its financial transactions and records.
#2014-117B: – Information (SD)
Recommendation: We recommend that City Management communicate and manifest the importance of timely communication in the policies and employee manuals.
#2014-122B – Communication (BP)
Recommendation: We recommend that the City has forms and means of communication in place to be able to communicate important information with employees and others.
#2014-125B – On-Going Monitoring (SD)
Recommendation: We recommend the City train and educate City personnel to obtain information and evaluate whether internal control they work with on a daily basis is functioning properly.
#2014-132B – Separate Evaluation (MW)
Recommendation: We recommend that once an internal control unit has been established that the scope and frequency of separate internal control evaluations to be tailored to the City’s circumstances and needs.
#2014-133B – Separate Evaluation (MW)
Recommendation: We recommend that once an internal control unit has been established that the City ensures that they have the necessary resources, ability, and independence.
#2014-134B – Separate Evaluation (MW)
Recommendation: We recommend that any deficiencies found during internal audit evaluations are promptly resolved to reduce the risk of subsequent effects. #2014-135B – Separate Evaluation (MW)
Recommendation: We recommend the City implement ongoing monitoring of internal controls to gain comfort of their functionalities and/or discover any deficiencies that needs to be further investigated and addressed. #2014-136B – Report Deficiencies (SD)
Recommendation: We recommend that issues and deficiencies are directly communicated to the Responsible Person and elevated to someone at least a level higher.

FEBRUARY 6, 2024
TO: HONORABLE MAYOR AND COUNCIL MEMBERS
FROM: DIRECTOR OF RECREATION
SUBJECT: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COMPTON

AUTHORIZING THE CITY MANAGER TO ENTER INTO A TWO AND A

HALF-YEAR SERVICE AGREEMENT AND ESTABLISH A PURCHASE
ORDER WITH BRIGHTVIEW LANDSCAPE SERVICES, INC. TO

PERFORM ATHLETIC FIELD MAINTENANCE SERVICES FOR THE
GONZALES PARK DODGER DREAMFIELDS ($247,260.00).

SUMMARY
Adoption of the attached resolution of the City Council of the City of Compton authorizes the City Manager to enter into a two and a half-year service agreement and establish a purchase order with BrightView Landscape Services, Inc. to perform athletic field maintenance services for the Gonzales Park Dodger Dreamfields ($247,260.00).

BACKGROUND
The City of Compton has partnered with Dodgers Dreamteam to provide a sports-based youth development program to serve Compton’s youth. The program uses the power of sport to provide critical resources and services to communities that are experiencing social injustices. In order to assist with this task, the City of Compton must contract with a professional field maintenance provider to keep the sports field in safe and playable condition.

STATEMENT OF THE ISSUE
City Council approval is needed to secure athletic field maintenance service for the Dodger Dreamfields at Gonzales Park, located at 1101 W. Cressey Street Compton, California. The previous contract with Major League Infields Inc. has expired and the Department of Recreation is requesting to secure a long-term partnership for the field maintenance with BrightView Landscape Services, Inc.

7. Staff report-Dodger Dreamfields
Brightview Landscape Services Inc - Athletic Field Maintenance February 6th, 2024 Page 2
The Request for Proposals, (RFP) was published on 09/13/2023. A total of six (6) proposals were received. A review committee ranked the received proposals as noted below:

Contractor Proposal (Cost per year)
BrightView Landscape Services, Inc $98,904.00
Major League Infields, Inc $99,720.00
SGD Enterprises $125,283.00
ESI Field of Dreams $361.925.00
Alexander Construction & Engineering $384,054.00
BSI Sports Turf, Inc $542,038.00

FISCAL IMPACT
The cost for fiscal year 2023-2024 is Forty-Nine Thousand Four Hundred Fifty-Two Dollars ($49,452) and the cost for the remaining two years is Ninety-Eight Thousand Nine Hundred Four Dollars ($98,904) per year, for a total Two Hundred Forty-Seven Thousand Two Hundred Sixty Dollars ($247,260.00) for the term of the agreement. The funds for these expenditures are available in the 2023-2024, and will be available in 2024-2025 and 2025-2026 Fiscal Year Budgets in Account number 1001-840-000-4238.

RECOMMENDATION
Staff recommends that the City Council adopt the attached Resolution establishing and authorizing the City Manager to enter into a two-and-a-half-year service agreement to perform needed athletic field maintenance services at Gonzales Park.

Staff report-Dodger Dreamfields
Brightview Landscape Services Inc - Athletic Field Maintenance February 6th, 2024 Page 3

BRYAN SPRAGG

DIRECTOR OF RECREATION
APPROVE FOR FORWARDING:

WILLIE A. HOPKINS JR.

CITY MANAGER
RESOLUTION NO. ___________

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF COMPTON AUTHORIZING THE CITY MANAGER TO ENTER INTO A TWO AND A HALFYEAR SERVICE AGREEMENT AND ESTABLISH A PURCHASE ORDER WITH BRIGHTVIEW LANDSCAPE SERVICES, INC. TO PERFORM ATHLETIC FIELD

MAINTENANCE SERVICES FOR THE GONZALES PARK DODGER
DREAMFIELDS ($247,260.00).

WHEREAS, adoption of this resolution by the City Council of the City of Compton authorizes the City Manager to enter into a two and a half-year service agreement and establish a purchase order with BrightView Landscape Services, Inc. to perform athletic field maintenance services for the Gonzales Park Dodger Dreamfields; and WHEREAS, the City of Compton has partnered with Dodgers Dreamteam to provide a sports-based youth development program to serve Compton’s youth; and WHEREAS, the program uses the power of sport to provide critical resources and services to communities that are experiencing social injustices; and WHEREAS, the previous contract with Major League Infields Inc. has expired and the Department of Recreation is requesting to secure a long-term partnership for the field maintenance with BrightView Landscape Services, Inc.; and WHEREAS, in September 2023, the City released a Request for Proposal to provide needed athletic field and maintenance services, and staff reviewed the proposals that were received in accordance with the City’s Municipal Code (§ 4-11.5 Lowest Responsible Bidder); and
WHEREAS, the following bids were received; and
Vendor Proposal (Cost per year)
BrightView Landscape Services, Inc $98,904.00
Major League Infields, Inc $99,720.00
SGD Enterprises $125,283.00
ESI Field of Dreams $361.925.00
Alexander Construction & Engineering $384,054.00
BSI Sports Turf, Inc $542,038.00
Resolution No.__________

Page 2 ends

2 WHEREAS, taking into consideration factors such as pricing, the thoroughness of each proposal, quality of work with other municipalities, experience of the staff, resources and equipment available to manage the program; and
WHEREAS, the Department received a total of 6 proposals and interviewed the companies to further evaluate staffing, equipment and services; and determined the following ranking:

Ranking Contractor Score
1 SGD Enterprises 94
2 BrightView Landscape Services, Inc 87
3 Major League Infields, Inc 84
4 ESI Field of Dreams 76
5 BSI Sports Turf, Inc 77
6 Alexander Construction & Engineering 75
WHEREAS, staff determined BrightView Landscape Services, Inc’s proposal was the most responsive and had the lowest bid at an annual cost of Ninety-Eight Thousand Nine Hundred Four Dollars ($98,904); and
WHEREAS, the funds for these expenditures are available in the 2023-2024 Fiscal Year Budgets, and will be available in the 2024-2025 and the 2025-2026 Fiscal Year Budgets within account number 1001-840-000-4238.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF COMPTON DOES HEREBY RESOLVE AS FOLLOWS:

Section 1. That the City Manager, is hereby authorized, on the advice and approval of the City Attorney, to enter into a service contract with BrightView Landscape Services, Inc for a period of two and one half (2.5) years.

Section 2. That purchase orders are authorized to be established for BrightView Landscape Services, Inc. in an amount of Forty-Nine Thousand Four Hundred Fifty-Two Dollars ($49,452) for fiscal year 2023-2024, and Ninety-Eight Thousand Nine Hundred Four Dollars ($98,904) annually for the remaining two-year term of the contract, for a total Two Hundred Forty-Seven Thousand Two Hundred Sixty Dollars ($247,260.00), to be drawn from Account Number 1001-840-000-4238.

Resolution No.__________

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3 Section 3. That funds are available in the 2023-2024 Adopted Fiscal Year Budget in Account Number 1001-840-000-4238, for athletic field maintenance service for Dodger Dreamfields.

Section 4. That the annual amount of Ninety-Eight Thousand Nine Hundred Four Dollars ($98,904) will be authorized in the 2024-2025 and the 2025-2026 Fiscal Year Budgets.

Section 5. That a copy of this Resolution shall be filed in the offices of the City Clerk, City Attorney, City Manager, Public Works Street Maintenance, Recreation and the City Controller.

Section 6. That the Mayor shall sign, and the City Clerk shall attest, to the adoption of this Resolution.

ADOPTED this _______day of ____________, 2024

MAYOR OF THE CITY OF COMPTON
ATTEST:

CITY CLERK OF THE CITY OF COMPTON

STATE OF CALIFORNIA )

COUNTY OF LOS ANGELES ) SS

CITY OF COMPTON )
I, Vernell McDaniel, City Clerk of the City of Compton, hereby certify that the foregoing Resolution was adopted by the City Council of the City of Compton, signed by the Mayor and attested by the Clerk at a regular meeting thereof held on this _______ day of ____________, 2024.

Resolution No.__________

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4 That said Resolution was adopted by the following vote, to wit:

AYES: COUNCILMEMBERSNOES: COUNCILMEMBERSABSTAIN: COUNCILMEMBERSABSENT: COUNCILMEMBERS-

CITY CLERK OF THE CITY OF COMPTON

REQUEST FOR PROPOSAL

ATHLETIC FIELD MAINTENANCE SERVICES

FOR THE CITY OF COMPTON
The City of Compton is soliciting proposals for athletic field maintenance services covering the Gonzales Park Dodger Dreamfield.

Proposals will be received in the office of the City Clerk, City of Compton, 205 South Willowbrook Avenue, Compton, California, 90220 until 5:00 pm on October 2, 2023.

POSTMARKS WILL NOT BE ACCEPTED. All proposals must be clearly marked, “PROPOSAL TO PROVIDE ATHLETIC FIELD MAINTENANCE SERVICES IN THE CITY OF COMPTON – DO NOT OPEN WITH REGULAR MAIL” and shall be delivered during the business hours of 7:00 a.m. to 6:00 p.m., Monday through Thursday, except holidays, to the City Clerk’s office.

Submit four (4) copies of your service proposal, one must be digital. It should be understood that the final annual costs will be as negotiated with the City. As part of the proposal please indicate the unit costs that are associated with each phase.

All submitted proposals will be reviewed and analyzed by City staff and the proposal which best meets the City’s needs will be selected for further analysis and negotiation.

The City of Compton proposes to enter into an Agreement for a three (3) year term.

The City of Compton reserves the right, in its sole discretion during this selection process, to reject any or all proposals or any portion without exception or explanation.

Parties interested in obtaining a Request for Proposal (RFP) package should check the City’s website at www.comptoncity.org or contact the:

Recreation Department
City of Compton
205 South Willowbrook Avenue
Compton, CA 90220
(310) 605-3060

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SUBMITTAL DEADLINE
To be considered, proposals must be submitted no later than Monday, October 2, 2023 at 5:00 p.m. to the City Clerk’s Office, 205 South Willowbrook Avenue, Compton, California, 90220.

Postmarks will not be accepted. The City may extend the deadline at its option.

During this period of restricted contact, any attempt by a proposing firm, its representative or agent to contact, lobby, or make a representation to a member of the City Council, or any other official, employee, or agent of the City will be grounds for disqualification.

Vernell McDaniel
City Clerk
Publish: 09/13/2023
09/20/2023
09/27/2023

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REQUEST FOR PROPOSAL

CITY OF COMPTON

ATHLETIC FIELD MAINTENANCE SERVICES

INTRODUCTION TO THE CITY OF COMPTON
The City of Compton was incorporated in 1888. The City totals approximately 10.2 square miles in size, and is home to more than 93,597 residents (2022). The City has approximately five (5) major parks with recreational facilities, eight (8) neighborhood parks, one (1) Par 3 Golf Course and two (2) commercial swimming pools.

The City has partnered with the Dodgers Dreamteam (formerly Dodgers RBI) Association to provide a comprehensive sports-based youth development program that uses the power of sport to provide critical resources and services to communities who are experiencing social injustices.

The Los Angeles Dodgers Foundation (LADF) works in partnership with 14 Affiliate Partners to deliver sports-based programming and wraparound services for 11,000 youth and to support communities and families across the city. With growing interest in Dodgers Dreamteam programming from the community, LADF aims to serve 25,000 youth annually by 2030.

SCOPE OF WORK
The City of Compton is requesting proposals from experienced and qualified vendors, hereinafter referred to as the “Contractor”, to provide athletic field maintenance at Gonzales Park where the Dodgers Dreamteam programming occurs.

Jackie Robinson Stadium
Turf maintenance:

Weekly:

Mow Outfield and foul ground turf. 1 time per week
Mow Infield Turf. 2 times per week
Edge and weed perimeter. 1 time per week
Water blast perimeter. 1 time per week
Paint foul lines on turf. 1 time per week
Quarterly:

Fertilize all turf area. 4 times a year
Annually:

Aerate all turf to depth of 2 inches
Outfield turf overseed with annual rye grass seed
Infield turf overseed and top dress with perennial rye grass seed Mound and Batter’s Box Maintenance:

Repair all holes with mound/batter’s box clay. 3 times per week

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Infield Traction Area Maintenance:

Weekly:

Scarify infield traction area. 1 time per week
Backfill and level infield traction area. 1 time per week Heavy water infield traction area. 1 time per week
Drag infield traction area. 3 times per week
Drag warning track area. 3 times per week
Bi-weekly:

Spray all traction areas using Round up
Semi-annual:

Float the infield traction area with grading equipment
Annual:

Laser grade traction area
Add 50 tons of infield mix
Field 42
Turf maintenance:

Weekly:

Mow Outfield and foul ground turf. 1 time per week
Edge and weed perimeter. 1 time per week
Water blast perimeter. 1 time per week
Paint foul lines on turf. 1 time per week
Quarterly:

Fertilize all turf area. 4 times a year
Annually:

Aerate all turf to depth of 2 inches
Outfield turf overseed with annual rye grass seed
Batter’s Box Maintenance:

Repair all holes with batter’s box clay. 3 times per week Infield Traction Area Maintenance:

Weekly:

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Spray all traction areas using Round up
Semi-annual:

Float the infield traction area with grading equipment
Annual:

Laser grade traction area
Add 12.5 tons of infield mix
Rachel Robinson Field
Turf maintenance:

Weekly:

Mow Outfield and foul ground turf. 1 time per week
Edge and weed perimeter. 1 time per week
Water blast perimeter. 1 time per week
Paint foul lines on turf. 1 time per week
Quarterly:

Fertilize all turf area. 4 times a year
Annually:

Aerate all turf to depth of 2 inches
Outfield turf overseed with annual rye grass seed
Batter’s Box Maintenance:

Repair all holes with batter’s box clay. 3 times per week Infield Traction Area Maintenance:

Weekly:

Spray all traction areas using Round up
Semi-annual:

Float the infield traction area with grading equipment
Annual:

Laser grade traction area
Add 12.5 tons of infield mix
Kershaw Training Field

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Turf maintenance:

Weekly:

Mow Outfield and foul ground turf. 1 time per week
Edge and weed perimeter. 1 time per week
Water blast perimeter. 1 time per week
Paint foul lines on turf. 1 time per week
Quarterly:

Fertilize all turf area. 4 times a year
Annually:

Aerate all turf to depth of 2 inches
Outfield turf overseed with annual rye grass seed
Batter’s Box Maintenance:

Repair all holes with batter’s box clay. 3 times per week Infield Traction Area Maintenance:

Weekly:

Spray all traction areas using Round up
Semi-annual:

Float the infield traction area with grading equipment
Annual:

Laser grade traction area
Add 12.5 tons of infield mix
Repair all holes with mound/batter’s box clay. 3 times per week and all other maintenance services as determined necessary.

PROPOSAL FORMAT
Your proposal should be submitted in the following format:

Section 1: Describe your firm, including your area of specialization; number of employees; prior experience performing similar services; current workload; current financial environments, etc.

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Section 2: Describe your firm’s or employees’ experience working for or with municipal governments.

Section 3: Describe how you typically communicate with City staff regarding your status.

Please provide any report format you currently use to keep City staff informed about the status.

Section 4: Provide the names and backgrounds of the individuals who will be providing the actual services to the City. Include their prior experience providing athletic field maintenance services to municipalities and/or their previous experience working with municipalities.

Section 5: Provide the total annual cost to perform the Athletic Field Maintenance Services for the activity levels described in the Proposal Form herein. This shall be the total amount payable to the Service Provider by the City. The total amount shall be divided by twelve (12) and invoiced and paid monthly.

Section 6: Provide any additional information you believe will be helpful to assist in the review of your proposal. Include any attachments, exhibits, or reports which you feel will help us to gain a better understanding of your firm’s ability to provide this service to the City of Compton.

Your proposal must respond to and conform to the “Athletic Field Maintenance Services” specifications listed in this document.

PROPOSED SCHEDULE OF EVENTS
The following is the proposed schedule for the selection process:

Release of RFP by the City to Service Providers 09/13/2023 RFP’s final submittal date 10/02/2023
Council approval of Agreement (Tentative) 10/03/2023 (tentative) Agreement commencement (Tentative) 10/16/2023 (tentative)

DEFINITION OF TERMS
Whenever the terms listed below appear in the Contract Documents, they shall be defined as follows:

1. City shall mean the City of Compton, California, as it now exists or as its boundaries may from time to time be change.

2. Contractor, Service Provider, Bidder, Firm, Corporation shall mean the person with whom the City has executed the Agreement and who is fully responsible for performance of the work.

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MISCELLANEOUS PROVISIONS
These specifications and the draft agreement are complementary. This RFP does not commit the City to enter into an agreement or to pay any costs incurred by proposers in the preparation of a proposal.

The City reserves the right to accept or reject any or all proposals received as a result of this RFP.

The City reserves the right to cancel in part, or in its entirety, this RFP.

Any changes to the RFP requirements will be made by addendum. All addendum shall be signed by bidders and attached to the proposal. Failure to attach any addendum may render the proposal non-responsive and cause it to be eliminated from consideration.

The City may require the selected bidder(s) to participate in negotiations and to submit such prices, technical or other revisions to their proposals as may result from negotiations. Bidder(s) selected for an interview may be asked to submit “best and final” cost proposals as a final step in the selection process.

All responses to the RFP become the property of the City of Compton. At such time a final award is made, all proposals submitted in response to this RFP become a matter of public record and shall be regarded as public records, with the exception of those elements in each proposal which are defined by the bidder as business or trade secrets, and marked “Trade Secret,” “Confidential,” or “Proprietary.”

SELECTION
All proposals will be reviewed by the Public Works Street Superintendent and other relevant staff.

The Public Works Street Superintendent and staff will evaluate the proposals based upon price, service plan, experience, and customer service experience.

During the evaluation process, the Public Works Street Superintendent, at his discretion, may request any or all service providers to provide oral presentations. Such presentations will provide service providers with an opportunity to answer any questions the selection committee may have on a service provider’s proposal. Not all firms may be asked to make oral presentations.

There is no expressed or implied obligation for the City to reimburse responding service providers for any expenses incurred in making an oral presentation to the selection committee.

Upon completion of the evaluation process, the Public Works Street Superintendent will recommend a service provider for selection to the City Council.

1.0 GUIDELINES

1.1 Purpose of Procurement

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The purpose of the Request for Proposal (RFP) is to outline the City of Compton’s interest in obtaining the services of a qualified company to provide athletic field maintenance services. Athletic Field maintenance services must meet all sport field regulations. Proposing companies are hereby invited to submit their proposals in accordance with the terms of this document.

1.2 Basic Guidelines for this Request for Proposal
The qualifications shall be evaluated in accordance with the criteria set forth in this Request for Proposal (RFP). Proposing firms shall be afforded fair and equal treatment with respect to any opportunity for discussion and revisions; and such revisions may be permitted after submissions prior to the deadline date for the purpose of obtaining the best and final offers.

Selection shall be made to the proposing firm whose qualifications are determined in writing to be the most advantageous for the City, considering all of the evaluation factors set forth in this RFP. No other factors or criteria shall be used in the evaluation. The City reserves the right to reject any and all proposals submitted in response to this request.

1.3 Contract Term
No award shall be binding upon the City unless and until consummated by a written, fully executed contract. The contract duration is expected to begin September 23, 2023 through June 30, 2026. The annual renewal of the contract shall be at the sole discretion of the City. The City will retain the right to terminate the contract at any time.

1.4 Withdrawal of Proposal
Proposals submitted early may be withdrawn by the proposing firm prior to the proposal due date specified. Following the proposal date, the proposal constitutes a binding offer and may not be withdrawn prior to the award.

1.5 Costs of Preparation
The proposing firm shall be solely responsible for any and all costs associated with developing and preparing the proposal.

1.6 Reservation of Right
The City of Compton reserves the right to: (a) waive minor irregularities or variances, non-material bid formalities or defects in any proposal; (b) reject any and all proposals, in whole or in part, submitted in response to this RFP; (c) request clarifications from all proposing firms; (d) request resubmissions from all proposing firms; (e) make partial, progressive or multiple awards; and (f) withdraw or cancel this RFP without prior notice, at any time, at its sole discretion.

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2.0 DESCRIPTION OF REQUIREMENTS

2.1 Objective of the Procurement
The overall and ultimate objective of this Request for Proposal is to provide athletic field maintenance services within the City of Compton Gonzales Park Dodger Dreamfield from the selected or contracted firm (“Contractor”).

2.2 Duties and Procedures
The Contractor shall adhere to the following duties and procedures in the fulfillment of the scope of services.

2.3 Personnel and Equipment. The work consists of furnishing all labor, materials, machinery, tools, means of transportation, supplies, equipment and services necessary for the maintenance of athletic fields in the City.

1. Work Orders and Communication. Work orders for athletic field maintenance services will be provided by e-mail to the Contractor from the City’s representative. The Contractor shall respond by e-mail promptly with an acknowledgment of receipt; if sent before 12:00 pm, the Contractor shall respond by 5:00 pm the same day or if sent after 12:00 pm, the Contractor shall respond by 9:00 am the next day.

Each time work is completed, the Contractor is responsible for cleaning and removing from each area worked in, all debris, materials and equipment associated with the work performed.

2. Notice To Proceed and Schedule. Once the athletic field maintenance plan is approved by the City representative, a notice to proceed (NTP) will be issued to the Contractor. The athletic field maintenance services plan shall commence 48 hours of receiving assignments and 24 hours for designated emergencies.

The Contractor is not to commence work until an NTP is issued.

3. Responsiveness. The City expects the Contractor to respond promptly through the weekends and holidays. Work shall be performed during or after business hours, on weekends and during holidays if necessary.

4. Property Damage. Services performed under this contract, the Contractor shall notify the City representative within 24 hours if damage occurs and replacement and/or repair shall be done at no cost.

2.4 Additional Requirements

1. Contractor will have ten (10) days to correct any unsatisfactory performance as determined by the City representative for no extra compensation. If the correction is not made within ten (10) days, no payment shall be rendered for the work. If two of these instances occur within a 12-month period

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without correction in 10 days, the contract may terminate for cause upon 7 days’ notice by the City. Additionally, the contract will be terminated by the City upon 30 days’ notice.

2. The Contractor shall maintain all permits, certificates, and licenses necessary to perform the athletic field maintenance services described herein.

3. The Contractor may not assign this contract or subcontract to another party for performance of the terms and conditions hereof without the written consent of the City. All correspondence authorizing subcontracting must reference the contract and identify the specific job being subcontracted.

3.0 PROPOSAL PACKAGE
A complete proposal package must be submitted to be considered and shall include four (4) copies of your service proposal, one must be digital. The proposal shall consist of the elements within the following sections. E-mail submittals are not accepted.

3.1 Basic Information

1. Provide basic company information: owner, company name, address, name of primary contact, telephone number, fax number, e-mail address, and company website (if available). If the firm has multiple offices, the qualification statement shall include information about the parent company and branch office separately. Provide form of ownership, including state of residency or incorporation, and number of years in business. Indicate if the proposing firm is a sole proprietorship, partnership, corporation, Limited Liability Corporation (LLC), or other structure.

2. Identify and provide the name of the project manager who will be assigned to this contract. The project manager is the foreman or responsible person overseeing and/or participating in the actual work. Provide all relevant experience along with references for the project manager, completed projects and contact information for references.

3. Provide the overall qualifications and experience for the firm itself with references. These references may overlap with those for the project manager.

4. Overall at least three (3) references must be provided, illustrating similar and relevant experience with services provided to organizations, communities or agencies, highlighting successfully completed related projects. Please include references of people, firms, or agencies that may be contacted to verify this experience. Please provide name, e-mail address, and phone number. References should be able to validate firm experience and project manager experience. Demonstrating successful experience with public agencies is highly desired.

3.2 Cost and Pricing

1. (a) Provide a complete list of rates for services from which the cost of each service request shall be priced.

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2. The cost proposals must be inclusive of all related costs including but not limited to: materials, labor, and administrative costs and any taxes that may be levied. It is the responsibility of the bidder to determine any and all taxes and/or fees and include same in the proposal.

3. Pricing shall include all cost, both direct and indirect to perform the work.

3.3 Insurance Requirements
Demonstrate ability to fulfill insurance requirements as follows:

1. Commercial General Liability Insurance. $1,000,000 combined single limit per occurrence for bodily injury, personal injury and property damage. If the submitted policies contain aggregate limits, general aggregate limits will apply separately to the work under this Agreement or the general aggregate will be twice the required per occurrence limit.

2. Automobile Liability. $1,000,000 combined single-limit per accident for bodily injury and property damage.

3. Workers' Compensation and Employer's Liability. Workers' Compensation limits as required by the California Labor Code and Employer's Liability limits of $1,000,000 per accident for bodily injury. Workers' Compensation and Employer's Liability insurance will not be required if Contractor has no employees and provides, to City's satisfaction, a declaration stating this.

4. Professional Liability. Errors and omissions liability appropriate to Contractor’s profession with limits of not less than $1,000,000 per claim. The coverage shall also provide an extended two (2) year reporting period commencing upon termination or cancellation of this Agreement.

Endorsements. For Commercial General Liability Insurance and Automobile Liability Insurance, Contractor will ensure that the policies are endorsed to name the City of Compton and its respective elected and appointed officers, officials, employees, agents and volunteers as “additional insured” with respect to liability arising out of the activities of the Contractor. Any failure to comply with reporting provisions of the policies shall not affect coverage provided to the City. Prior to City's execution of this Agreement, Contractor will furnish certificates of insurance and endorsements to City.

Waiver of Subrogation. The policies shall contain a waiver of subrogation for the benefit of City.

4.0 EVALUATION

4.1 Proposals
Each response shall be prepared simply and economically, providing straightforward, concise delineation of proposing firm’s capabilities to satisfy the requirements of this RFP. Emphasis on each proposal must be on completeness and clarity of content. To expedite the evaluation of qualifications, it is essential that proposing firms follow the format and instruction contain herein.

4.2 Proposal Submission
Proposals are due at the location specified below no later than:

Monday, October 2, 2023 at 5 pm
Submit four (4) copies of your service proposal, one must be digital to:

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City of Compton
City Clerk’s Office
205 South Willowbrook Avenue
Compton, CA 90220
Attention: Bryan Spragg
Director of Recreation

4.3 Evaluation Criteria and Process
The following items are evaluation criteria for all qualifying proposals and will be rated on a point system basis by the evaluation team. Submittals must provide all information as required in this RFP.

1. Firm’s qualifications and experience (5 points max)

2. Firm’s references for experience (10 points max)

3. Proposed project manager’s qualifications and experience (10 points max)

4. Proposed project manager’s references for experience (15 points max)

5. Overall examples of similar and relevant work (15 points max)

6. Demonstrated successful experience with public agencies (10 points max)

7. Approach and responsiveness to sign removal and installation services (15 points)

8. Completeness and responsiveness to RFP requirements (10 points)

9. Familiarity with the City of Compton (5 points)

10. Local Hiring Credit (5 points)

4.4 Review of Qualifications
All qualifications received will be reviewed by the City to ensure that all administrative requirements of the RFP package have been met by the proposing firm. Failure to meet these requirements may be cause for rejection of a qualification. All technical qualifications that meet the administrative requirements will then be turned over to the technical evaluation team members for further evaluation.

4.5 Selection and Evaluation Process
The City will complete the selection process and in its sole discretion, and in the course of its evaluation, may request interviews or presentations with one or more selected proposing firms. The selection process shall be completed at the pleasure of the City, but is anticipated to conclude within thirty (30) days after submittal. An invitation will be extended to the finalist to complete a contract for services.

4.6 Preliminary Award of Contract Schedule
The following dates reflect the anticipated schedule for proposal solicitation, selection of Consultant and award of contract.
• Solicit Proposals for Services Sept 13, 2023
• Proposals Due Oct 2, 2023
• Review Proposals Oct 2, 2023 (week of)
• Recommend Award to City Council Oct 10, 2023 (tentative) • Agreement commencement (tentative) Oct 16, 2023 (tentative)

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5.0 ADDENDUM
All inquiries and questions of this RFP must be submitted in writing by e-mail to [email protected]. Written responses to all written questions will be addressed in the form of an addendum and available on the City’s website at www.comptoncity.org Questions and inquiries will not be answered by any other means. If the website is down, responses will be provided by e-mail or fax upon request.

1 REQUEST FOR PROPOSAL

CITY OF COMPTON

ATHLETIC FIELD MAINTENANCE SERVICES

GONZALES PARK, JACKIE ROBINSON STADIUM
ESI Field of Dreams, LLC.

Doug Allen
(626) 222-2317
[email protected]
Contact: Doug Allen (Project Manager) Andre Sanchez (Project Manager) (626) 222-2317 (310) 920-5485
[email protected] [email protected]

PROPOSAL TO PROVIDE

ATHLETIC FIELD NAINTENANCE SERVICES IN THE CITY OF COMPTON 2 ESI Field of Dreams, LLC.

PROPOSAL ATHLETIC FIELD MAINTENANCE SERVICES
Table of Contents
Description of firm (section 1) page 3
Description of firm’s employees (section 2) page 3
Communications with City Staff (section 3) page 3
Names and backgrounds of individuals (section 4) page 4 Annual cost breakdown (section 5) * page 5
Additional Information (section 6) page 6
Turf maintenance schedule (grass maintenance) page 7
References page 8
List of equipment page 9
Calendar of events (12-month daily field breakdown) *page 10 3 Thank you for the opportunity to submit a proposal for the athletic field maintenance services in the City of Compton at Gonzales Park, Jackie Robinson Fields. We have carefully reviewed the requirements and specifications outline in the Request for Proposal (RFP), we are pleased to present our comprehensive plan and cost breakdown for your consideration. Our proposal covers a 12-month period, with two one-year extensions.

Section 1
ESI Field of Dreams, LLC. (ESI), has extensive experience in athletic field maintenance, and management a proven track record of delivering safe high-quality results for municipalities and public facilities. Our organization specializes in field maintenance, field preparation, rodent eradication, weed control, fungus treatment and pre-game preparation. We have a team of 4 with a combined 20 plus years of experience in field maintenance to oversee all aspects of the project. Our team includes skilled groundkeepers, horticulturists, irrigation specialists, equipment operators and administrators. Current workload, consist of Dominquez High School, Urban Youth Academy, North Torrance Little League, Torrance Little League, Palos Verde Little League, periodic work on Peninsula and Hawthorne High Schools**(see attachment photos) **.

Despite our workload, we are committed to delivering safe high-quality results to the City of Compton. Our financial environment is very strong, we own our equipment, only maintenance and up keep of equipment is needed. **(see attachment list of equipment) ** Section 2
Our CEO Don Buford has extensive time in managing field maintenance facilities, starting as a Director of Field Operations for the Baltimore Orioles, Director of MLB Urban Youth Academy, Doug Takaragawa was part of the original team that opened MLB Urban Youth Academy, Doug Allen (Project Manager) has been taken part in the field maintenance, lining of the fields, fungus treatments and fertilizing over the past two years at Dominguez High Schools baseball and softball fields. Project Manager Andre Sanchez is certified from Ohio State, horticulturists, irrigation specialists (see attachment), with years of experience as a groundkeeper, and one of the original and now head groundkeepers at the MLB Urban Youth Academy. ESI has worked with various entities over the past several years, we have an ongoing partnership with the Compton Unified School District for the past 6 years and have partnered with Compton School Police, Compton Sheriffs, Imperial Courts, Harvard Park, L.A. Police Department and Ramona Gardens.

Section 3
Our communication with City staff, we prioritize responsive, effective communication along with full transparency. Our company maintains open lines of communication with City staff to keep them informed about the progress and status of the athletic field maintenance activities. 4 We utilize various communication channels, including email, phone calls, photos, and in-person meetings, based on the preferences of the city staff. Additionally, we provide detailed reports on maintenance activities, schedules, and recommendations for improvement to ensure City staff are involved and informed throughout the contract period.

Section 4
Over the course of his impressive 15-year work Experience with the various cities of Compton, Palos Verdes, Hawthorne, North Torrance and Torrance, Andre Sanchez has demonstrated exceptional expertise in field maintenance. Through his unwavering dedication and meticulous approach, he has been instrumental in maintaining the pristine condition of numerous sports fields within these communities. Andre’s skillset spans a wide range of essential tasks, including mowing of the fields, precise edging, and expert repair of pitcher and home plates. He ensures that the fields are consistently groomed to perfection by diligently dragging and lining them. Moreover, Andre’s expertise in moisture management and watering practices has resulted in safe healthy, lush playing surfaces, safeguarded from undesirable weed growth. Additionally, his swift and effective fungus treatment has shielded the fields from potential damage, providing athletes and sports enthusiasts with optimal safe playing conditions. Andre Sanchez’s remarkable commitment to field maintenance has undoubtedly left a lasting positive impact on the sports communities of Compton, Palos Verdes, Hawthorne, and Torrance. Doug Allen over the past two years has been a standout in field maintenance at Dominguez High School, diligently ensuring the sports fields are in top-notch condition. His meticulous approach to dragging the fields has resulted in consistently even and well-prepared playing surfaces. Doug’s expertise also extends to the repair and maintenance of the pitcher’s mound and batter’s box, crucial elements for safe and fair gameplay. His proficiency in watering and moisture management practices has led to the development of lush, healthy fields that athletes can truly thrive on. Furthermore, in his capacity as the Project Manager for the Educational Sports Institute for the past six years, Doug has demonstrated remarkable leadership skills by securing ongoing partnerships with the City of Compton Unified School District and organizing events in collaboration with Compton School Police with Chief Wu, Imperial Court with State Assemblyman Mike Gipson, Ramona Gardens, with Congressman Jimmy Gomez. Notably, he has organized the Battle of the Badges event, a heartwarming occasion for families of fallen officers, alongside Congresswoman Nanette Barragan. Doug is currently working towards securing a five-year partnership with the Sheriffs Youth Athletic League in the City of Compton, further exemplifying his dedication to fostering sport, youth and community engagement.
5 Section 5*(see cost breakdown sheet) *
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6 Section 6
Additional Information:

ESI Field of Dreams, LLC stands proudly alongside the Don Buford Educational Sports Institute (DB ESI0 as its sibling company, functioning as its for-profit counterpart. This enduring partnership has flourished in collaboration with the Compton Unified School District for the past six years, recently reaffirmed through a renewed five-year extension. Within this collaboration, DB ESI takes charge of coaching the baseball and softball teams at Dominguez High School. Additionally, they have embraced a holistic approach by employing a student team manager and a social media marketer, and are currently in the process of hiring three more student athletes to assist with field maintenance.

Under the umbrella of the Compton Unified School District, DB ESI has been entrusted with introducing the intricacies of baseball and softball to a student body consisting of 19,000 students throughout the school district. Looking forward to 2024, DB ESI’s flagship initiative will be the Tee Ball League, accommodating 1,000 young players. This outreach extends beyond the sports field; DB ESI has become an integral part of the community, recognizing that not every aspiring student athlete will pursue a professional sports career. Instead, they emphasize education as the cornerstone of personal development fostering exceptional citizens The synergy between our extensive years of professional expertise and the extensive networks starting with our newest partnership with USC’s Rod Dedeaux Foundation and current and former professional athletes who once played in the stadium are poised to elevate, enrich, and expand the existing programs at Jackie Robinson Stadium and surrounding parks throughout the City of Compton. Some of our programs like Umpire camps with former Dominguez High School alum and now MLB Umpire Malachi Moore, video broadcasting training, field maintenance training, just to name a few. The ultimate aspiration revolves around unifying the community, echoing the words of Nelson Mandela who emphasized the transformative potential of sports to reshape the world.

ESI Field of Dreams, LLC is unwaveringly committed to providing services that transcend the conventional realm of duties. Our scope of work extends to activities such as field dragging, meticulous watering, and precise field lining each executed as needed. Ensuring the readiness of the pitcher’s mound and batter’s box before every game stands as paramount in upholding premium quality sports facilities. These additional endeavors not only spotlight concern for the safety and satisfaction of both players and spectators.

By consistently tending to the field through post-game dragging, we guarantee a smooth playing surface that reduces the risk of injuries and fosters an environment where athletes can truly showcase their skills. Simultaneously, regular field lining guarantees unequivocal boundaries, fostering fair play and heightening the overall experience for everyone involved.

Taking proactive measures to maintain the pitcher’s mound and batter’s box demonstrates our 7 steadfast commitment to maintaining superior standards, thereby cultivating a secure and enjoyable arena for athletes to compete.

Our commitment extends beyond mere reputation-building; it’s about instilling pride in the facility and nurturing a vibrant sports community. Ultimately, these extra efforts mirror a genuine dedication to the sport and the well-being of its participants, forging an indelible imprint on the broader sporting experience.

Turf Maintenance Schedule: Annual
**All fertilizing, seeding and aerating will be performed on infield and outfield**

1. January: Light fertilizing (1)

2. February: Light fertilizing (2)

3. March: Seed (rye grass seed)- fertilize- apply pre-emergent for grab grass

4. April: Aerate (2-inch depth)-fertilize (3) for summer

5. May: Lower cut to bring up Bermuda

6. June: Cut fine for Bermuda

7. July: Apply pre-emergent for Winter

8. August: Begin renovating- aerate (2-inch depth) verti-cut-getting ready for seeding (rye grass seed)

9. September: (middle of the month) Seeding (Rye grass seed) for warm weather

10. October: Light fertilizing (4)- germinate to help seeding come out

11. November: Light fertilizing (5)-germinate to help seeding come out

12. December: Light fertilizing (6)-germinate to help seeding come out 8 References
James Chicano: Phone (562) 631-7904 Email; [email protected] *for Andre Sanchez* Mark Webb Phone310-283-5958 [email protected] *for Andre Sanchez* Adrian Gonzales: Phone (323-359-5693 [email protected] *for Andre Sanchez* JaMaiia Bond (CUSD Senior Director) (310) 200-6023 [email protected] *for Doug Allen*
9 Equipment
Toro 3100 tractor
John Deer 7700
Toro Walk Behind Mower 1600
Clinton Vetra Cutter
Power Trim edger
Echo Wee Wacker
John Deer Bunker Hack
Steel Blower
Backpack Sprayer
Pressure Washer
Fertilizer Spreader
Water Hose, 1 inch
Quick Connect
One inch nozzle
10 Calendar of events (12-month calendar of field maintenance breakdown) *Page intentionally left blank* see following pages

Compton City CouncilFebruary 6, 2024

Compton City Council
February 6, 2024