How To Ensure That An Eac Edge Program Is Successful



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Introduction Te Economic Diversification and Growt Enterprises Act became effective on 1 January 1995. Te creation of tis Act was to encourage new businesses to start or expand in Newfoundland and Labrador. Te Act is administered by te Department of Innovation, Trade and Rural Development, wit tax incentives administered in conjunction wit te Department of Finance. Te Department as establised specific criteria wic eac EDGE corporation must meet and maintain in order to receive EDGE approval and incentives. Figure 1 provides te Program criteria. Figure 1 Department of Innovation, Trade and Rural Development Economic Diversification and Growt Enterprises Program Eligibility Criteria Criteria - Potential for capital investment of at least $300,000 or annual sales of at least $500,000 - Potential for te creation and maintenance of at least 10 permanent jobs in te Province - Business activities offer te opportunity for long-term sustainable jobs and growt - Business activities offer a substantial net economic benefit to te Province - Business activities would not be undertaken witin te Province or at te time of application witout te presence of EDGE incentives - EDGE incentives provided to te business would not provide a direct competitive advantage over oter businesses establised in te Province Companies make application to Government for EDGE status and te Department performs an assessment of te criteria. Te Departmental assessments are forwarded to te EDGE Board wic makes recommendations to te Lieutenant-Governor in Council (Cabinet). Pursuant to te Act, te Board is comprised of public and private sector members appointed by Cabinet. Under te Act, te EDGE program initially provided significant tax incentives over a 10 year period wit a pase down period of 5 years, a $2,000 grant for eac permanent job created during te initial 5 year term of te contract, access to unserviced Crown Land for $1, and te availability of EDGE facilitators to assist wit regulatory requirements. Effective 1 April 1997, te $2,000 start-up job grant for new EDGE Auditor General of Newfoundland and Labrador 431

companies was discontinued and te retail sales tax incentives, oter tan for insurance premiums, were no longer applicable wit te establisment of te armonized sales tax system. Effective 1 January 2002, amendments to te Act introduced a new 50% rebate on Federal corporate income tax for eligible EDGE corporations, an increase in te eligibility period from 10 years to 15 years for EDGE companies outside te norteast Avalon, and more stringent conditions relating to eligibility criteria in tat corporations must acieve and maintain and not just sow potential to acieve and maintain te criteria. Tese canges only apply to EDGE corporations wic applied after 1 January 2002. Scope and Objectives Our review of te EDGE program was completed in October 2004. Te objectives of our review were to assess weter: EDGE corporations are properly assessed, approved and monitored; and program objectives, performance indicators and measurable targets ave been establised, and actual results are measured and reported against tese targets. Conclusions Te Department of Innovation, Trade and Rural Development's objective for te EDGE program is to encourage new businesses to start or expand in Newfoundland and Labrador. However, since te Department as not establised specific targets for te program, it cannot determine weter te program objective is being met or weter te EDGE program is a success. Our review indicated te following: As of June 2004, 53 (43%) of te 122 EDGE corporations wic were approved under te EDGE program since it began in 1995 ad teir EDGE status revoked by Cabinet for failing to meet te requirements of te program. Te remaining 69 approved EDGE corporations reported employment and capital investment for 2004 far below te total amounts projected. Wile employment and capital investment by EDGE corporations are two of te main EDGE program performance indicators, tese indicators ave sown a significant decrease between 2001 and 2004. Te estimated employment declined from a projection of 3,850 jobs in 2001 to a projection of 2,777 in 2004, wit actual reported employment for 2004 of only 1,473. Te estimated amount of capital investment declined from a projection of $1.12 billion in 432 Auditor General of Newfoundland and Labrador

2001 to a projection of $187.9 million in 2004, wit actual reported investment for 2004 of only $70.3 million. Te Department of Innovation, Trade and Rural Development is not adequately monitoring program activity. As a result, neiter te Department nor te House of Assembly can determine weter te program as been successful in meeting its objective. In particular: te Department as not establised specific targets in te areas of jobs created, capital invested, incremental sales and substantial net economic benefit to te Province; te management information system used by te Department to record information on eac EDGE corporation is not being used for monitoring and periodic reporting; EDGE corporations are not always providing annual reports to te Minister as required and te Department is not always following up wit te corporations to obtain tese reports; and neiter te Department of Innovation, Trade and Rural Development nor te Department of Finance receive information on all incentives provided to EDGE corporations. EDGE applications are not always approved on a timely basis and in accordance wit te Economic Diversification and Growt Enterprises Act. Te average time delay between te receipt of te application and te approval by Cabinet was 7 monts. One application was not approved until 11 monts after te application was received. Tese delays are in large part due to infrequent meetings of te EDGE Board and te fact tat Cabinet is not providing its decision witin te 30 day timeframe set out in te Act. Corporations tat qualify for EDGE status are provided certain tax incentives and prior to 2003 were provided wit wage grants. Our review indicated tat incentives provided to some EDGE corporations were not adequately supported. Findings and Recommendations Application Process From te implementation of te EDGE program in 1995 to 15 June 2004, te Department ad received 298 applications for EDGE status. Of tese 298 applications, 192 were assessed and provided to te EDGE Board for recommendation and 106 did not provide te necessary information to assess te application or were witdrawn by te company or are still in te Auditor General of Newfoundland and Labrador 433

Figure 2 assessment pase. Figure 2 summarizes information gatered during te application process. Department of Innovation, Trade and Rural Development Economic Diversification and Growt Enterprises Program Statistical Information 6 Oct. 95 14 Oct. 98 30 Oct. 99 10 Nov. 00 24 Oct. 01 8 April 03 15 June 04 Approved applications 28 86 97 108 114 120 122 Rejected applications 21 55 59 63 66 70 70 Deferred applications 11 3 5 6 6 6 0 Total applications assessed 60 144 161 177 186 196 192 Revoked applications (1) (20) (30) (37) (42) (53) (53) Active EDGE companies Not available Not available Not available 41 46 46 50 # of estimated jobs on applications approved 666 2,452 3,549 3,656 3,850 2,950 2,777 Amount expected to be invested in capital $194.2 M $164 M $1.12 B $1.14 B $1.12B $1.07B $187.9 M Source: Department of Innovation, Trade and Rural Development As te Figure sows, bot te number of estimated jobs and te expected amount of capital to be invested dropped significantly between 2001 and 2004. As of June 2004, 53 of te 122, or 43% of EDGE corporations wic were approved EDGE since 1995 ad teir EDGE status revoked by Cabinet. Tis is an increase of 11 revoked applications since October 2001, an increase of 26%. A significant portion of te decrease in te number of estimated jobs related to te EDGE status for Friede Goldman Newfoundland Limited (Marystown sipyard) being revoked in October 2002. Te Department indicated tat in 1998 tis company ad estimated tat 900 jobs would be created. 434 Auditor General of Newfoundland and Labrador

Similarly, a significant portion of te decrease in te expected amount of capital to be invested related to te EDGE status for two related companies being revoked in Marc 2004. Te Department indicated tat in 1999 tese companies ad estimated tat $883 million would be invested. Only 8 companies ave been approved EDGE status since 1 January 2002. In order to qualify for EDGE status a company must submit an application and meet certain eligibility criteria. 1. Application Assessment and Approval Applications for EDGE are submitted to te Department and are to be accompanied by a business plan. Applications are assessed by te Department's two Industrial Developmental Officers and forwarded to te EDGE Board wic makes recommendations to Cabinet for approval or rejection. From 1 January 2002 to 15 June 2004, te Department received 33 applications for EDGE approval. As at 15 June 2004, te Board recommended tat 7 of tese 33 applications, as well as 1 application received prior to 1 January 2002, be approved by Cabinet. A review of tese 8 applications indicated tat tey were not approved on a timely basis and in accordance wit te Act. For example: Te average time delay between te receipt of te application and te approval by Cabinet was 7 monts. One application was not approved until 11 monts after te application was received. Officials indicated tat te main reasons for tese delays are te EDGE Board does not meet on a regular basis, Cabinet is not providing its decision witin te 30 day requirement of te Act (i.e. after receipt of te Board's recommendation), and EDGE companies do not provide information on a timely basis. Altoug te Act provides for te appointment and composition of te Board and states tat applications sall be evaluated by a Board, tere is no provision for ow often te Board sould meet. Our review indicated tat te Board as only met six times from 1 January 2002 to October 2004. Altoug te Act requires Cabinet to make its decision on a corporation's EDGE designation witin 30 days of te Board's recommendation, our review indicated tat te average time between te Board's recommendation and Cabinet's approval was approximately 105 days. Auditor General of Newfoundland and Labrador 435

Te Act requires tat te Minister of Innovation, Trade and Rural Development give notice to te House of Assembly witin 15 days after te signing of an EDGE contract or witin 15 days after te next House sitting if te House of Assembly was not in session. However, officials indicated tat no notices were made by te Minister to te House of Assembly for te 8 EDGE corporations approved since 1 January 2002. 2. Eligibility Criteria Te Department as establised specific criteria wic eac EDGE corporation must meet and maintain in order to receive EDGE approval and incentives. Our review of documentation supporting te 8 approved EDGE corporations since January 2002 indicated tat one corporation did not meet all of te criteria. Altoug one of te criteria is tat business activities would not be undertaken witin te Province or at te time of application witout te presence of EDGE incentives, te company did not meet tis criterion. Tis company ad already started te proposed operations prior to te approval of its application in August 2003. Terefore, business activities ad been undertaken before te company received EDGE status and as a result, te company did not meet tis criterion. Program Monitoring A company approved under te EDGE program can receive benefits for up to 20 years. It is terefore important tat tese companies be monitored to ensure tat te requirements of te program continue to be met. In order to monitor te results of te EDGE program we would expect te Department to ave documented policies and procedures, a management information system to record expected and actual results for eac EDGE corporation, and timely and relevant reporting. In addition, we would expect incentives provided to EDGE corporations to be properly approved and supported. 1. Policies and Procedures Te Department as establised policies and procedures for te monitoring of EDGE corporations to determine if tey are maintaining program criteria. 436 Auditor General of Newfoundland and Labrador

2. Information Systems Te Department as a management information system wic records application and approval information for eac EDGE corporation and information received from eac EDGE corporation on teir actual progress in meeting and maintaining program criteria. However, our review indicated tat te information system is not being used for monitoring and periodic reporting. As a result, te Department cannot adequately monitor program activity. For example: Te Department provided a listing of te 298 projects wic reported information related to te application date, date received, capital investment, annual sales, jobs created, type of business and te status of te application. However, te listing did not include project numbers 1216 to 1259. Tis was brougt to te attention of Departmental staff, and after searcing troug te EDGE database, a revised report was prepared wit all projects included. Altoug information regarding applications approved, rejected, deferred, incomplete, or witdrawn is recorded in te system, reports providing tis information cannot be generated by te system. Department officials indicated tat te information must be extracted from te system, and compiled separately. Tese reports are only compiled to meet specific requests. Te last status report was prepared by te Department in May 2004 wic covered te period ending 31 December 2002. Tis report provided information suc as location, activity type, year approved, type of business (new or expansion), capital investment made, jobs created, amount of incentives granted to date. 3. Reporting by EDGE Corporations EDGE corporations are required to report annually in prescribed format to te Minister on te progress made in implementing its business proposal and compliance wit te terms and conditions of teir contract witin 90 days of its fiscal year end. Te annual report must include a report from te corporation's auditor stating weter te corporation complied wit te terms and conditions of te EDGE contract. Officials indicated tat te Department will notify EDGE corporations in writing if annual reports are not submitted on time. Auditor General of Newfoundland and Labrador 437

We examined 13 EDGE corporations and determined tat EDGE corporations are not always reporting to te Minister as required and tat te Department is not always notifying te corporations of teir noncompliance. As well, te reports do not always include te required auditor's report. Witout complete and timely reports, te Department cannot determine weter EDGE corporations continue to meet eligibility requirements, weter actual results compare wit expected results and weter program objectives are being met. Our review identified te following: None of te 13 EDGE corporations examined submitted all of teir annual reports witin 90 days. Of te total 76 annual reports to be submitted by tese 13 corporations, only 3 were submitted witin 90 days. One EDGE corporation submitted its annual reports for 1997 to 2000 in September 2001. Anoter EDGE corporation as not submitted an annual report subsequent to its 2000 report. Two oter EDGE corporations ave not submitted any of teir annual reports since being approved (in 2001 for one corporation and in 2002 for te oter). Wile Departmental officials indicated tat some EDGE corporations were notified verbally were an annual report was late, te Department did not notify 12 of te EDGE corporations in writing in 26 instances were an annual report was late. 2 EDGE corporations did not include an auditor's report in 5 annual reports and 4 EDGE corporations did not attac a copy of teir financial statements to 6 of teir annual reports as required. Te Department monitors te criteria requirements relating to employment troug te submission of te annual reports; owever, te Department does not conduct regular site visits to EDGE corporations. Suc site visits would provide furter evidence of weter EDGE corporations' activities continue to meet eligibility requirements. One EDGE company reported 6 employees in 2001 wic were related to EDGE activities; owever witin te next two years tis number increased to 13. Our review indicated tat in 2002, te company transferred certain equipment from non-edge activities to EDGE activities and sales related to EDGE activities increased from 11% in 2001 to 50% in 2003. Tere was no evidence on file to indicate tat te Department conducted a site visit or oterwise ensured tat canges were reasonable and weter tey would impact EDGE incentives. 438 Auditor General of Newfoundland and Labrador

4. Program Incentives Corporations tat qualify for EDGE status are provided certain incentives suc as tax incentives and prior to 2003 were provided wit wage grants. Our review indicated tat incentives provided to some EDGE corporations were not adequately supported. For example: In one instance a corporation as not submitted any annual reports as required by te Act for 2001 onwards; owever, it continues to receive incentives suc as payroll tax forgiveness under te program. Four of te 13 EDGE corporations we reviewed received start-up job grants of $2,000 for eac job created. Te last incentive grant paid out was in 2002. Our review indicated te following: Altoug te Department uses a standard 1,820-our work year for its calculation of jobs created, te number of jobs created for one EDGE corporation included ours in excess of te 1,820 standard. As a result, te number of jobs created was overstated. For 1998, te EDGE corporation included 42 employees wit ours in excess of 1,820 ours and for 2000, tere were 112 employees wit ours in excess of 1,820 ours. In 2000, one employee reported working 3,144.5 ours. For tis one employee, an incentive grant was paid out wic accounted for 1.73 employees or $3,460. One EDGE corporation's employee listings included international employees wic te corporation excluded in its incentive grant calculation from 1998 to 2000. However, in 2001, altoug te international employees were excluded from te total number of employees, teir days of work were still included in te calculation of incremental employment created. Altoug tis information was available to te Department, officials did not follow-up on tis inconsistency. One EDGE corporation did not provide a listing of 12 salaried employees in 1998 wic accounted for 499 ours of employment. Auditor General of Newfoundland and Labrador 439

Performance Reporting In order to provide good performance reporting, strategic objectives must be clearly defined, performance indicators wic allow te evaluation of program objectives must be identified, targets for tese indicators must be set, and actual performance must be reported against tese targets. 1. Strategic Objectives Te Department as establised broad goals for te program. Te EDGE program was establised in 1995 as a strategic economic development and marketing tool to encourage new business investment in te Province to elp diversify te economy and stimulate new private sector job creation, especially in rural areas. 2. Performance Indicators Te Department as identified certain performance indicators to evaluate its objectives. Tese performance indicators include jobs created, capital invested, incremental sales, and a substantial net economic benefit to te Province. 3. Measurable Targets Te Department as not establised specific measurable targets for eac of tese performance indicators. As a result, te Department cannot compare actual results to targets in order to determine if program objectives are being met. Te Department does record te expected number of jobs to be created, investment of capital and incremental sales for eac approved EDGE corporation; owever, tis only provides targets for measuring wat te program is doing, not wat te program can or sould do. In addition, te Department as not quantified wat would qualify as a substantial net economic benefit. 4. Performance Te Department reports on te actual results of te EDGE program eac year in its annual report, wic is tabled in te House of Assembly. Information reported includes te number of new approvals, current active EDGE corporations, employment created and investment made in capital. However, since te Department as not establised specific targets it can not report on weter program objectives are being met. In addition, oter actual results of te program suc as te number of applications received, te number of approvals revoked, te amount of incentives provided, EDGE companies not complying wit reporting requirements, and weter te program continues to provide a substantial net economic 440 Auditor General of Newfoundland and Labrador

benefit to te Province are not reported. Witout tis information, te Department and te House of Assembly cannot determine weter te program is meeting its objectives. Our review indicated te following: Two of te main EDGE program performance indicators ave sown a significant decrease between 2001 and 2004 - te estimated jobs declined from 3,850 in 2001 to 2,777 in 2004 and te expected amount of capital to be invested declined from $1.12 billion in 2001 to $187.9 million in 2004. Te 69 approved EDGE corporations ad projected employment for 2004 totalling 2,777 and estimated capital investment for 2004 of $187.9 million. However, as of June 2004, tese 69 companies ad only reported employment of 1,473, and capital investment of $70.3 million. Te Department does not report te breakdown of eac job created between full-time, part-time and seasonal employees. Suc a breakdown is important for te Department to be able to assess te impact of jobs created as a result of te EDGE program. For example, a review of one of tese companies indicated tat te EDGE report received for 2000 reported 272 person years of employment created for 553 employees. We note tat 82 of tese 553 employees were employed for less tan 100 ours during te year. As part of its assessment process, te Department of Innovation, Trade and Rural Development provides financial information gatered in te application process to te Projects Analysis Division of te Department of Finance wo in turn inputs te information into a computerized economic impact analysis to determine te net economic benefit to te Province. Altoug tis process is performed in te assessment pase based on projected financial information, te Department does not conduct tis assessment eac year wit actual financial information to ensure tat business activities acieve and maintain a substantial net economic benefit to te Province. Te Department of Finance administers tax incentives provided to EDGE corporations. Te Department of Finance reported approximately $6.1 million in tax incentives eiter refunded or forgiven by te Province to EDGE corporations since te inception of te EDGE program in 1995. Auditor General of Newfoundland and Labrador 441

Te Department of Innovation, Trade and Rural Development administered te start-up job grants up until 2002, te last year grants were provided. Te Department of Innovation, Trade and Rural Development reported approximately $1.9 million in startup job grants. Figure 3 provides details on tese incentives. Figure 3 Department of Innovation, Trade and Rural Development Economic Diversification and Growt Enterprises Program Incentives Provided to EDGE Corporations 1995 to 2004 Incentive Provided to EDGE Corporation Amount Approved Amount Paid Corporate income tax $1,768,546 $1,768,546 $ - Amount Forgiven Retail sales tax 1,778,542 1,778,542 - Payroll tax 2,549,589 279,174 2,270,415 Total tax incentives 6,096,677 3,826,262 2,270,415 Start-up job grants 1,861,746 1,861,746 - Total $7,958,423 $5,688,008 $2,270,415 Altoug te Province reports te refund of corporate income taxes in te notes to te Scedule of Current Account Revenue of te Public Accounts; it does not report te amount of forgiven payroll tax for EDGE corporations in te Public Accounts of te Province. As a result, te Province as not reported over $2.5 million in forgiven payroll tax revenues since 1995. Our review indicated tat not all incentives provided to EDGE corporations are reported by Government. Witout complete and accurate information on te cost and benefits of te EDGE program, Government cannot determine te overall success of te program in meeting its objectives. For example: 442 Auditor General of Newfoundland and Labrador

Te Department of Finance reported tat 30 EDGE corporations ad not registered for purposes of payroll tax reporting. Department officials indicated tat 12 of tese companies ave exceeded payroll tax exemption amounts since being approved; owever, te Department as not determined weter tese 12 corporations ave reduced any payroll tax oterwise payable by te amount of te EDGE payroll tax incentive. Discussions wit Department staff indicated tat unregistered EDGE corporations ave been notified and tat te Department is in te process of collecting payroll information for any applicable previous years. Te Department of Finance uses a spreadseet program to record incentives approved and provided to EDGE corporations. However, at te time of our review tis spreadseet was not updated to sow all incentives provided. A review of a sample of 13 EDGE corporations identified approximately $299,000 in forgiven payroll tax for 3 corporations wic were not reported in te spreadseet. One EDGE corporation, wic registered under te payroll tax in 1996, reported employment ranging from 39 in 1997 to 90 in 2001 troug te annual reporting process; owever, it as not reported any payroll information to te Department of Finance for tese years. Te Department of Finance as requested tis information but te company ad not responded as at October 2004. As a result, te Department is not aware weter tis corporation ad reduced any payroll tax oterwise payable, by te amount of te EDGE payroll tax incentive. A municipal autority may grant a remission of property and business tax to an EDGE corporation wic establises or expands a business activity witin its boundaries. Te Department of Innovation, Trade and Rural Development reported tat 45 municipalities ad adopted te remission of municipal taxes for 10 or 15 years. Te Department, owever, does not request from te municipalities te number of EDGE corporations tat were provided wit incentives or te amount of taxes forgiven eac year. Witout tis information, te Department cannot determine te success of te EDGE program as it relates to municipal incentives. Auditor General of Newfoundland and Labrador 443

Recommendations Te Department sould ensure: applications are approved on a timely basis; EDGE corporations meet and maintain program criteria; te EDGE management information system is used in te monitoring and reporting of te EDGE program; EDGE corporations submit annual reports as required and are notified on a timely basis of non-compliance; all incentives provided to EDGE corporations from all sources are supported and recorded in te Department's management information system; and performance indicators are clear, measurable performance targets for tese indicators are establised, actual results are assessed against tese targets, and results are reported to te House of Assembly. Department s Response EDGE was designed to encourage new business start-ups and expansions in te Province. EDGE is performance based - companies must pay taxes in order to receive te EDGE benefits. Your report concludes tat because te Department as not establised specific targets for te program, it can not determine if EDGE is a success. Te Department as establised performance indicators (jobs, investment), but as not establised measurable performance targets for tese indicators. Te Department as been working on te issue over te past year and will establis measurable performance targets for EDGE beginning in 2005. Your review indicates tat over 40% of te companies tat received EDGE ave since ad teir EDGE status revoked and tat te EDGE companies ave not collectively acieved te employment and investment targets outlined in teir original business plans. New business start-ups are risky and not all succeed or indeed raise te necessary financing to start and once a company as ad its EDGE status revoked, tey no longer receive any EDGE benefits. Wile te EDGE companies did not acieve teir projected employment and investment targets, tey still created almost 1,500 jobs and generated $70 million in investment. 444 Auditor General of Newfoundland and Labrador

Your conclusion tat te Department is not adequately monitoring program activity is based on te following four issues: No establised program targets - te Department as been reviewing tis issue for te past year for all its programs and will be establising targets for EDGE for 2005. Management system used to record information is not being updated - Te Department acknowledges tat tere as been some tecnical issues wit its computerized system and are looking at ways to address te issue. Having said tis, all te information is available eiter troug te computer system or manually. EDGE corporations are not always filing activity reports and te Department is not always following up. -Te Department always follow-ups wit te companies in tis regard but not always in writing. Te Department will ensure written follow-up occurs in te future. Te Department does not receive all te information on incentives -Te Auditor General is essentially talking about incentives provided by participating municipalities - te Department will immediately begin to collect te information. Wit respect to te time frame to review applications, Government is aware of tis issue wit respect to timing and are looking at ways to speed up te process. Te Report states tat certain incentives provided to EDGE companies were not adequately supported and were calculated incorrectly. Essentially you are talking about te start-up jobs grant of $2,000 for eac new job created over 5 years. Tis was one of te initial incentives wen EDGE was first establised but was discontinued in 1997. You ave raised potential issues wit tree companies tat received te grant: One EDGE company was paid for 1.73 employees for 1 job. Te Department used person years (i.e. 1,820 ours equals 1 person year) instead of actual number of employees. Person years is a standard form used in many similar situations. Te Department is reviewing tis particular file given your comments. Auditor General of Newfoundland and Labrador 445

One EDGE company may ave received te grant for international employees wose positions were ineligible. Te Department's payment was based on an independent auditor's verification and your report is now questioning te accuracy of tis verification. In ligt of tis, te Department is reviewing tis individual file. One EDGE company did not provide a listing of twelve salaried employees in 1998 wic accounted for 499 ours of employment - te department is reviewing tis particular file. Te Department is aware tat te EDGE Act requires te Minister of Innovation, Trade and Rural Development to give notice in te House of Assembly witin fifteen days after signing of an EDGE contract. Since te new administration took office in November, 2003 until te closing of te House in te Spring of 2004, no new EDGE contracts were signed. Since ten, EDGE contracts ave been signed and a listing of all current EDGE companies was tabled in te House on December 13, 2004. Your report states tat one EDGE company did not meet te criteria - specifically it ad started operations prior to te EDGE Board recommending approval and terefore did not meet te EDGE criteria of EDGE induced (i.e. activity would not take place witout EDGE). Te Department refers to application date wen determining weter a company meets tis criterium. In tis particular case, te company submitted an EDGE application to Government prior to te start of operations; owever, it was not submitted to te officials responsible for te EDGE program. Tose officials received te application after te company commenced operation. Information on te receipt of te application was presented to te EDGE Board and government for teir consideration and it was decided to consider te date it was initially submitted to Government as te application date, wic was prior to te commenced date of operation. Wit respect to te annual reports of EDGE companies not always being submitted on time, te Department always follows-up on late annual reports but not always in writing. Te Department will now follow-up in writing. EDGE companies are not entitled to receive benefits until teir annual reports are filed. In addition, EDGE companies are currently required to file an annual report wit EDGE witin 90 days of teir fiscal year end; owever, tey ave 180 days after teir fiscal year end to file teir financial statements for income tax purposes. Consequently, many companies advise tey are unable to meet te EDGE time lines. Te Department is currently reviewing tis matter. 446 Auditor General of Newfoundland and Labrador

Your report indicated tat in one instance, an EDGE company ad not submitted any annual reports but as continued to receive benefits suc as payroll forgiveness. Te Department, as you are aware, as written several notices to te company and are actively trying to address tis matter. Your report states tat te Department did not request payroll records or perform site visits to confirm employment levels as part of its verification of employment ours for incentive grants ($2,000 per job), but instead relied on statements by te company's auditor. Te verification process required EDGE companies to ave teir independent auditors provide an audited statement verifying te payroll levels related to EDGE activity. Te independent auditor ad to sign te statement verifying te information's accuracy. To conclude, it sould be noted tat government is currently going troug a program renewal process wic is examining all government programs and services to determine teir effectiveness, including tose programs offered by te Department of Innovation, Trade and Rural Development. As well, te Department notes te Auditor General's comments wit respect to monitoring and will be reviewing our procedures in ligt of tese comments. Auditor General of Newfoundland and Labrador 447

448 Auditor General of Newfoundland and Labrador