REG - 88 Energy Limited - Quarterly Report and Appendix 5B
17/04/2025 07:10
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RNS Number : 4390F 88 Energy Limited 17 April 2025
17 April 2025
QUARTERLY ACTIVITIES REPORT
For the quarter ended 31 March 2025
88 Energy Limited (ASX:88E, AIM:88E, OTC:EEENF) (88 Energy, 88E or the
Company) provides this summary of activities for the quarter ended 31 March
2025.
Highlights
Project Leonis (100% WI)
· Multi-Reservoir Opportunity of Scale:
(Ø) Prospective Resource declared at the recently identified Canning
Prospect at Project Leonis indicates significant resource potential. Total
estimated net mean Prospective Resource of 283 MMbbls(1,2) recoverable from
the Canning Formation. Unrisked net 3U (high) 469 MMbbls, 2U (best) 259
MMbbls, and 1U (low) 136 MMbbls estimated(1,2).
(Ø) Combined internal gross mean Prospective Resource estimate across the
Canning and Upper Schrader Bluff (USB) Prospects of 798 MMbbls, with 664
MMbbls net mean prospective resource to 88E(1,2) (unrisked combined net 3U
(high) of 1,140 MMbbls, 2U (best) of 597 MMbbls and 1U (low) of 303
MMbbls(1,2)).
· Future Potential Tiri-1 Exploration Well:
Ø Planning underway for Tiri-1 well scheduled for Q1 CY26 during the Alaskan
winter operating window, targeting both the Canning and USB Prospects.
Ø Optimal Tiri-1 well location under assessment, leveraging results from the
quantitative interpretation study, in parallel with ongoing permitting and
operational planning.
Ø 88 Energy's 100% working interest provides a strong position from which to
secure a large proportionate carry on completion of the active farm-out
process, ahead of any drilling event.
Project Phoenix (~75% WI)
· Joint Venture Partner Farmout Secured:
Ø Burgundy Xploration LLC (Burgundy) settled final US$2.2 million cash call,
demonstrating its commitment to the project and progress towards its North
American public listing.
Ø Executed a farmout Participation Agreement (PA) with Burgundy securing a
full carry for the CY25/26 work program including lease rentals and horizontal
well drilling and long term production test in exchange for ~40% additional
working interest upon Phase 1 completion(3).
Ø Provides a gross US$39M (A$60M) funding avenue to advance Project Phoenix
towards a final development decision.
Ø Burgundy reaffirmed its commitment by paying 2025 cash calls, including
100% of lease costs.
· Extended Horizontal Well Test Planning:
Ø Planning and design continued for the optimisation of the planned
stimulation and extended horizontal flow test at the Franklin Bluffs gravel
pad, targeting spud in mid-2026(4).
1. Cautionary Statement: The estimated quantities of petroleum that may be
potentially recovered by the application of a future development project
relate to undiscovered accumulations. These estimates have both an associated
risk of discovery and a risk of development. Further exploration, appraisal
and evaluation are required to determine the existence of a significant
quantity of potentially recoverable hydrocarbons.
2. Refer to the ASX announcement dated 30 January 2025 for full
details. 88E is not aware of any new information or data that materially
affects the information included in the relevant market announcement and that
all material assumptions and technical parameters underpinning the estimates
continue to apply and have not materially changed.
3. For full details of the PA executed, refer to the ASX announcement
on 17 February 2025
4. Horizontal well test is subject to farmout funding as well as
government and other approvals
Project Longhorn (~65% WI)
· Production Performance:
Ø Q1 CY25 production averaged 342 BOE per day gross (~69% oil), down from 358
BOE per day in Q4 CY24.
Ø Production volumes were slightly down on the previous quarter primarily as
a result of adverse weather conditions and gas plant downtime
· Cash Flow Contribution: A$0.3 million received in March 2025 for
the Q1 CY25 period.
· Strategic Review:
Ø Internal Review of Project Longhorn's position as part of the Company's
long-term exploration strategy and asset mix was undertaken during the
quarter, with the Operator's focus on drilling new production wells as part of
the next phase of expansion, a decision was taken to explore the potential
divestment of interests in the assets to reduce exposure to ongoing CAPEX.
Corporate
· Cash balance at the end of the quarter of A$10.6 million, inclusive
of Burgundy's A$5.1 million payment of outstanding Project Phoenix cash calls,
interest and penalties.
· Strong treasury balance enables planning for the Tiri-1 exploration
well to continue, including securing long lead items and progressing the
ongoing farmout process.
Project Leonis (100% WI)
Expanded Multi-Zone Opportunity of Significant Magnitude
The expansion of Project Leonis' acreage position(5) and the addition of the
Canning Formation reservoir create a multi-reservoir opportunity of scale. The
Upper Schrader Bluff (USB) reservoir provides an attractive appraisal drilling
opportunity, targeting a Prospective Resource of 381 MMbbls of oil (net mean;
unrisked); net 3U (high) of 671 MMbbls, 2U (best) of 338 MMbbls and 1U (low)
of 167 MMbbls(1,2,4). The USB formation is the same proven producing zone as
found in nearby Polaris, Orion and West Sak oil fields to the north-west.
The addition of the Canning Formation as a secondary reservoir further
enhances Project Leonis' and creates a multi-zone drilling opportunity. The
Canning reservoir added a new prospective resource target of 283 MMbbls of oil
(net mean); unrisked net 3U (high) 469 MMbbls, 2U (best) 259 MMbbls, and 1U
(low) 136 MMbbls(1,3,4).
The identification of the Canning Prospect comes after an extensive review of
data, including newly reprocessed and interpreted Storms 3D seismic data, and
the outcome of the recently completed quantitative interpretation study (rock
physics, AVO and seismic inversion). This work has confirmed significant
prospectivity at both reservoir intervals.
In parallel, AVO analysis for both the USB and Canning intervals continues,
aiming to identify sweet spots and refine drilling locations for a potential
exploration well in H1 CY26 - the Tiri-1 well will be optimally located to
test both the Canning and USB prospects.
Guided by modern seismic re-evaluation and aided by a strategic location,
Project Leonis is a key asset in 88 Energy's portfolio.
1. Cautionary Statement: The estimated quantities of petroleum that
may be potentially recovered by the application of a future development
project relate to undiscovered accumulations. These estimates have both an
associated risk of discovery and a risk of development. Further exploration,
appraisal and evaluation are required to determine the existence of a
significant quantity of potentially recoverable hydrocarbons.
2. Refer to the ASX announcement dated 4 June 2024 for full details.
3. Refer to the ASX announcement dated 30 January 2025 for full
details.
4. 88E is not aware of any new information or data that materially
affects the information included in the relevant market announcements and that
all material assumptions and technical parameters underpinning the estimates
continue to apply and have not materially changed.
5. Highest Bidder on 4 lease blocks over Canning reservoir announced
to ASX on 12 December 2024 is subject to adjudication and regulatory approvals
prior to formal award expected in 1H 2025
Prospectivity supported by data
Historical data reinforces the compelling technical and commercial potential
of Project Leonis. The Hemi Springs Unit 3 well, drilled in 1985, targeted
deeper reservoirs than the Canning and USB Formations and without the benefit
of modern seismic data, leading to overlooked low-resistivity oil pay.
Re-evaluation of petrophysical data has since identified oil saturations
within both the USB and Canning Formations; oil shows observed in the Hemi
Springs Unit 3 mud log correlate with extensive areal mapped potential. Modern
advances in understanding low-resistivity pay have unlocked substantial
reserves across Alaska's North Slope, as demonstrated by the Willow and Pikka
fields. Similarly, 88E's re-evaluation of legacy wells led to the successful
drilling and testing of Hickory-1 in CY23-24. This approach has guided the
evaluation of Project Leonis, leveraging both historical and modern data to
identify and target untapped resources. A comprehensive Quantitative
Interpretation (QI) study, including rock physics, AVO and seismic inversion,
was completed with the primary objective of identifying anomalous responses
within the Canning feature; the secondary aim was to pinpoint "sweet spots"
within the USB reservoir. Results from the AVO and inversion analysis
confirmed significant prospectivity at both intervals, providing actionable
insights for future well planning.
Project Leonis: Forward Program
Project Leonis key milestones
Indicative Project Leonis timeline(1) H1-24 H2-24 H1-25 H2-25 H1-26 H2-26
Maiden Prospective Resource Report - USB reservoir P
Completion of QI study, mapping of Canning prospect & lease bid P
Maiden Prospective Resource Report - Canning Formation P
Planning/permitting/design for proposed Tiri-1 well n n
Targeted farmout to attract potential partners n n
Tiri-1 exploration well(1) n n
1 This timeline is indicative and subject to change. The Company reserves
the right to alter this timetable at any time.
Project Phoenix (~75% WI)
Joint Venture Partner Farmout Participation Agreement Executed
88 Energy Limited announced on 17 February 2025, that it entered into binding
terms for a Farmout Participation Agreement (PA) with Burgundy Xploration
LLC (Burgundy) in relation to Project Phoenix. Under the agreement, 88
Energy's wholly owned subsidiary, Accumulate Energy Alaska, Inc. (Accumulate),
will be provided with a full carry for all costs associated with the planned
horizontal well program, including an extended flow test currently scheduled
for mid-2026.
Transaction highlights:
· Burgundy to fully fund up to US$39 million (approx. A$60 million)
of Project Phoenix's total gross future work program costs in exchange for up
to an additional 50% Working Interest (WI) in Project Phoenix from 88 Energy.
· Provides a clear funding avenue to advance Project Phoenix towards
a final development decision via a two-phase farm-in arrangement:
Ø Phase 1: Burgundy to fund US$29 million (approx. A$45 million) for CY25/26
work program, including drilling of a horizontal well and production testing
scheduled for H1 CY26 (88E fully carried, Accumulate WI post Phase 1 farmout
35%)
Ø Phase 2: Upon Phase 1 Success; Burgundy to fund up to US$10 million
(approx. A$15 million) for an additional well or other CAPEX program (88E
carry up to US$7.5 million, based on the current 75%, with Accumulate WI post
Phase 2 farmout to 25%).
The recently announced PA marks a key milestone for 88 Energy, serving to
financially de-risk Project Phoenix while delivering significant value for
shareholders. Importantly, the PA implies a transaction value approximately
50% higher than 88 Energy's invested capital in Project Phoenix since
mid-CY22, while enabling 88E's investors to continue to participate in future
success. Following completion of the PA, Burgundy will become the operator of
Project Phoenix, enabling 88 Energy to focus on advancing and de-risking
Project Leonis.
The Company also received final payments of A$5.1 million, including penalties
and interest, from Burgundy for its outstanding cash call related to the
Hickory-1 flow test.
88 Energy has commenced work with Burgundy to progress planning and permitting
for the horizontal test well and flow back operation scheduled for mid-CY26.
Project Phoenix key milestones
Indicative Project Phoenix timeline(1) H1-24 H2-24 H1-25 H2-25 H1-26 H2-26
Successful Hickory-1 flow test flows light crude oil to surface P
Post-well analysis and updated Contingent Resource Estimate P
Targeted farmout to de-risk and provide pathway to production test P
Planning/permitting/design for proposed horizontal well n n n
Extended horizontal production test(2) n n
1 This timeline is indicative and subject to change. The Company reserves
the right to alter this timetable at any time.
(2) Horizontal production test subject to Burgundy funding / 2025 public
listing, as well as government and other approvals.
Near Neighbour Activities
The Company is monitoring neighbouring leaseholder, Pantheon Resources PLC
(Pantheon), following the successful spud of its Megrez-1 well in December
2024, and commencement of its extended multi-zone well test in H1 CY25.
Namibia PEL 93 (20% WI)
Namibia is recognised as one of the world's most prospective, under-explored
onshore frontier basins, offering significant potential for large-scale
hydrocarbon discoveries. Petroleum Exploration Licence 93 (PEL 93) situated in
the Owambo Basin, spans an area more than ten times the size of 88 Energy's
Alaskan portfolio and over 70 times larger than Project Phoenix.
Historical Exploration Activities:
· Joint Venture (JV) operator Monitor Exploration Limited
(Monitor), which holds a 55% working interest, utilised geological and
geophysical methods to identify the Owambo Basin.
· Awarded in 2018, PEL 93 contains ten (10) independent
structural closures, identified through airborne geophysical techniques and
partially verified by existing 2D seismic data.
Recent Developments:
In July 2024, Polaris Natural Resources Development Ltd (Polaris) acquired
203-line km of 2D seismic data. Data processing completed in Q4 CY24
identified significant structural closures with promising hydrocarbon
potential:
· High-quality seismic data: Strong signal-to-noise ratios
observed across all nine seismic lines.
· Interpretation by Monitor: Confirmed multiple significant leads
in the southern PEL 93 area, with individual closures up to ~100 km² in size,
showing good vertical relief, and clear hydrocarbon charge potential.
Forward Activities:
· Independent validation of Monitor's findings, integrating
available datasets, including well logs, airborne geophysics and soil
geochemistry.
· Delivery of a maiden, independently certified Prospective
Resource estimate in 1H CY25.
· Identification of drilling locations targeting the Damara Play.
Regional Context:
· Recon Africa (TSXV: RECO) spudded the Naingopo-1 well in PEL 73
in July 2024, reaching TD of 4,184 metres in November 2024. Results from
extensive evaluations, including wireline logging and coring, are eagerly
anticipated.
· In August 2024, BW Energy Limited farmed into PEL 73 (20%
working interest for US$16 million invested), further demonstrating industry
confidence in the Owambo Basin's potential.
Project Longhorn (~65% WI)
Production through Q1 CY25 averaged 342 BOE/day gross (~64% oil), down from
358 BOE/day gross in Q4 CY24 due to adverse weather and gas plant downtime. In
March 2025, a cash flow distribution of approximately A$0.3 million was
received.
An internal review of Project Longhorn's position as part of the Company's
long-term exploration strategy and asset mix was undertaken during the
quarter, with the Operator's focus on drilling new production wells as part of
the next phase of expansion, a decision was taken to explore the potential
divestment opportunities of interests in the assets to reduce exposure to
ongoing CAPEX as well as realise existing value in the asset. Discussions with
external parties for the sale of working interest commenced and there is no
guarantee that a transaction will take place.
Finance
At 31 March 2025, the Company's cash balance was A$10.6 million. The ASX
Appendix 5B attached to this quarterly report contains the Company's cash flow
statement for the quarter.
The material cash flows for the period include:
· Final Burgundy outstanding cash call related to Hickory-1 flow
test of A$5.1 million received, including interest and penalties.
· Exploration and Evaluation Expenditure: A$1.0 million (December
2024 quarter A$0.6 million) related to Leonis permitting and planning and PEL
93 2025 work program and budget costs.
· Staff and Administration Costs: A$0.9 million (December 2024
quarter A$0.9 million) in line with previous quarter, and includes fees paid
to Directors and consulting fees paid to Directors of A$0.3 million.
Corporate
Subsequent to quarter-end, the Company appointed leading independent
investment bank Hannam & Partners ('H&P') who have been engaged
alongside Cavendish to assist with its North Hemishphere public market
engagements.
Information required by ASX Listing Rule 5.4.3
Project Name Location Net Area Interest at beginning of Quarter Interest at end of Quarter
(acres)
Phoenix Onshore, North Slope Alaska 44,562 ~75% ~75%
Peregrine(1) Onshore, North Slope Alaska (NPR-A) 125,735 100% 100%
Longhorn Onshore, Permian Basin Texas 2,830 ~65% ~65%
Leonis(2) Onshore, North Slope Alaska 25,431 100% 100%
Umiat(3) Onshore, North Slope Alaska (NPR-A) 17,633 100% 100%
PEL 93 Onshore, Owambo Basin, Namibia 914,270 20% 20%
1. Refer announcement released to ASX on 21 December 2023 regarding
Project Peregrine initial suspension, which was extended by the BLM until 30
November 2025
2. Refer announcement released to ASX on 12 December 2024, regarding
highest bidder of 4 additional leases covering ~10,203 net acres. Award
expected in 1H 2025.
3. Refer 2024 Half Yearly announcement released to ASX on 2 September
2024, regarding Umiat 12-month suspension until 30 June 2025
Pursuant to the requirements of the ASX Listing Rules Chapter 5 and the AIM
Rules for Companies, the technical information and resource reporting
contained in this announcement was prepared by, or under the supervision of,
Dr Stephen Staley, who is a Non-Executive Director of the Company. Dr Staley
has more than 40 years' experience in the petroleum industry, is a Fellow of
the Geological Society of London, and a qualified Geologist / Geophysicist who
has sufficient experience that is relevant to the style and nature of the oil
prospects under consideration and to the activities discussed in this
document. Dr Staley has reviewed the information and supporting documentation
referred to in this announcement and considers the prospective resource
estimates to be fairly represented and consents to its release in the form and
context in which it appears. His academic qualifications and industry
memberships appear on the Company's website, and both comply with the criteria
for "Competence" under clause 3.1 of the Valmin Code 2015. Terminology and
standards adopted by the Society of Petroleum Engineers "Petroleum Resources
Management System" have been applied in producing this document.
This announcement has been authorised by the Board.
Media and Investor Relations:
88 Energy Ltd
Ashley Gilbert, Managing Director
Tel: +61 (0)8 9485 0990
Email:investor-relations@88energy.com
Fivemark Partners, Investor and Media Relations
Michael Vaughan Tel: +61 (0)422 602 720
EurozHartleys Ltd
Dale Bryan Tel: +61 (0)8 9268 2829
Cavendish Capital Markets Limited
Derrick Lee / Pearl Kellie Tel: +44 (0)131 220 6939
Hannam & Partners
Leif Powis / Neil Passmore Tel: +44 (0) 207 907 8500
Information required by ASX Listing Rule 5.4.3 - Lease Schedules as at 31
March 2025
Appendix 5B
Mining exploration entity or oil and gas exploration entity quarterly cash flow report
Name of entity
88 Energy Limited
ABN Quarter ended ("current quarter")
80 072 964 179 31 March 2025
Consolidated statement of cash flows Current quarter Year to date (3 months)
$A'000
$A'000
1. Cash flows from operating activities - -
1.1 Receipts from customers
1.2 Payments for - -
(a) exploration & evaluation
(b) development - -
(c) production - -
(d) staff costs (438) (438)
(e) administration and corporate costs (490) (490)
1.3 Dividends received (see note 3) - -
1.4 Interest received 30 30
1.5 Interest and other costs of finance paid - -
1.6 Income taxes paid - -
1.7 Government grants and tax incentives - -
1.8 Other - -
1.9 Net cash from / (used in) operating activities (898) (898)
2. Cash flows from investing activities - -
2.1 Payments to acquire or for:
(a) entities
(b) tenements (46) (46)
(c) property, plant and equipment - -
(d) exploration & evaluation (979) (979)
(e) investments - -
(f) other non-current assets - -
2.2 Proceeds from the disposal of: - -
(a) entities
(b) tenements - -
(c) property, plant and equipment - -
(d) investments - -
(e) other non-current assets - -
2.3 Cash flows from loans to other entities - -
2.4 Dividends received (see note 3) - -
2.5 Other - Joint Venture Contributions 5,105 5,105
Other - Distribution from Project Longhorn 262 262
Other - Return of Bond - -
2.6 Net cash from / (used in) investing activities 4,342 4,342
3. Cash flows from financing activities - -
3.1 Proceeds from issues of equity securities (excluding convertible debt
securities)
3.2 Proceeds from issue of convertible debt securities - -
3.3 Proceeds from exercise of options - -
3.4 Transaction costs related to issues of equity securities or convertible debt - -
securities
3.5 Proceeds from borrowings - -
3.6 Repayment of borrowings - -
3.7 Transaction costs related to loans and borrowings - -
3.8 Dividends paid - -
3.9 Other (provide details if material) - -
3.10 Net cash from / (used in) financing activities - -
4. Net increase / (decrease) in cash and cash equivalents for the period
4.1 Cash and cash equivalents at beginning of period 7,198 7,198
4.2 Net cash from / (used in) operating activities (item 1.9 above) (898) (898)
4.3 Net cash from / (used in) investing activities (item 2.6 above) 4,342 4,342
4.4 Net cash from / (used in) financing activities (item 3.10 above) - -
4.5 Effect of movement in exchange rates on cash held (49) (49)
4.6 Cash and cash equivalents at end of period 10,593 10,593
5. Reconciliation of cash and cash equivalents Current quarter Previous quarter
at the end of the quarter (as shown in the consolidated statement of cash flows) to the related items in the accounts
$A'000
$A'000
5.1 Bank balances 10,593 7,198
5.2 Call deposits - -
5.3 Bank overdrafts - -
5.4 Other (provide details) - -
5.5 Cash and cash equivalents at end of quarter (should equal item 4.6 above) 10,593 7,198
6. Payments to related parties of the entity and their associates Current quarter
$A'000
6.1 Aggregate amount of payments to related parties and their associates included 343
in item 1
6.2 Aggregate amount of payments to related parties and their associates included -
in item 2
Note: if any amounts are shown in items 6.1 or 6.2, your quarterly activity
report must include a description of, and an explanation for, such payments.
6.1 Payments relate to Director and consulting fees paid to
Directors. All transactions involving directors and associates were on normal
commercial terms.
7. Financing facilities Total facility amount at quarter end Amount drawn at quarter end
Note: the term "facility' includes all forms of financing arrangements available to the entity.
$US'000
$US'000
Add notes as necessary for an understanding of the sources of finance available to the entity.
7.1 Loan facilities - -
7.2 Credit standby arrangements - -
7.3 Other (please specify) - -
7.4 Total financing facilities - -
7.5 Unused financing facilities available at quarter end -
7.6 Include in the box below a description of each facility above, including the
lender, interest rate, maturity date and whether it is secured or unsecured.
If any additional financing facilities have been entered into or are proposed
to be entered into after quarter end, include a note providing details of
those facilities as well.
8. 1.1 Estimated cash available for future operating activities $A'000
8.1 Net cash from / (used in) operating activities (item 1.9) (898)
8.2 (Payments for exploration & evaluation classified as investing activities) (979)
(item 2.1(d))
8.3 Total relevant outgoings (item 8.1 + item 8.2) (1,877)
8.4 Cash and cash equivalents at quarter end (item 4.6) 10,593
8.5 Unused finance facilities available at quarter end (item 7.5) -
8.6 Total available funding (item 8.4 + item 8.5) 10,593
8.7 Estimated quarters of funding available (item 8.6 divided by item 8.3) 5.64
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7.
8.8 If item 8.7 is less than 2 quarters, please provide answers to the following
questions:
8.8.1 Does the entity expect that it will continue to have the current
level of net operating cash flows for the time being and, if not, why not?
Answer:
n/a
8.8.2 Has the entity taken any steps, or does it propose to take any
steps, to raise further cash to fund its operations and, if so, what are those
steps and how likely does it believe that they will be successful?
Answer:
n/a
8.8.3 Does the entity expect to be able to continue its operations and
to meet its business objectives and, if so, on what basis?
Answer:
n/a
Note: where item 8.7 is less than 2 quarters, all of questions 8.8.1, 8.8.2
and 8.8.3 above must be answered.
1.2 Compliance statement
1 This statement has been prepared in accordance with accounting
standards and policies which comply with Listing Rule 19.11A.
2 This statement gives a true and fair view of the matters
disclosed.
Date: 17 April 2025
Authorised by: By the Board
(Name of body or officer authorising release - see note 4)
1.3 Notes
1. This quarterly cash flow report and the accompanying
activity report provide a basis for informing the market about the entity's
activities for the past quarter, how they have been financed and the effect
this has had on its cash position. An entity that wishes to disclose
additional information over and above the minimum required under the Listing
Rules is encouraged to do so.
2. If this quarterly cash flow report has been prepared in
accordance with Australian Accounting Standards, the definitions in, and
provisions of, AASB 6: Exploration for and Evaluation of Mineral Resources and
AASB 107: Statement of Cash Flows apply to this report. If this quarterly cash
flow report has been prepared in accordance with other accounting standards
agreed by ASX pursuant to Listing Rule 19.11A, the corresponding equivalent
standards apply to this report.
3. Dividends received may be classified either as cash flows
from operating activities or cash flows from investing activities, depending
on the accounting policy of the entity.
4. If this report has been authorised for release to the
market by your board of directors, you can insert here: "By the board". If it
has been authorised for release to the market by a committee of your board of
directors, you can insert here: "By the [name of board committee - eg Audit
and Risk Committee]". If it has been authorised for release to the market by a
disclosure committee, you can insert here: "By the Disclosure Committee".
5. If this report has been authorised for release to the
market by your board of directors and you wish to hold yourself out as
complying with recommendation 4.2 of the ASX Corporate Governance Council's
Corporate Governance Principles and Recommendations, the board should have
received a declaration from its CEO and CFO that, in their opinion, the
financial records of the entity have been properly maintained, that this
report complies with the appropriate accounting standards and gives a true and
fair view of the cash flows of the entity, and that their opinion has been
formed on the basis of a sound system of risk management and internal control
which is operating effectively.
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