This tool contains two policy samples that establish uniform procedures for identifying and recording a company’s non-routine transactions. 

In these samples, each plant controller is responsible for identifying non-routine transactions. All non-routine transactions should be formally documented in writing and forwarded to either the corporate controller or CFO upon occurrence. Any non-routine transactions will be fully disclosed in each site’s quarterly disclosure package, and any non-routine transactions that are initiated in the U.S. and that affect foreign locations (e.g., restructuring) will be formally communicated in writing to the foreign controllers prior to the initiation of the transaction.