Risk Controls - Hedging and Commodity Risk Management

1. Develop a detailed hedging program with specific price targets, volumes and tenor based on total demand and implied risk.

2. Provide training in derivatives and risk management for senior management and the board of directors.

3. Conduct a corporate risk – self assessment.

4. Establish written policies for hedging.

5. Develop a decision - Chain of command and define roles and responsibilities.

6. Mark-to-Market daily with a specific distribution list.

7. Provide adequate financial reserves to manage hedge risk.

8. Establish a counterparty credit list detailing exposure and limits.

9. Continue to develop and expand counterparties based on credit, performance and overall relationship.

10. Establish potential margin warning signals.

11. Manage Corporate accounting and detail quarterly and annual requirements for financial reporting.

12. Provide independent support and supervision for market analysis, transactions, hedging decisions, Mark-to-Market and accounting.