INTERNAL AUDIT SERVICES Pin#

Transcription

1 The Queens Borough Public Library Merrick Boulevard Jamaica, New York REQUEST FOR PROPOSALS INTERNAL AUDIT SERVICES Pin# April 8, 2014 Proposals must be received by May 9, 2014

2 TABLE OF CONTENTS I. CORPORATE OVERVIEW 3 A. QUEENS BOROUGH PUBLIC LIBRARY 3 B. QUEENS LIBRARY FOUNDATION 4 II. GENERAL INFORMATION 5 III. INSURANCE REQUIREMENTS 5 IV. TERM OF ENGAGEMENT 6 V. SERVICES REQUIRED 6 A. ANNUAL INTERNAL AUDIT SERVICES 6 B. INTERNAL AUDIT SCHEDULE 8 C. ADDITIONAL SERVICES 8 VI. PROPOSAL REQUIREMENTS 9 A. PROFILE OF THE FIRM 9 B. SUMMARY OF THE FIRMS QUALIFICATIONS 9 C. WORK PLAN 10 D. FEE PROPOSAL 11 E. ADDITIONAL INFORMATION 11 VII. EVALUATION OF PROPOSALS 11 VIII. ATTACHMENTS 12 SCHEDULE A: PROFESSIONAL FEES FOR THE FOR INTERNAL AUDIT SERVICES 13 FISCAL YEAR FISCAL YEAR FISCAL YEAR FISCAL YEAR FISCAL YEAR PROPOSAL SUBMISSION REQUIREMENT FORMS 18 Form #1 - Statement Of Understanding 18 Form #2 - References 19 Form #3 - Vendor Responsibility Questionnaire 20 2

3 I. CORPORATE OVERVIEW QUEENS BOROUGH PUBLIC LIBRARY The primary function of the Library is to provide life-long learning opportunities to the public through 62 public libraries in Queens, New York. Services such as administration, finance, human resources, legal, purchasing, facilities and capital management, information technology, logistics and security management, materials management, marketing, government and community affairs, programs and services and risk management support the primary function of delivering library services by public staff at each community library. ORGANIZATION Founded in 1896 as an autonomous Library system Incorporated by the State of New York in 1907 as a Non-Profit Corporation Tax exempt under IRS Code 501(c) (3) Guided by a nineteen member Board of Trustees President & CEO, Thomas Galante FINANCIAL MANAGEMENT Chief Financial Officer Tracy Yogman, CPA Controller Malcolm W. Bryan, CPA PRIMARY REVENUE SOURCES (fiscal year 2013) The City of New York, $ 88.9 million The State of New York, $ 6.6 million United States of America, $ 5.1 million Contributions (including promises to give), $ 3.5 Interest & Dividend Income, $1.5 million Fines and Fees, $ 2.1 million Other sources, $1.1 million FINANCIAL BACKGROUND SAP Enterprise system is an integrated solution that incorporates the key business functions. Audit firms will have access to the system to view and audit all relevant documents for each transaction with related digital images. Financial Statements include the consolidation of the Queens Borough Public Library and the Queen s Library Foundation. The Library s funds are considered one general fund for governmental accounting standards purposes. The Library tracks and receives approximately 210 sources of revenue that are established and tracked as a separate fund in SAP. There are five operating funds (Fines & Fees, City Operating, Federal Erate Funds, State Aid, Workers Compensation) that require annual operating budgets that are approved by the Board of Trustees. 3

4 EMPLOYEES 922 salaried employees 735 hourly rate employees LIBRARY SITES 61 community libraries throughout the borough of Queens, New York 2 literacy centers Central Library and Corporate Offices at Merrick Blvd., Jamaica, NY CUSTOMER SERVICES Serves a population of 2.2 million people in Queens, New York Approximately 866,000 registered cardholders 17.5 million items circulated in FY 13 Twelve million customer visits last year Nearly 700, 000 customers attend cultural and educational programs per year About 6,000 adult learners participate in reading, writing and literacy programs annually Queens Library has more than 7.5 million items in its collections A computerized circulation system is networked throughout the Borough to each Library site to manage the inventory of all library materials and customer accounts The Library offers a wide variety of reading, writing and literacy programs and functions as an integral part of each community in Queens The library has nearly 1,900 computers for public use and almost 5,200 tablets 43 locations are completed with Self Check Out/PPS and Self Check In (Exterior and/or Interior) THE QUEENS LIBRARY FOUNDATION The Queens Library Foundation ( Foundation ) is a separate, nonprofit corporation that is tax exempt under IRS Code 501(c) (3) and is considered part of the reporting entity of The Queens Borough Public Library for financial statement reporting purposes. Therefore, the internal audit of The Queens Borough Public Library shall include an internal audit of all financial activity of The Queens Library Foundation as well. SAP Enterprise system is an integrated solution that incorporates the key business functions. Audit firms will have access to the system to view and audit all relevant documents for each transaction with related digital images. The Foundation s finances are managed by the Library s Finance Department and are consolidated in the Library s SAP system. The Foundation receives approximately 130 private sources of revenue that are established and tracked as a separate fund in SAP. 4

5 II. GENERAL INFORMATION The Queens Library is requesting proposals, based upon the information contained in this Request for Proposals (RFP) from qualified firms to perform comprehensive internal audit services pertaining to, but not limited to, best practices, management auditing, organizational effectiveness reporting, internal controls and compliance with laws, regulations, and Library policies. To be considered, a signed original and two (2) copies of a proposal must be received by Cristina Polychronopoulos, Purchasing Department, The Queens Borough Public Library, Merrick Boulevard, Jamaica, NY 11432, by 2 p.m. on May 9, The outside of the envelope must be clearly marked INTERNAL AUDIT SERVICES Proposals submitted by mail may be addressed as above. Any proposals received after that time will be returned to sender. All proposals will be opened at the time stated above, but will not be read aloud. Any interested party may attend. There will be no discussion or decision at the time of the opening of the proposals; however, the names of the firms which submitted a proposal will be available to interested parties upon request at the time of the proposal opening. If you should require additional information or have any questions, please Cristina Polychronopoulos at Cristina Polychronopoulos@queenslibrary.org indicating your questions or concerns and we will endeavor to respond to concerns raised as soon as practical. Any questions or concerns will be provided to all firms in writing by . The Library reserves the right to accept or reject any proposal, if in its opinion it is in the best interest of the Library. The Library also reserves the right to negotiate the proposed contract, after proposals are received, and before a contract is awarded, if two competing proposals offer similar services for a similar price. Although pricing is an integral part of the award evaluation process, the Library is not obligated by operation of any statute, by law, or regulation, to award this contract on the sole basis of cost. Factors such as services, experience, and financial stability of the firm, references, and contract requirements will also be an integral part of the contract award decision. It is the responsibility of the firm to carefully review this Request for Proposals and seek the necessary clarifications prior to submitting the proposal. The information contained in this Request for Proposals, and the written proposal from the successful firm, will be the basis of a formal contract to be executed by both parties. III. INSURANCE REQUIREMENTS 1. Maintain in full force at all times a General Liability- Commercial General Liability Insurance, occurrence form, including premises-operations, productscompleted operations, contractual, personal injury, owner-contractor protective and fire damage legal liability coverage is required. Limits for general liability coverage shall be in the minimum amount of $1,000,000 per occurrence, $2,000,000 aggregate and supply evidence of the same to the Library. 5

6 2. Maintain in full force at all times Statutory Worker s Compensation and Employers Liability Insurance for all employees of the firm to be engaged in work under the contract is required, and if any such work is sublet the firm shall require the subcontractor to maintain similar coverage for all its employees and supply evidence of the same to the Library. 3. Maintain in full force at all times Professional Liability Insurance in the minimum amount of $1,000,000 per occurrence, $2,000,000 aggregate and supply evidence of the same to the Library. As part of its submission in response to this RFP, each firm shall indicate whether it will provide a certificate of insurance to satisfy each of the three coverages listed above, and whether the firm will be able to name the Library as an additional insured for General Liability. In submitting their proposal, the firm acknowledges that the contract to be signed between the Library and the firm shall include a statement that the firm shall indemnify and hold the Library harmless for losses and defense costs arising of its actions in undertaking this engagement. If the firm does not desire to use the Library s standard indemnification agreement, the firm should include a copy of a draft agreement indemnifying the Library with their proposal. IV. TERM OF ENGAGEMENT The term of the agreement for services is for one (1) fiscal year, beginning July 1, 2014 with four (4) additional one-year renewals, which will be subject to annual review, the satisfactory negotiation of terms (including a price acceptable to both the Library and the selected firm) and the concurrence of the Library s Board of Trustees. The Library reserves the right, within its sole discretion, to terminate the audit service engagement at any time and for any reason. V. SERVICES REQUIRED The services required include but are not limited to: A. Annual Internal Audit Services 1. The Internal Audit should be conducted in accordance with the following guidance, as applicable: the Statement on Auditing Standards (SAS) 54, Illegal Acts by Clients; SAS 99, Consideration of Fraud in a Financial Statement Audit; Management Antifraud Programs and Controls (an attachment to SAS 99). 2. Perform a risk assessment of the Library s financial and organizational operations including, but not limited to, review of financial policies, procedures and practices in conjunction with the Library s Audit Committee to prioritize the areas of continued internal audit work taking into account risk, control and the size of operations. The assessment will identify systems with the greatest risk to the Library, and make recommendations for the testing of the systems. Twenty-five percent 6

7 (25%) of assessed risk areas will be audited each year so that all assessed risk areas will be completed every four years. 3. Carry out independent evaluations and appraisals of the effectiveness of the policies, rules and procedures through which financial, physical and human resources are managed. 4. Develop a comprehensive risk management process to ensure that risks are identified and evaluate existing internal controls ability to mitigate the impact and likelihood of occurrence of the identified risks. 5. Research and keep abreast of legislative issues, new audit regulations/trends, new and emerging technologies, tools, and methodology, audit practices and elicit information from knowledgeable internal/external sources in order to evaluate effectiveness and efficiency, and advocate and influence the highest standards of ethics, discipline, and professionalism. 6. Keep the Audit Committee informed of emerging trends and successful practices in auditing and controls testing. 7. Facilitate the formulation of new procedures and organizational changes and discuss changes in related policies, rules, procedures, and methods for strengthening internal controls, reducing identified risks, with timeframes for implementation of such recommendations. 8. Develop a flexible risk based annual internal audit plan using risk based support models and methodologies, and ensure its full implementation. 9. Coordinate with the external auditors, state and federal agencies, and external consultants, and that each party is not only aware of the other s work, but also well briefed on areas of concern to ensure appropriate coverage. 10. Preparation of reports to be presented to the Audit Committee, on a quarterly basis, which analyze significant risk assessment findings and details recommendations for operational/control or policy changes including enhancements or corrective action or any problems noted in the risk assessment. 11. Auditors shall be required to make an immediate, written report of all irregularities and illegal acts or indications of illegal acts of which they become aware to the Audit Committee. 12. The audit partner shall review the engagement letter, plan the audit, review draft reports and the auditor s assessment of the Library s system of internal controls with the Library s audit committee. Such meetings will be scheduled at least two weeks in advance to coordinate the committee and audit partner s availability. 7

8 13. All working papers and reports must be retained, at the auditor's expense, for a minimum of three (3) years, unless the firm/individual is notified in writing by the Library of the need to extend the retention period. The auditor will be required to make working papers available, upon request by the Audit Committee. In addition, the internal auditor shall respond to the reasonable inquiries of successor internal auditors, and current or subsequent external auditors and allow them to review working papers relating to matters of continuing accounting significance. B. Internal Audit Schedule The Library anticipates the annual internal audit schedule below: Month May June June or July Quarterly Quarterly Activity Appointment of the internal auditor for the ensuing fiscal year. Meet with the audit committee prior to commencement of the audit, to review the audit engagement letter. Risk assessment is performed by the internal audit firm in order to develop audit plan. Review the risk assessment and annual internal audit plan with the Audit Committee to ensure that high risk areas and key control activities are periodically evaluated and tested. Review and accept Internal Audit Report(s), including significant findings and recommendations completed by the internal auditor. Review progress reports from management to monitor the implementation of the internal auditor s recommendations. Review and approve Corrective Action Plan(s) to be submitted to the Internal Auditor within 90 days after the Internal Audit Report(s) is issued. C. Additional Services Special analyses and reviews, including compliance, instances of alleged fraud and unethical misconduct outside the scope of the normal risk assessment cycle and audit may be requested by the Audit Committee at hourly rates provided in the proposer s fee schedule. 8

9 VI. PROPOSAL REQUIREMENTS We request that the proposal contain, at minimum, the following information: A. Profile of the Firm a. Describe the firm s professional experience. This should include an explanation of the firm s philosophy, size, structure, and qualifications with serving not for profit organizations with a similar size and operations. Describe your firm s resources devoted to not for profit organizations. b. The firm should provide an affirmative statement that it is independent of the Queens Borough Public Library and The Queens Library Foundation as defined by generally accepted auditing standards/the U.S. General Accounting Office's Government Auditing Standards (2011). The firm should also list and describe the firm's (or proposed subcontractors') professional relationships with the Library and/or Foundation in the past five (5) years with a statement explaining why such relationships do not constitute a conflict of interest relative to performing the proposed audit. c. State whether the firm is local, regional, national, or international. Indicate the location of the office from which the work is to be done and the number of partners, managers, supervisors, seniors and other professional staff employed at that office. Describe the communications and coordination procedures which will pertain if the work is to be performed from multiple offices. B. Summary of the Firms Qualifications The proposal must include the following information for the evaluation of the firm s qualifications: a. Identify the managers, partners and supervisors who will work on the audit, including staff from other than the local office. Resumes of each supervisory person to be assigned to the audit, non-profit/library experience, experience with automated financial management systems with digital records, copies of current active certified public accounting licenses in the State of NY, copies of Certified Internal Auditing designation, and their most recent continuing education course that will be beneficial to the Library, should be included in the proposal as an appendix or attachment. b. Provide a list of professional associations that the firm holds a membership in. c. Describe recent local and regional office auditing experience similar to the type of audit and management services requested in this RFP. Provide the names and telephone numbers of three client contacts who would serve as references. Firms should place particular emphasis on their experience with libraries or nonprofit organizations. 9

10 d. Describe the firm s time constraints and deliverability of services to the Library. e. Provide information on the results of any peer reviews of its audits during the past three (3) years. In addition, the firm shall provide information on the circumstances and status of disciplinary action taken or pending against the firm during the past three (3) years with State regulatory bodies or professional organizations. f. Describe how and why your firm is different from other firms being considered, and why our selection of your firm as our internal auditors is the best decision we could make. g. Provide five (5) references that the Library may contact. The reference information should include the names, addresses and telephone numbers of individuals that are the firm s current or former clients within the past two years. C. Work plan The firm should include a summary of its formal work plan, including the audit methodology to be followed in performing the required internal audit. The firm should also indicate other areas or issues it believes should be reviewed. Proposers will be required to provide the following information on their audit approach: a. Proposed segmentation of the engagement. b. Level of staff and number of hours to be assigned to each proposed segment of the engagement. c. Type of analytical procedures to be used in the engagement. d. Approach to be taken to gain and document an understanding of the Library s internal control structure. e. Approach to be taken in testing compliance with laws and regulations. f. Approach to be taken in drawing audit samples for purposes of tests of compliance. g. Examples of reports provided throughout the course of the Audit. D. Fee Proposal Firms must submit their proposal in three parts as provided in Schedule A: Schedule of Professional Fees for Internal Audit Services attached for each of the five years contemplated in this RFP: Part I: Annual Risk Assessment and Internal Audit Provide the estimated total hours, hourly rates by classification 10

11 and the resulting all-inclusive maximum flat fee cost the firm will charge to perform the annual services as outlined herein. Part II: Special Audit Requests Indicate applicable hourly rates to compute fees for other consulting services as may be required by the Library during the year for additional services as needed. Manner of Payment: Progress payments will be made on the basis of hours of work completed during the course of the engagement. Interim billing shall cover a period of not less than a calendar month. The final payment for any audit shall become due only after the submission of all reports required and their acceptance by the Library. Should the firm encounter circumstances requiring an increase in the extent of the audit, or should the Library require an increase in the scope of the audit, written notice to that effect must be furnished to the other party in advance. The engagement can then be modified by mutual agreement of both parties as to additional work and compensation. The Library reserves the right to negotiate and modify any elements of this RFP and to negotiate with the successful firm a final fee for the proposal based upon mutually agreed upon changes or refinements in the scope of the work. E. Additional information In this section, provide any additional information the firm considers essential to successfully conduct the audit. VII. EVALUATION OF PROPOSALS The proposals will be evaluated for a total of 100 points as follows: 1. Firm qualifications that include a record of quality internal audit work, experience of the firm. (20 points) 2. Quality of the proposer's personnel (if any) to be assigned to the engagement and the quality of the proposer's management support personnel to be available for technical consultation. (30 points) 3. Quality and appropriateness of the firm s work plan and audit techniques. (30 Points) 4. Cost proposal, including an evaluation of the detailed information provided by the firm, such as the estimated hours of work to be performed by each level of staff during each segment of the engagement. (20 Points) During the evaluation process, the Library may, at their discretion, request any or all proposers to make oral presentations. Such presentations will provide proposers with an opportunity to answer any 11

12 questions the Library may have on their proposal. Not all proposers may be asked to make such oral presentations. VIII. Attachments A complete set of financial statements are attached for review: 1. The Queens Library and Affiliate Consolidated Financial Statements and Independent Auditor s Report (June 30, 2013); 2. The Queens Library and Affiliate Supplementary Information to the Financial Statements and Independent Auditor s Report (June 30, 2013); 3. The Queens Library and Affiliate Supplementary Information As Required Under OMB Circular A-11, Audits of States, Local, Governments and Non-Profit Organizations (June 2013); 4. The Queens Library Foundation, Inc. Financial Statements and Independent Auditor s Report (June 30, 2013); End of Request for Proposals 12

13 SCHEDULE A SCHEDULE OF PROFESSIONAL FEES FOR INTERNAL AUDIT SERVICES Proposers Company Name Fiscal Year: FY 2014 PART I Organization Annual Risk Assessment and Internal Audit Fees Partners Number of Hours Quoted Hourly Rates Extended Total Managers Senior Staff Junior Staff III Other (specify) TOTAL ANNUAL RISK ASSESSMENT AND INTERNAL AUDIT FEES Consulting Fees: Special Audit Requests Partners Managers Senior Staff Junior Staff Other (specify) 13

14 SCHEDULE A SCHEDULE OF PROFESSIONAL FEES FOR INTERNAL AUDIT SERVICES Proposers Company Name Fiscal Year: FY 2015 PART I Organization Annual Risk Assessment and Internal Audit Fees Partners Number of Hours Quoted Hourly Rates Extended Total Managers Senior Staff Junior Staff III Other (specify) TOTAL ANNUAL RISK ASSESSMENT AND INTERNAL AUDIT FEES Consulting Fees: Special Audit Requests Partners Managers Senior Staff Junior Staff Other (specify) 14

15 SCHEDULE A SCHEDULE OF PROFESSIONAL FEES FOR INTERNAL AUDIT SERVICES Proposers Company Name Fiscal Year: FY 2016 PART I Organization Annual Risk Assessment and Internal Audit Fees Partners Number of Hours Quoted Hourly Rates Extended Total Managers Senior Staff Junior Staff III Other (specify) TOTAL ANNUAL RISK ASSESSMENT AND INTERNAL AUDIT FEES Consulting Fees: Special Audit Requests Partners Managers Senior Staff Junior Staff Other (specify) 15

16 SCHEDULE A SCHEDULE OF PROFESSIONAL FEES FOR INTERNAL AUDIT SERVICES Proposers Company Name Fiscal Year: FY 2017 PART I Organization Annual Risk Assessment and Internal Audit Fees Partners Number of Hours Quoted Hourly Rates Extended Total Managers Senior Staff Junior Staff III Other (specify) TOTAL ANNUAL RISK ASSESSMENT AND INTERNAL AUDIT FEES Consulting Fees: Special Audit Requests Partners Managers Senior Staff Junior Staff Other (specify) 16

17 SCHEDULE A SCHEDULE OF PROFESSIONAL FEES FOR INTERNAL AUDIT SERVICES Proposers Company Name Fiscal Year: FY 2018 PART I Organization Annual Risk Assessment and Internal Audit Fees Partners Number of Hours Quoted Hourly Rates Extended Total Managers Senior Staff Junior Staff III Other (specify) TOTAL ANNUAL RISK ASSESSMENT AND INTERNAL AUDIT FEES Consulting Fees: Special Audit Requests Partners Managers Senior Staff Junior Staff Other (specify) 17

18 FORM # 1 STATEMENT OF UNDERSTANDING By signing in the space provided below, the undersigned certifies that the respondent (i) has read and understands and accepts the scope and requirements of this project and all of the attachments; (ii) has the capacity to execute this project; (iii) agrees to accept payment in accordance with the requirements of this Proposal and the standard construction services contract, and (iv) will, if its proposal is accepted, enter into a standard agreement with the Queens Borough Public Library. I hereby certify that my firm will carry all types of insurance specified in the Proposal. The undersigned further stipulates that the information in this proposal is, to the best of knowledge and belief, true and accurate. Name of Firm/Consultant By: Signature of Partner or Corporate Officer Date Print Name Title Telephone / Fax # s EIN # Address address 18

19 FORM #2 REFERENCES Consultant MUST furnish five (5) references for work/projects completed within the last three (3) years of the same general character as that specified herein. Please do not include the Queens Borough Public Library or any Queens Borough Public Library employee as a reference. 1. Name of Firm Contact Telephone 2. Name of Firm Contact Telephone 3. Name of Firm Contact Telephone 4. Name of Firm Contact Telephone 5. Name of Firm Contact Telephone 19

20 FORM # 3 VENDOR RESPONSIBILITY QUESTIONNAIRE Legal Business Name: EIN: Address of the Principal Place of Business/Executive Office: New York State Vendor Identification Number: Telephone/Fax: Website: Authorized Contact for this Questionnaire: Name: Telephone/Fax: Title: List any other DBA, Trade Name, Other Identity, or EIN used in the last five (5) years, the state or county where filed, and the status (active or inactive) (if applicable): I. Business Characteristics a. Business Entity Type: b. Was the Business Entity Formed in New York State? c. If no, indicate jurisdiction where Business Entity was formed: d. Is the Business Entity currently registered to do business in New York State with the Department of State? 20

21 e. If no, explain why the Business Entity is not required to be registered in New York State. f. Does the Business Entity have a DUNS Number? If so, what is it? g. Is the Business Entity s principal place of business/executive Office in New York State? If no, does the business entity maintain an office in New York State? h. Is the Business Entity a Minority or Women Owned Business (MWBE)? i. Identify current Key Employees of the Business Entity. Attach additional sheets, if necessary. II. Contract History a. Has the Business Entity held any contracts with the City of New York, Queens Borough Public Library and/or New York State governmental entities in the last three (3) years? If yes, attach a list including the agency name, contract amount, contract start date, contract end date and the contract description. III. Integrity: Contract Award: Within the past five (5) years, has the business entity or affiliate: a. Been denied a contract or had a bid rejected based upon a finding of nonresponsibility by a governmental entity? b. Been suspended, cancelled or terminated for cause on any government contract? 21

22 c. Been subject to an administrative proceeding or civil action seeking specific performance or restitution in connection with any government contract? d. Entered into a formal monitoring agreement as a condition of a contract award? *** For each yes answer, provide an explanation of the issue(s), the Business Entity involved, the relationship to the submitting Business Entity, the government entity involved, relevant dates and any remedial or corrective action(s) taken and the current status of the issue(s). Provide answer below or attach additional sheets with numbered responses. IV. Certifications/Licenses a. Within the past five (5) years, has the Business Entity or any Affiliate had a revocation, suspension or disbarment of any business or professional permit and/or license? *** If yes, provide an explanation of the issue(s), the Business Entity involved, the relationship to the submitting Business Entity, the government entity involved, relevant dates and any remedial or corrective action(s) taken and the current status of the issue(s). Provide answer below or attach additional sheets with numbered responses. V. Legal Proceedings: Within the past five (5) years, has the business entity or affiliate: a. Been the subject of a civil complaint? b. Been the subject of a judgment or conviction for conduct constituting a crime? c. Received any OSHA citation and Notification of penalty containing a violation classified as serious or willful? 22

23 d. Had any New York State Labor Law violation deemed willful? VI. Leadership Integrity: Within the past five (5) years, has any individual previously identified, any other Key Employees not previously identified or any individual having the authority to sign, execute or approve bids, proposals, contracts or supporting documentation within New York State been subject to: a. A sanction imposed relative to any business or professional permit and/or license? b. An investigation, whether open or closed, by any governmental entity for a civil or criminal violation for any business related conduct? c. A conviction or judgment of any business related conduct constituting a crime including, but not limited to, fraud, extortion, bribery, racketeering, price fixing, bid collusion or any crime related to truthfulness? d. Misdemeanor or felony conviction for: i. Any business-related activity, including, but not limited to, fraud, coercion, extortion, bribe or bribe-receiving, giving or accepting unlawful gratuities, immigration or tax fraud, racketeering, mail fraud, wire fraud, price fixing or collusive bidding; or ii. Any crime, whether or not business related, the underlying conduct of which related to truthfulness, including, but not limited to the filing of false documents or false sworn statements, perjury or larceny? 23

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