Received Member Agencies The Honorable Sonny Sandhu, Presiding Judge Sep 2 5 2025 Superior Court of California, County*

StanCOG is not responsive to their obligations with respect to the authority of the Civil Grand Jury and the Policy Board. Stanislaus County Response: The respondent disagrees wholly or partially with the finding and shall include an explanation. <b>Policy Board Chair</b> Explanation: StanCOG is a small agency with less than 14 full-time employees. The <b>Buck Condit</b> requests of the Grand Jury were voluminous in nature, often requiring StanCOG staff to cease work on their required tasks to address the Grand Jury requests. It took time for staff to locate, produce or create the requested information. The StanCOG Policy Board was informed of the Grand Jury requests, the state and federal mandates the agency was Policy Board required to complete, and the competing deadlines of the requests and mandates and Vice-Chair provided direction to the Executive Director and General Counsel accordingly. George Carr

StanCOG has no significant oversight by its Policy Board. Response: The respondent disagrees wholly or partially with the finding and shall include an explanation. Explanation: The Policy Board approves the annual Overall Work Program and Budget, accepts audits, approves contracts, grant awards, allocations and suballocations of funding programs, TDA allocations, the Measure L Strategic Plan and funding opportunities that further the priority of projects identified in the Strategic Plan, participates in outreach and approves planning documents such as the Regional Transportation Plan/Sustainable Communities Strategy, the Regional Transportation Improvement Program and Federal Transportation Improvement Program, among others. Various standing committees such as the Executive Committee, Management & Finance Committee, Measure L Oversight Committee, Social Services Transportation Advisory Committee, Technical Advisory Committee, Bicycle and Pedestrian Advisory Committee and Citizens Advisory Committee provide recommendations to the Policy Board. The Technical Advisory Committee is made up of technical planning staff from each of StanCOG's member agencies. The Management & Finance Committee is comprised of the city managers and a representative from the county Chief Executive's office. Each of these city and county representatives keep their respective members of the Policy Board informed of items discussed at and presented to the committees. StanCOG Response Civil Grand Jury Case #25-06C

As used in the Accounting Policy in Section 9, "reasonable" is not a specific enough spending limit to be employed responsibly with respect to travel. Response: The respondent agrees with the finding. Explanation: An independent consultant has been retained to conduct a comprehensive review and update of all financial policies, which will include the accounting and travel policies. In addition, the Policy Board has created a five-person Ad Hoc committee to oversee the recommended changes and present those to the Policy Board for review, approval, and implementation.

StanCOG lacks a Director of Financial Services, and that position is subject to the authority of the Executive Director. Response: The respondent disagrees partially with the finding and shall include an explanation. Explanation: The Director of Financial Services most often reports directly to the top administrative officer in an organization and works with them to manage the agency's finances, develop budgets, and provide financial information to the agency's governing board and the public. This model is used by Stanislaus County and every city within the county. The StanCOG Deputy Director of Operations has been overseeing the finance StanCOG Response Civil Grand Jury Case #25-06C department while recruitment is underway for a full-time Director of Financial Services. In August, a Manager of Financial Services was hired filling some of the gaps created by the vacant Director of Financial Services position. StanCOG's Policy Board, not the Executive Director, should take

StanCOG's absence of a Director of Financial Services resulted in several members of upper management undertaking that role's responsibilities. The substandard performance of these duties led to delinquent audits with material findings. Response: The respondent agrees with the finding. Explanation: StanCOG continues to recruit for a Director of Financial Services, but like many agencies in California, is facing high demand for the position, a limited talent pool, and rising salary expectations. In August, a Manager of Financial Services was hired filling some of the gaps created by the vacant Director of Financial Services position.

The Employee Handbook as stated is a "working guide for Employees and supervisors." It is out of compliance with the current practices of StanCOG. Response: The Respondent disagrees wholly or partially with the finding and shall include an explanation. Explanation: The Employee Handbook is compliant with current practices because it has been reviewed by outside legal counsel every year to ensure compliance with applicable laws and regulations, incorporated current HR best practices, and aligned it with evolving agency culture and workplace trends including remote work.

The Jury found that the StanCOG Single Audit, dated June 30, 2023, had material weaknesses that caused the report to be issued late. Response: The respondent agrees with the finding. Explanation: In August, StanCOG hired a manager of Financial Services and continues to recruit for a Director of Financial Services.

There are two published Appendix A documents for full-time employee benefits. Appendix A (1/1/25) provided by the director of Administrative Services allows for nine weeks paid vacation at twelve years and Appendix A (11/17/21) provided by the General Counsel allows for only five weeks at twelve years and more. Response: The respondent agrees with the finding. Explanation: The Policy Board has created a five-person Ad Hoc committee to review the employee handbook and make recommended changes to the Policy Board for review, approval and implementation.

The Executive Director has used rental cars extensively and excessively rather than her personal vehicle due to vague policies and lack of oversight. Response: The respondent agrees with the finding. Explanation: An independent consultant has been retained to conduct a comprehensive review and update of all financial policies, which will include the accounting and travel policies. In addition, the Policy Board has created a five-person Ad Hoc committee to oversee the recommended changes and present those to the Policy Board for review, approval, and implementation.

The policy on missing receipts is not being adhered to by the Executive Director due to the lack of appropriate oversight by the Policy Board. Response: The respondent agrees with the finding. Explanation: An independent consultant has been retained to conduct a comprehensive review and update of all financial policies, which will include the accounting and travel policies. The consultant will provide training for all employees on the policies to help ensure compliance. In addition, the Policy Board has created a five-person Ad Hoc committee to oversee the recommended changes and present those to the Policy Board for review, approval, and implementation.

The expenditure category "training and education" is too broad. Response: The respondent agrees with the finding. Explanation: The Policy Board has initiated an independent investigation examining the allegations contained in the Grand Jury report. The recommendations of the independent investigation will be considered/evaluated and implemented in a manner deemed prudent by the Policy Board.