NAVIGATING THE AFFILIATED OPERATIONS PLAN: A
NAVIGATING THE AFFILIATED OPERATIONS PLAN:A GUIDE FOR INDUSTRY Business Analysis and Mitigation Strategy Division, DSS
2 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY CONTENTS3 AOP LIFE CYCLE DIAGRAM4 INTRODUCTION5 IDENTIFYING AFFILIATED OPERATIONSTypes of Affiliated Operations 5Categories of Affiliated Operations 7Human Resources8Finance and AccountingInternal Audits10Business DevelopmentMarketingLegal1213Shared Personnel1416 AOP SUBMISSION21 AOP COMPLIANCE25 CONCLUSION26 ACRONYMS & ABBREVIATIONS27 DEFINITIONS911
3 Business Analysis and Mitigation Strategy Division, DSS AOP LIFE CYCLEReviewing affiliatedoperations thatmay pose a FOCIrisk is a continuousprocess, fromidentifying sharedservices to DSSapproval andoversight.The AOP LifeCycle diagramillustrates yourcompany’s rolein each step ofthis continuousprocess.SURVEY internaladministrativeand operationalfunctions toidentify AffiliatedOperationsIdentifyRISKSpresentedby eachAffiliatedOperationWork withrelevantEMPLOYEESto developrisk mitigationmeasuresDESCRIBE AffiliatedOperations, risks,mitigation measuresand correspondingoversight, for DSSapprovalEnsureCOMPLIANCEwith theprocessesoutlined in theapproved AOP
4 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY INTRODUCTIONThe purpose of this guide is to assistcompanies with mitigating and managingaffiliated operations per the requirementsof the Foreign Ownership, Control, orInfluence (FOCI) mitigation agreement.The guide may not include all potentialareas of affiliated operations, but itoffers a starting point for Facility SecurityOfficers (FSOs) and Government SecurityCommittees (GSCs) in developing an AOP.We will discuss three important topics:1. How to identify whether your companyhas any affiliated operations, and if so,which;2. How to write an AOP for DSS’s reviewand approval; and3. How to manage your affiliated operationsfor internal and external assessments.DSS’s understanding of what form thatsharing can take, however, has evolved,and no longer just includes services that anaffiliate provides to the mitigated company.DSS considers an affiliated operation tobe a business or operational relationshipbetween a mitigated company and anaffiliate, to include any internal policy,process, or procedure that could give anaffiliate financial or operational leverageover the mitigated company.This definition covers “reverse sharedservices,” where a mitigated companyprovides a service for an affiliate, becausethose “reverse services” can still leave themitigated company vulnerable to FOCI orthe inadvertent dissemination of classifiedor otherwise sensitive information.First, however, we pause to consider thepurpose of AOPs and affiliated operationsmore generally.Affiliated operations can help companiessave time and money, but they can alsointroduce new risks, presenting subtle andcomplex mitigation challenges.Competition, best business practices, andresponsibility to stockholders have drivenindustry to identify areas where processescan be streamlined to increase efficiency.DSS introduced the AOP as a way to identifyaffiliated operations so that industry canmaintain competitiveness while reassuringDSS that FOCI is mitigated.DSS used to refer to affiliated operationsas “shared services” because affiliatedoperations often involve a mitigatedcompany sharing a service with its affiliates.Ultimately, the goal of the AOP is toreconcile DSS’s mission with industry’sneeds. As those needs evolve, so too maythe AOP.
Business Analysis and Mitigation Strategy Division, DSS 5IDENTIFYING AFFILIATED OPERATIONSWhether your company is in process for afacility clearance (FCL) or long establishedin the National Industrial Security Program(NISP), it probably shares some serviceswith or through an affiliate that mustbe reviewed by your GSC and approvedby DSS.Identifying those services can be achallenge, especially if you are not used tothinking of shared services as “affiliatedoperations.”DSS encourages you to use this guide asa resource for analyzing your company’saffiliated operations, and to foster aproductive dialogue with your FOCIaction officer.TYPES OF AFFILIATED OPERATIONSThis section will introduceseveral categories of commonlyshared services with questionsdesigned to help you tounderstand which services youshare, how you can describethem, what FOCI risks theypresent, and how you canmitigate and continuouslymonitor those risks.FOCI mitigation agreements define affiliatedoperations as cooperative endeavors,regardless of whether such endeavors,performed directly or through third partyservice providers, are administrative,operational or commercial.These endeavors include shared personnel,shared third-party services, commercialarrangements, other shared services andproducts, and affiliate technology. Mostaffiliated operations have to be approvedby DSS before the mitigated company canbegin using them.There are several considerations that canhelp you with the process of analyzing your
6 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY company and identifying which operations,if any, involve your affiliate(s).FIRST, Does sharing the service give mycompany an economic benefit it would nototherwise enjoy?For example, suppose an affiliate usessoftware for payroll processing and offersto provide it to your company for a belowmarket fee.If you accept the affiliate’s offer, it willsave your company money, but the affiliatewill also acquire a degree of leverage overyour company; in a worst-case scenario,the affiliate could threaten to cancel thesoftware sharing arrangement. This maycompel you to purchase the software froma third party at higher cost, potentiallyharming your company’s financial wellbeing.Because sharing the software therefore givesthe affiliate leverage over your company,that sharing counts as an affiliated operationand must be described in your AOP. If theaffiliate provides services rather than goods,the test for economic benefit is still satisfied.SECOND, Does using an internal processor procedure of either the affiliate or mycompany give the affiliate some operationalleverage over my company?For example, suppose an affiliate asks yourcompany to provide annual reports onyour employees’ compensation, ostensiblyto standardize salaries throughout thecorporate family. Providing that informationmay be helpful in fostering corporatesymmetry and competitive pay, but it alsogives the affiliate insight into how youmanage part of your company’s business;such insight could enable activities whichmay constitute undue leverage over yourcompany. As such, this counts as anaffiliated operation that must be includedin your AOP.THIRD, Does my company provide a benefitto the affiliate that it would otherwise notenjoy?This consideration involves a “reverseshared service,” where a mitigatedcompany provides a service to an affiliate,rather than the other way around.Here the mitigated company may acquireleverage over the affiliate, but risks ofinadvertent disclosures of information andundue influence can still arise, and still haveto be mitigated.For example, suppose an affiliate asks youto provide accounting services to them.Doing so would result in your providinga service to the affiliate it would nototherwise enjoy, making this arrangementan affiliated operation that must bedescribed in your AOP.FOURTH, Is my company using the samethird party vendor or service provider myaffiliates use?For example, suppose a mitigated companywishes to use an insurance company to
Business Analysis and Mitigation Strategy Division, DSS provide medical benefits to its employees,and it happens that the affiliate usesthe same insurer for its own employees.Because both the mitigated company andthe affiliate are using the same third partyentity, this is an affiliated operation thatmust be described in your AOP.constitute sharing an employee, makingthis arrangement an affiliated operation.FIFTH, Is my company engaged in acontract, joint research and development orteaming agreement with the affiliate that iscommercial and arms-length in nature?For example, suppose your companywishes to subcontract performance on partof a commercial contract involving thedistribution of widgets.You could conceivably engage anynumber of companies to assist with suchdistribution, but you decide to engagean affiliate since the work is unclassifiedand you have greater familiarity with theiroperations and reliability.Since you enter into this commercialagreement with the affiliate independentlyand on (more or less) equal footing, youare engaging in a cooperative commercialarrangement, which must be described inyour AOP.SIXTH, Does my company share personnelwith an affiliate?For example, suppose an affiliate asksyou to allow one of your accountants toserve as its Treasurer on a part-time basis.Permitting the accountant to do so wouldCATEGORIES OF AFFILIATEDOPERATIONSIn this section we will discussthe different categories ofaffiliated operations to assistyou in defining the specificsof your circumstances. Theexamples below are notionaland therefore may not applyperfectly to your company.An AOP should be comprehensive,describing all operations and services themitigated company shares. It should alsobe detailed enough to explain all risks7
8 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY that are inherent to that sharing, and howthe company will mitigate those risks andconduct oversight.The AOP should empower the GSC to takean active role in overseeing the company’saffiliated operations, but it should alsoexplain how DSS can conduct its ownoversight. The AOP, in short, is both asecurity plan and a governance plan, andDSS emphasizes both in its review.Also, please note that the suggestedmitigation measures discussed below areneither perfectly inclusive nor exclusive, andDSS may require additional steps on a caseby-case basis.Human ResourcesThe scope of potential Human Resources(H.R.) services is expansive, coveringeverything from assistance in hiring totermination of benefits.Some examples of H.R.-affiliated operationsare as follows: leveraging your affiliates’subject matter expertise in conducting jobinterviews; advertising job openings on anaffiliate’s website; sharing consolidatedreports on compensation.Sharing H.R. services can present FOCIrisks because of the leverage that might beacquired by your affiliates, although someof those risks can be mitigated with robustGSC oversight.When reviewing H.R. services, DSS isinterested in how much informationaffiliates can learn about your company’semployees, including the projects they workon. DSS is also interested in the affiliates’ability to affect the pool of prospectiveemployees if it assists in the hiring process.Furthermore, DSS is interested in theamount of leverage the affiliates haveover hiring, firing, compensation andperformance appraisal decisions. Somequestions you should consider include: How does my company performrecruitment functions — advertisevacancies, receive resumes, interviewapplicants, select a candidate (especiallycleared personnel and Key ManagementPersonnel [KMPs])? If vacancies are advertised on anaffiliate’s website, does the affiliate“screen” resumes before they are sentto my company? How does my company handleperformance evaluations for employees,including company officers? Whois responsible for determiningcompensation, particularly for clearedpersonnel and KMPs? Are my company’s employees able toparticipate in affiliate training programs,including employee exchange ormentorship opportunities? How are my company’s H.R. processesaudited, and by whom? How is payroll managed? Do mycompany and the affiliate share a system?
Business Analysis and Mitigation Strategy Division, DSS The risks involved in H.R. servicesinclude exposure of details related tooperations security (OPSEC) establishedby the Government Contracting Activity(GCA) pursuant to contract requirements;identification of classified programsand employees; and undermining themanagerial independence of the mitigatedcompany (to include influence over salariesand compensation).These risks may be mitigated by carefullyreviewing all information that is sharedwith the affiliates to ensure that theidentity of individuals with personnelsecurity clearances and details about theirprojects are not included, and by ensuringthat all personnel decision-making authorityrests with the mitigated company. Theamount of mitigation required will dependon the amount of influence the affiliatesmight be able to exert when personneldecisions are made.Finance and AccountingYour affiliates are entitled to receiveinformation about your company’sfinancial situation on a regular basis. Buta company might wish to share more thaninformation with its affiliates; perhaps youwant to share a bank account for cashflow purposes, or perhaps your affiliatewants to file consolidated tax returns foryour company. The ultimate parent maywish to standardize accounting proceduresthroughout the corporate family.Given the importance of accounting incorporate governance, leveraging financial9services must be considered and monitoredcarefully. (Audits are discussed separately.)When reviewing requests for affiliatedoperations in the financial arena, DSSwill look to ensure that the GSC is ableto review the procedures used to reportinformation to the affiliates. If the affiliateswish to assist with accounting services, themitigated company must maintain controland oversight of its own books.As with H.R. services, the mitigated companymust consider how the requested servicesmight allow the affiliates to obtain leverage,thereby unduly influencing its decisionmaking. The mitigated company mustalso consider whether the services mightcompromise its financial viability. Somequestions you may want to consider include: How does my company report financialdata to its affiliate(s), and does the GSCreview the data or the format of thereporting in advance? When my company reports financialdata, is a shared network connectionused? How does my company manage budgetdevelopment, and who has finalapproval authority? How does my company manageaccounts payable/receivable? Does my company share a cash poolor bank account with the affiliate, anddoes the affiliate have either deposit orwithdrawal authority?
10 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY How are taxes done for my company,and does the GSC review the formatof reporting tax information to theaffiliates?For those reasons, you may find thethreshold required for being allowed toconduct an internal audit is typically higherthan other shared services.The risks associated with finance andaccounting services include exposure ofOPSEC details; undermining the managerialindependence of the mitigated company;adversely affecting short-term cash flow;and unduly influencing long-term projectfinancing and budget decisions.If the affiliates request internal auditing asa service, DSS is interested in the safeguardsemplaced to prevent the inadvertentdisclosure of classified and other sensitiveinformation. DSS will also consider howthe results of the audit are conveyed tothe mitigated company, and whether theGSC is empowered to accept or reject anysuggestions corresponding to those results.Some questions you should ask include:These risks can be mitigated by: havingthe GSC review and approve the format forreporting all financial data; aggregatingand screening data respecting classifiedprograms; masking locations, employees,and customer line items; reserving theright to obtain financial services from athird party; ensuring that the mitigatedcompany’s board maintains the ability topay for operations expenses without affiliateintervention; and ensuring that the Boardretains final decision-making authority.Internal AuditsAs part of accounting operations, someaffiliates may want to play a role inconducting regular audits of your company.While this can be helpful in promotinguniform practices throughout a corporatefamily and identifying irregularities, it canalso potentially enable the affiliates to learnabout a mitigated company’s classifiedprojects and cleared employees; it can alsounduly influence the company’s operationalindependence. How are internal audits of mycompany’s processes and/or financesconducted and by whom precisely? Willthe audits be conducted by internalauditors or third-party auditors? Who determines the scope, schedule,and methodology of the internal audits,and is the GSC empowered to approveit all? How will my company preventthe auditors from obtaining eveninadvertent access to sensitiveinformation? Who receives the results and findingsof the internal audits, and is the GSCempowered to review those findingsbefore they are sent to the affiliates?How are they then protected? Who has decision-making authorityover the adoption of auditorrecommendations?
Business Analysis and Mitigation Strategy Division, DSS Some of the risks of conducting internalaudits have been discussed above, butothers include the inadvertent disclosureof OPSEC and other sensitive information;compromising the managerial independenceof the mitigated company; inviting undueinfluence on process improvements thatmight affect performance on classifiedcontracts; relying on an affiliate for abusiness-critical function; and identifyingemployees and their work.Possible mitigation strategies includethe mitigated company maintaining aninternal audit capability or using a thirdparty auditor; heavily involving the GSCin the development of the internal auditscope and process (affiliate expertisemay be used while developing the scopeof the audit, however the audit mustbe conducted by internal or third-partyauditors); empowering the security staffand GSC to monitor the audit and review allinformation, including the audit’s results,before being shared with the affiliates;allowing the mitigated company’s boardto have sole authority to accept or rejectinternal audit recommendations.Business DevelopmentLeveraging business development (BD)operations with affiliates could take theform of contracting support, sales, researchand development (R&D), or supply chaincoordination.This coordination could allow the affiliatesto assume an oversized role in themanagerial decisions of the mitigated11company, presenting clear and importantFOCI risks that must be mitigated.When DSS reviews affiliated BD operations,it will be especially concerned with ensuringthat all decision-making authority rests withthe mitigated company’s board. DSS willscrutinize carefully any arrangement thatempowers the affiliates to act or speak onbehalf of the mitigated company.DSS will also consider the extent to whichprocurement activities affect the supplychain for a product being used by the U.S.Government, and how that supply chain issecured. If the mitigated company wishesto sub-contract work to an affiliate, orbe a sub-contractor for an affiliate, DSSwill examine how the GSC monitors andoversees the arrangement, and how thegovernment customer is notified. Somequestions you may ask include: How does my company identifyprospective BD opportunities andclients, and how do the affiliates assistwith those processes, if at all? Do the foreign affiliates liaise directlywith government customers onbehalf of my company, or have anyrepresentational authority? Does my company resell or licenseproducts or services of the foreignaffiliates in connection withprocurement activities? Does my company use foreign affiliatetechnology in the performance ofclassified or unclassified contracts?
12 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY What involvement if any do affiliateshave in my company’s R&D?independence. Some questions you mayask include: If my company enters into a subcontract agreement with an affiliate,how will the GSC monitor the project toensure there is no undue FOCI? How does my company managemarketing, particularly trade shows, pressreleases, branding, and client services?The potential risks of leveraged BDservices include exposure of OPSEC andother sensitive information; undermining themanagerial independence of the mitigatedcompany; supply chain vulnerabilities; andconfusion among government customersabout which corporate entity is providing aservice or product.These risks can be mitigated by ensuringthe affiliates are not authorized to representor bind the mitigated company in contract;testing affiliates’ technology/products priorto delivery to the government customer;reserving all ultimate BD decisions, includingchoice of vendors, to the mitigatedcompany; notifying the governmentcustomer anytime the cleared companyuses technology, products or services froman affiliate in the performance of classifiedcontracts (a copy of such notificationmust be included as an addendum to theAOP); and making all affiliated commercialarrangements arms-length transactions.MarketingWhile advertising and other affiliatedmarketing operations are relativelystraightforward, DSS will consider whetheraffiliate involvement compromisesthe mitigated company’s operational Does my company provide contract orprogram information to the affiliates formarketing purposes? Do the FSO and the TechnologyControl Officer (TCO) review marketinginformation before it is sent to affiliates,and do they report to the GSC on thematter? How much independence does mycompany have in its marketing plansand strategies? Can my company obtain the samemarketing services from a third party? Is my company required to participatein any marketing-related activities at theaffiliates’ behest?The potential risks of sharing marketingservices include exposure of OPSEC detailsand other sensitive information, andcompromising the mitigated company’soperational independence.Most marketing-related risks can bemitigated by requiring the FSO to reviewany information prior to release to theaffiliates; notifying the GSC if any problemsarise; distinguishing the mitigated companyfrom the affiliates within marketingmaterials; and reserving ultimate decisionmaking authority to the mitigated company.
Business Analysis and Mitigation Strategy Division, DSS 13with respect to mitigating undue FOCI.Some questions you should ask include: How does my company receive legalcounsel, and is counsel required toexecute any non-disclosure agreements? Does my company have its own generalcounsel? Can my company afford to hire outsidecounsel if necessary? Do the affiliates have legal regulatoryobligations that depend uponcompliance by my company?LegalIf your company uses an affiliate’s generalcounsel when appearing before a governmentagency, obtaining guidance on how tocomply with legal requirements, or havingan affiliate review regulatory submissionsfor compliance and quality control purposes,then you are sharing legal services.Even if your company is not looking to“share” a lawyer as such, asking for evennon-binding legal advice constitutes anaffiliated operation that must be mitigated.Given the weight legal counsel can carry at alllevels of a company, DSS will scrutinize sharedlegal services carefully to ensure that theaffiliates’ counsel do not act as unregulatedagents of the mitigated company.DSS will also be sensitive to potentialconflicts of interest that may arise, especially Is the affiliates’ counsel empoweredto represent my company in litigation,contract negotiations, or othertransactions with third parties? How will the affiliates’ legal counselconduct conflict screenings, and whatwill (s)he do if a conflict is identified oreven suspected? Who is compensating the attorney, andfor which services?The potential risks of using affiliatedlegal operations include inadvertentleakage of sensitive information to affiliatepersonnel; undermining the mitigatedcompany’s managerial independence;relying on an affiliate for a business-criticalfunction; and conflicts of interest.Potential mitigation strategies caninclude requiring the GSC to approve alllegal consultations in advance; hiring ageneral counsel at the mitigated company;
14 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY reserving the right to seek outside counselat the GSC’s discretion; barring the affiliatesfrom representing the mitigated companyin any negotiation or before any tribunal;and empowering the mitigated company toaccept or reject any advice offered.Should you request to share personnel,DSS will analyze the role intended for theshared individual(s) to determine howmuch influence (s)he is likely to have onthe mitigated company’s management andoperations.Shared PersonnelDSS will also work with the company todevise appropriate collocation mitigationmeasures via a FLP. This analysis will be thesame whether an affiliate shares personnelwith a mitigated company, or vice versa.Some questions you should ask include:While sharing personnel presents uniqueopportunities, it also presents unique risksthat must be considered carefully.Shared personnel include (i) affiliateemployees assigned to work with thecompany or (ii) company employeesassigned to work with any affiliate.Shared personnel are not permitted absentDSS approval. Sharing personnel can createconflicts of interest and greatly affect thework of a mitigated company, dependingon the employees’ position.For example, sharing project engineers canheighten the risk of leakage, while sharingaccountants or attorneys can have anundue impact on the mitigated company’smanagement. The mitigated company mayhave to implement a facility location plan(FLP), subject to review and approval byDSS, to accommodate a shared employee.Additional visit control measures might benecessary.Sharing personnel, in other words,can require a considerable amount ofwork by both the affiliates and themitigated company to accommodate thearrangement. Are any individuals employed by bothmy company and its affiliate(s), and ifso, what sort of work do they do? If my company hosts affiliate employees,how often do they interact with theaffiliates, and what is the nature ofthose interactions? If my company hosts affiliate employees,how are their communications with theaffiliate monitored? If my company hosts affiliate employees,are they authorized to supervise orotherwise direct any of the mitigatedcompany’s employees? Do the affiliates host any of mycompany’s workers as long-term visitors,and if so, what is the nature of thosevisits? If the affiliates host any of mycompany’s employees, what steps aretaken to ensure they are not undulyinfluenced by the affiliates?
Business Analysis and Mitigation Strategy Division, DSS The potential risks of sharing personnelinclude inadvertent disclosure of sensitiveinformation to affiliate personnel;undermining the mitigated company’smanagerial independence; undue influenceon employees performing on classifiedcontracts; and conflicts of interest.While an FLP may go some way towardmitigating some of these risks, otherpotential mitigation measures includeavoiding the identification of classifiedprograms and cleared personnel; ensuringthat the mitigated company retains allpersonnel-related decisions for its ownemployees (e.g. hiring, firing, etc.); havingthe shared employee become an employeeof the mitigated company; requiring allhosted affiliate personnel to take trainingon the FOCI mitigation agreement andall related, ancillary plans; and creatingan oversight structure to report noncompliance by shared personnel, as well asinappropriate attempts to influence clearedindividuals.15
16 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY AOP SUBMISSIONDSS provides a formatted template of AOPsfor FOCI companies’ use in preparing drafts.The template standardizes submissionsfrom all FOCI companies.and submit a draft AOP for DSSreview and approval.It defines broad categories of sharedservices to include affiliated services(traditional and reverse), shared third partyservices, shared persons, and cooperativecommercial arrangements.The AOP ensures that all FOCI risks havebeen addressed and provides guidance forreview of risk mitigation strategies. Foreach service or operation shared betweenthe mitigated company and foreignaffiliates, the mitigated company is expectedto provide a description of the service,the risks inherent in sharing the service,corresponding risk mitigation measures,and review of the service internally by thecompany and externally by DSS.This can be done by working with relevantemployees and executives to identify anddevelop risk mitigation measures. Lastly,the AOP must be approved by DSS beforethe mitigated company can start leveragingany affiliated operations.This section will introduce theDSS template AOP and provideguidance on how to prepare STEP 1: Download the AOP template,which can be found on the DSS plan.html STEP 2: On the template title page(page 1), replace “Defense SecurityService FOCI Operations Division”with your company’s name. Theword “Template” under “DSS AffiliateOperations Plan” should also beremoved. “February 2013” should bereplaced with AOP submission date.
17 Business Analysis and Mitigation Strategy Division, DSS STEP 3: On page 2, add the full date ofsubmission, Company name, address,CAGE code, and the names of allaffiliates with which you will shareservices. STEP 4: On the table of contents (page3), replace the “X’s” with actual pagenumbers once the draft AOP is finalized.The instructions located at the bottomof page 3 can remain or be removed. STEP 5: On the “WHEREAS” clausepage (page 4), fill in “[COMPANY]”and “[PARENTS/AFFILIATES]” in thetitle and first paragraphs with yourcorresponding Company name andParent/Affiliate names. The secondWHEREAS clause should reflect thedate of your Company’s executed FOCImitigation agreement. The remainder ofthe “WHEREAS” clauses should not
2 NAVIGATING THE AFFILIATED OPERATIONS PLAN: A GUIDE FOR INDUSTRY CONTENTS 3 AOP LIFE CYCLE DIAGRAM 4 INTRODUCTION 5 IDENTIFYING AFFILIATED OPERATIONS Types of Affiliated Operations 5 Categories of Affiliated Operations 7 Human Resources 8 Finance and Accounting 9 Internal Audits 10 Business
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