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U.S. Department of Commerce Federal Financial Assistance Listing 11.307 Economic Adjustment Assistance Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CFR 200.328 and 200.329 require that the auditee submit financial and performance reports for federal awards that provide accurate, current, and complete information regarding the use of federal funds. Condition: During our testing, we noted that the amounts reported on the SF-425 and SF-271 reports did not accurately reflect qualified expenditures for the year ended December 31, 2025. Cause: The entity did not have sufficient internal controls over grant reporting to ensure that reported amounts were accurate for the year ended December 31, 2025. This resulted in inaccuracies that were not identified prior to submission. Effect: The financial reports submitted to the federal agency were materially misstated and did not comply with Uniform Guidance reporting requirements. The lack of effective internal controls over grant reporting allowed these material misstatements to occur and not be detected prior to submission, which could adversely affect federal oversight, monitoring, and funding decisions. Questioned Costs: None reported Context/Sampling: A nonstatistical sample of one SF-425 report, three SF-271 reports, and two quarterly progress reports out of a population of twelve total reports was selected for testing. Errors were noted on the SF-425 report and one of the SF-271 reports. Repeat Finding from Prior Year(s): No Recommendation: We recommend that the entity strengthen internal controls over reporting to ensure that reported amounts accurately reflect qualified expenditures for the period and comply with federal program requirements. Views of Responsible Officials: Management agrees with the finding.

Finding Summary: Material noncompliance was noted in reporting as reported amounts did not agree to underlying supporting documentation. Responsible Individuals: Kim Clay, Corporate Controller and Paul DiTomasso, Site`2 Controller Corrective Action Plan: Management will review and improve internal controls over reporting to ensure that reported amounts agree to underlying supporting documentation. Anticipated Completion Date: June 30, 2026