What is Whistleblower protection policy? The first obligation from SOX that applies to all organizations is the requirement for a documented “whistleblower protection” policy. SOX requires all organizations, including nonprofits, to establish a means to collect, retain, and resolve claims regarding accounting, internal accounting controls, and auditing matters. The system must allow such concerns to be submitted anonymously. SOX provides significant protections to whistleblowers, and severe penalties to those who retaliate against them. The following comes directly from SOX, Section 806:
“…any officer, employee, contractor, subcontractor, or agent of such company, may not discharge, demote, suspend, threaten, harass, or in any other manner discriminate against an employee in the terms and conditions of employment because of any lawful act done by the employee (1) to provide information, cause information to be provided, or otherwise assist in an investigation regarding any conduct that the employee reasonably believes constitutes a violation of section 1341, 1343, 1344, or 1348, any rule or regulation of the Securities and Exchange Commission, or any provision of Federal law relating to fraud against shareholders, when the information or assistance is provided to or the investigation is conducted by
(A) a Federal regulatory or law enforcement agency; (more…)
Popularity: 9% [?]
One of the common problems that auditor face is preparing for report against very limited time deadline. So what you should prepare to make your SOX reporting accurate, timely and secure during very tight time and schedule? Some of the classic solutions are by making priority for report that should be finished first.
Based on my experience, to be able to present an effective report should be depend on
1. Consistent with scope of the project,
Consistency is key factor for managing the deadline. SOX scope which usually pervasive to very part of corporation usually become major distracter for managing report timely. The auditors tend to recheck every part of system one by one and very detail. Most of auditor thinks that they could finish the job on time, and of course most of them were failed.
2. Understand the key person in the project
Sign off, interview and others personal relationship at SOX design usually become a problem when come with the deadline. The key person for entire department should be become the number one priority. Auditor should be work effectively with every stakeholder in the company. (more…)
Popularity: 5% [?]
Purpose
Guidance on the preparation of management’s reports on the effectiveness of internal control
over financial reporting is provided by the following.
- Item 308(a) of Regulation S-B and S-K, 17 C.F.R 228.308(a) and 17 C.F.R. 229.308(a)
- Questions 1, 2, 3, and 19 of Internal Control over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports: Frequently Asked Questions, published by the staff of the SEC Office of the Chief Accountant and the Division of Corporation Finance
The following are examples of such reports.
Example 1: Management Report when internal control over financial reporting is effective
The management of [company name] is responsible for establishing and maintaining adequate
internal control over financial reporting. This internal control system was designed to provide reasonable assurance to the company’s management and board of directors regarding the preparation and fair presentation of published financial statements. All internal control systems, no matter how well designed, have inherent limitations. Therefore, even those systems determined to be effective can provide only reasonable assurance with respect to financial statement preparation and presentation. (more…)
Popularity: 61% [?]
Imagine you’re board of director of very large company, and you want to know the latest status of your product distribution. Currently your product is distributed in 45 country with more than 1 million product released every month. Will you believe the report generated by your reporting division? Have you ever been thinking that the report will not be accurate? That’s ok, you’re not alone.
Reporting accuracy is the biggest issue every large company has. Imagine a company who has different application processing with different module and different reporting application. For example a car manufacturing company in Thailand would use SAP FICO module for its GL application, would use Oracle HR for payroll and for final consolidation would use Hyperion Reporting. Do you believe that the Board of Director will have the accurate report generate by machine? Of course not, there is some part that will be edited by Microsoft Excel, some correction by financial controller and so on.
In the current situation, the company also would like to apply another approach using data warehouse management for reporting accuracy. So it’s a lot of homework for very complex IT environment company. (more…)
Popularity: 9% [?]