Ethics – [Year]
Audit Program
Completed
Reference by/date
Audit Planning and Risk Analysis
A. Prepare planning form ___________ ___________
B. Send the pre-audit notification ___________ ___________
C. Gather facts about the audit area
1. Contact General Manager for input
and/or concerns ___________ ___________
2. Contact Business Practice
representative for updates ____________ ___________
3. Gather background data on audit
area ____________ ___________
4. Contact Director for input and/or
concerns ____________ ___________
5. Interview key audit area
personnel and appropriate
executives for their input ____________ ___________
D. Prepare COSO Worksheet ____________ ___________
1. Discuss the COSO worksheet
with reviewers ____________ ___________
E. Send entrance memo ____________ ___________
F. Conduct entrance conference ____________ ___________
G. Develop detailed audit test steps, ____________ ___________
discuss with reviewers
Audit Field Work
H. Compliance with Federal Sentencing Guidelines
H.1 Determine that company has a
written code of business ethics
and conduct. ___________ ___________
H.2 Verify that specific individual(s)
(high-level personnel of company) has
been assigned overall responsibility to
oversee compliance. ____________ __________
H.3 Verify that company uses due diligence
in delegation of authority. ____________ __________
H.4 Determine that standards are
effectively communicated to all
employees. ____________ __________
H.5 Verify there is a reporting system
whereby employees can report criminal
conduct by others without fear of
retribution. ____________ __________
H.6 Verify there is appropriate
disciplinary mechanisms in place. ____________ __________
H.7 Verify that company is prepared to
take all reasonable steps to respond
appropriately to an offense and to
prevent further similar offenses. ____________ __________
H.8 Verify that company has a continuing
method of monitoring. Monitoring should
include assurance of adherence to the
code of conduct, compliance with
federal laws, consistent enforcement of
standards, and appropriate responses to
reported offenses. ____________ __________
H.9 Determine if periodic reporting on
adherence to codes and laws is made to
company’s Board of Directors or other
appropriate committee. ____________ __________
I. Deregulation Pilot
I.1 Verify the code of conduct covering
the operation of the state’s deregulation
pilot is effectively communicated to all
employees. ____________ __________
I.2 Verify an adequate training program
is in place. ____________ __________
I.3 Verify there is a reporting system
whereby employees can report
offenses. ____________ __________
I.4 Verify that company is prepared to
take all reasonable steps to respond
appropriately to an offense and to
prevent further similar offenses. ____________ __________
J. Maintain ethical work environment
J.1 Verify that company’s mission/vision
statement supports an ethical
work environment. ____________ __________
J.2 Verify there are policies/business
practices in place promoting an
ethical environment. ____________ __________
K. Maintain environment of corporate citizenship
K.1 Determine that guidelines are developed
to encourage corporate citizenship. ____________ __________
K.2 Verify company informs the public on
relevant issues by means of a speaker
service. ____________ __________
K.3 Verify company personnel participate
in community activities. ____________ __________
K.4 Determine that company provides
financial support to community
organizations. ____________ __________
L. Comply with laws and regulations pertaining to
industrial relations
L.1 Verify that policies/business
practices are in place to cover areas of
discrimination, theft, confidentiality,
conflicts of interest, substance
abuse, etc. ____________ __________
L.2 Verify that a Compliance Officer
has been assigned the responsibility
of overseeing compliance. ____________ __________
M. Provide general guidance to all employees in
areas of integrity and ethical values
M.1 Verify standards of business
conduct for company employees
is effectively communicated to all
employees. ____________ __________
M.2 Verify that company has implemented
employee training programs regarding
the standards. ____________ __________
M.3 Verify there are appropriate
disciplinary mechanisms in place. ____________ __________
M.4 Verify that company is prepared to
take all reasonable steps to respond
appropriately to an offense and to
prevent further similar offenses. ____________ __________
Develop Findings and Recommendations
N. Develop recommendations from findings ____________ _________
O. Prepare audit reports ____________ _________
P. Obtain team review ____________ _________
Q. Obtain General Manager/Director review ____________ _________
R. Conduct exit conference ____________ _________
1. Hand out Audit Effectiveness
Questionnaire ____________ _________
Post Audit Work
S. Ensure planning form is complete ____________ _________
T. Close audit in time reporting system ____________ _________
