This memo outlines a process for reviewing entity-level controls. Once the memorandum is updated, management should sign off on it to verify accuracy.
Questions addressed in the memo include: What procedures would you follow if you received an ethical complaint? Are department personnel able to produce quality work in a timely manner? Do rewards and incentives foster an appropriate ethical tone? Does management take appropriate disciplinary action in response to departures from approved policies and procedures or violations of the code of conduct? While carrying out regular activities, how do you assess whether the internal controls are functioning in accordance with Sarbanes-Oxley?