Our Integrity and Ethical Values Audit Work Program provides a framework for conducting audits focused on integrity and ethical values within an organization. It outlines various stages of the audit process, including planning, fieldwork and reporting. The planning stage emphasizes the importance of understanding the scope, approach and timing of the audit, as well as the necessity of collaborating with auditees. It also includes reviewing best practices for ethics compliance and incorporating relevant federal guidelines. The audit steps detail procedures for obtaining necessary documents such as the code of business conduct, organizational charts, and policies related to ethics and compliance.

During the fieldwork phase, the document guides auditors through conducting entrance meetings, documenting findings, and assessing compliance with ethical standards. It instructs on selecting employees for review, tracking ethics incidents, and evaluating the effectiveness of the ethics program. The final steps involve drafting and issuing audit reports, ensuring these reports are reviewed by the auditee and agreed upon for action items. Overall, this work program serves as a tool to ensure that the ethics programs of organizations are not only in place but are also effective and actively enforced, thereby supporting the maintenance of high ethical standards across all operational levels.

Audit steps include:

• Work with the auditee(s) as to the scope, approach and timing of the audit and detailed document request.
• Observe and document (via flow charts) the ethics and code of conduct program.
• Determine the procedure for tracking reported ethics incidents and reporting trends to senior management and the audit committee.
• Evaluate insider trading compliance, reporting and associated blackout periods.