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 ____________ _________