Entity Level Control - Code of Conduct

Posted by Teresa Bockwoldt on January 24, 2010

One of the controls prescribed by The Committee of Sponsoring Organizations of the Treadway Commission (COSO), who provides the guidance for the Entity Level Process, relates to the use of a robust code of conduct. 

The code of conduct should be presented to all existing employees and then given to any new employees as they are hired.  The code of conduct can be used to mitigate risk to your company by requiring existing and new employees to attest to reading, understanding, and following the code.  If there is a need to terminate someone for violation of the code, the attestation sheet may need to be used as evidence that the former employee knowingly violated company procedures and that the termination was valid.  Or, by reading the code, employees may be more likely to adhere to company policy thereby mitigating issues that could have arisen if the code was not in place.

Now, most people do not have time to create a code of conduct or a corresponding attestation.  We at Vibato have over 500+ documents such as this in our library and we are happy to share them with you.  Feel free to send me an email or register via the registration box in the upper right hand corner if you would like a copy of our code of conduct.  I can be reached at tbockwoldt@vibato.com

Tags: Compliance tools, Sarbanes-Oxley Training, compliance, Sarbanes-Oxley