TABLE OF CONTENTS | Q. | As the CEO, CFO, or COO, what steps should I take to get the process of implementing SOX compliance underway? |
| A. | Here is a typical and reasonable approach to getting started. |
Call a Board meeting and
Decide whether to create an Audit Committee or have the Board take the responsibility. Decide on the committee members or Board members who will perform the tasks. Appoint an Internal Auditor.
Confirm that the company, its officers, directors, and management will behave in an ethical, trustworthy, and legal manner in the performance of their duties. This may seem obvious but few companies actually have it on record (minutes) that this is their intention.
Have at least the CFO and other financial officers read and signed the Code of Ethics. (Appendix D)
Appoint a Compliance Director (CD) who will oversee the compliance process and implement the Internal Control System. (Could be the Internal Auditor)
Discuss the scope and provide guidelines and then authorize a preliminary budget of compliance and Internal Control objectives.
Instruct the CD to prepare a plan with measurable objectives and budget requirements within a reasonable period, which will then be presented to the Board for approval and final budget approval.
Initiate a Policies and Procedures Manual (or revive an existing one) and place someone in charge of bringing it in line with SOX compliance requirements. They will work hand in hand with the CD.
Brief the entire company regarding SOX and its implications...
