How strong is the ethical tone at the top and in the middle?
• Are duties and responsibilities adequately segregated?
• Are remuneration systems promoting the right behaviors?
• Is the segregation of key dutiesand responsibilities still adequate following any cost-cutting initiatives?
• Do we have an adequate whistleblower hotline and would employees speak up if they had concerns?
• How well resourced is internal audit, compliance, and other third lines of defense?
• Does internal audit have the necessary fraud detection experience?
• Do our international operations have adequately staffed and competent finance departments?