Organizations and professional associations often establish a code of ethics or standards of conduct for their managers and employees. All firms subject to the Sarbanes-Oxley Act of 2002 must disclose whether they have established a code of ethics for senior financial officers and, if not, must explain why. Although a code of ethics is not man dated by law, it certainly is encouraged strongly. A survey taken by Deloitte & Touch LLP and Corporate Board Member magazine in 2003 revealed that 83 percent of the corporations surveyed had established formal codes of ethics, 98 percent agreed that an ethics and compliance program is an essential part of corporate governance, and 75 per cent of those with codes of ethics were actively monitoring compliance. In a 2008 survey, U.S. audit, tax, and advisory services firm KPMG found that 86 percent of the Fortune Global 200 had formal business codes of conduct. By region surveyed, 100 per cent of North American firms, 80 percent of European firms, and 52 percent of Asian firms had codes of ethics.