The following are typical characteristics we may observe relating to integrity, ethical values and behavior of key executives:
• The entity has a code of conduct or equivalent policy that is communicated and monitored.
• The entity’s corporate culture emphasizes the importance of integrity and ethical behavior. Senior management holds itself to the highest standards and leads by example.
• The entity’s communications reinforce a consistent message regarding policies and culture.
• Management takes appropriate action in response to departures from approved policies and procedures or the code of conduct.
• There are appropriate policies for such matters as accepting new business, conflicts of interest, and security practices that are adequately communicated throughout the organization.
• Management maintains, monitors and appropriately responds to a fraud hotline.
• The entity has a whistleblower policy and related whistleblower or ethics hotline, which are appropriately communicated throughout the organization, and include procedures for handling complaints and for accepting confidential submissions of concerns about questionable accounting or auditing matters.
The following are typical characteristics we may observe relating to integrity, ethical values and behavior of key executives:• The entity has a code of conduct or equivalent policy that is communicated and monitored.• The entity’s corporate culture emphasizes the importance of integrity and ethical behavior. Senior management holds itself to the highest standards and leads by example. • The entity’s communications reinforce a consistent message regarding policies and culture.• Management takes appropriate action in response to departures from approved policies and procedures or the code of conduct.• There are appropriate policies for such matters as accepting new business, conflicts of interest, and security practices that are adequately communicated throughout the organization.• Management maintains, monitors and appropriately responds to a fraud hotline.• The entity has a whistleblower policy and related whistleblower or ethics hotline, which are appropriately communicated throughout the organization, and include procedures for handling complaints and for accepting confidential submissions of concerns about questionable accounting or auditing matters.
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