Yes

c

No

c

Corporate Responsibility and Governance

Do key members of the executive team, including the CEO and CFO, personally review all financial reporting to ensure the financials are accurate, complete, and disclose all material off balance-sheet transactions?

c

c

Does your CEO personally read and sign all federal income tax returns?  (This is not required, but strongly suggested by the SEC.)

c

c

Do you know what types of executive loans have been prohibited since August 2002?

c

c

Do you understand the new restrictions on insider trading during blackout periods?

c

c

Is your board truly independent?

c

c

Do you have a financial expert on your board?

c

c

Has your company adopted a formal code of ethics for senior officers?

c

c

Does your company have a disclosure committee?

c

c

Does your company have a whistleblower policy?

Yes

c

No

c

Documentation of Internal Policies, Procedures, and Controls

Does your company have a written inventory of all significant systems?  If yes, are there appropriate controls in place to regulate and monitor use of the systems?

c

c

Does your company have a set process to assess, review, test, and document the internal policies, procedures, and controls?  Quarterly?  Annually?  If yes, has this process been reviewed by your disclosure committee? CEO & CFO?  Board?  Auditors?  

c

c

Do you know what types of internal controls need to be assessed and documented under the Sarbanes-Oxley Act?  If yes, have you included all the operational controls that impact financial results and disclosure statements?

c

c

Does your company have a process to measure the effectiveness of internal controls?  If yes, does your company have regular reviews with the disclosure committee and/or executive team to discuss control related metrics?

c

c

Has your management team, including the CEO and CFO, formally assessed the effectiveness of your internal policies, procedures and controls?  If yes, has the methodology and procedures you used to complete the assessment been reviewed and approved by public accountants?

c

c

Do you have a support document and/or written description for every significant policy, procedure, and control that has an impact on your financial reporting?   If yes, has the senior management team and/or disclosure committee reviewed the documentation?

c

c

Has your company documented and tested all internal policies, procedures and controls related to financial statements as required by Section 404 of the Sarbanes-Oxley Act?  If yes, have your external auditors reviewed the process followed and associated documentation?   If no, do you have this review scheduled? 

c

c

Has your company changed or modified any internal controls or procedures during the last 3 months?  If yes, has all appropriate documentation been updated to reflect the changes? 

Yes

c

No

c

Accounting and Audit Requirements

Is your audit committee truly independent and composed of members who are NOT employees and do NOT receive any compensation beyond board fees?

c

c

Does your audit committee include at least one financial expert?  (e.g. A CPA or former CFO, with equivalent corporate financial experience with knowledge of auditing, accounting and financial principals, procedures, controls and functions)

c

c

Has your audit committee established procedures for handling complaints, including anonymous, confidential complaints from employees, regarding auditing and accounting matters ?

c

c

Is your audit firm truly independent?  Do they report directly to the head of the audit committee?

c

c

Has your audit firm been hired to do any non-audit work since August 2002?  If yes, has this work been approved by the audit committee?

Yes

c

No

c

Enhanced Disclosure and Reporting Requirements

Does your company disclose insider stock transactions within 2 business days?

c

c

Does your company have a procedure for reporting and reconciling all Non-GAAP financial information, like EBITDA pro-forma information?

c

c

Do you understand the changes in reporting requirements for off-balance sheet transactions and events?  If yes, has your company updated its procedures to address the changes?

c

c

Does your company communicate the financial state of the company in plain English?

c

c

Is your company prepared to file form 8-K with all earnings press releases?

c

c

Did you know that any significant changes in your business that will have a material impact on the business need to be reported in real time?

c

c

Did you know that the CEO and CFO could loose their prior year’s bonus compensation if the company restates its financials due to the wrong doing of any employee?