Establishing an Effective Complaint and Confidential, Anonymous Reporting Process

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The Bulletin: Volume 1, Issue 11

Earlier this year, the Securities and Exchange Commission (SEC) issued rules, pursuant to Section 301 of Title III of the Sarbanes-Oxley Act of 2002 (SOX), requiring audit committees to establish procedures for "the receipt, retention and treatment of complaints received by the issuer regarding accounting, internal accounting controls or auditing matters, and the confidential, anonymous submission by employees of the issuer of concerns regarding questionable accounting or auditing matters."

Most public companies must be in compliance with this requirement by 2004; foreign private issuers and small-business issuers must be in compliance by 2005. In this issue, we address the issues that audit committees and management should consider as they collaborate to comply with this requirement.

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