All of the following are requirements of the Sarbanes-Oxley Act (SOX) except:

a. evaluation and reporting on the effectiveness of internal control over financial reporting by management for all public companies.

b. evaluation and reporting on the effectiveness of internal control over financial reporting by external auditors only for large public companies.

c. establishment of an audit committee of independent directors to ensure the company's accounting, internal control, and audit functions are effective.

d. adoption of a code of ethics covering all employees.