CASES Management Response Review the engagement observation that follows and Associates who have not acknowledged the record the spcifie information that represents the rec- March 24 will be sent a reminder noti ommendation and each of the following observation April 3 informing them of the requiremenn the wek Code as of CASE 1 edge the Code. A report of all associates who contimowl be delinquent in acknowledging the Code will be to the applicable HR liaison for review and folle week of April 17. The HR function will partne department provided attributes: criteria, condition, cause, and effect. Audit Observation and Recommendation: basiness heads of delinquent associates Corporation X associates are required to ahide by the obtain the necessary acknowledgments. A final rep o organization's formal Code of Business Conduct& Ethics will be generated the week of April 24 to determine th (the Code). To ensure all employees are aware of the Code remaining associates who have not acknowledged the and their obligations under it, Corporation X requires Code. A verbal warning will be issued to all who have not acknowledged the Code by April 24 anda written warning will be provided to associates who have not acknowledged the Code by April 30. receipt of the Code. A global email was sent to all associates on July 1 inform- ing them of their obligation to read and acknowledge the Code. Associates were instructed to complete and return acknowledgments by December 1.Our audit testing indi Accountability: Jane Doe cated the following relative to the acknowledgment pro-Responsibility: John Smith Implementation Date: March 24 As of March 1, fewer than 50 percent of associates had Does the observation, as presented, adequately address all of the suggested observation attributes? If not, explain why completed and returned acknowledgments Follow-up procedures have not been performed by human resources (HR) or department management to . There is not a formal policy indicating actions to be taken ifand when associates do not return acknowl- . No disciplinary actions have been taken regarding associates who have not completed acknowledgments of the Code to date Improving the acknowledgment process will help Cor- poration X demonstrate compliance with external reg- ulations requiring a Code of Ethics. It will also help to ensure all associates are aware of their responsibilities and obligations to the organization under the Code. We recommend management enhance the acknowledge- ment tracking process to ensure all associates acknowl- edge receipt of, compliance with, and understanding of the Code. Policy and procedures need to be developed and implemented to take appropriate action when associ- ates do not respond. Disciplinary action should be taken if associates refuse to complete and return acknowledg- ments, as required by policy