Risk Assessment & Audit Services Risk Management Capability Characteristics Control Environment COSO EXHIBIT B Stage A Stage B Stage C Stage D Stage E Ethical Values (policies) A formal code of ethics policy does not exist. An informal ethics policy exists but communication of policies is weak and inconsistent throughout the organization. Polices do not adequately cover dealings both internally and with external parties. Employees do not routinely display ethical behavior. Employees are not consistently displaying ethical behavior when conducting Company activities with internal and/or external parties. Ethical Values – (reporting) There are no means by which employees can report concerns regarding ethical behavior Informal methods exist to report questions on ethical behavior however, methods are not well established, communicated or supported by the organization. A formal ethics policy exists, covers the majority of aspects related to ethical behavior involving internal employees and external parties. Policy communication is good and the majority of policy aspects are understood throughout the organization. The policy is regularly updated. The majority of employees regularly display ethical behavior in their dayto-day activities. Questions periodically surface regarding a specific aspect of expected behavior but these questions are appropriately and timely surfaced and addressed. Formal methods exist, are considered effective and well communicated throughout the organization. Methods are frequently reviewed and updated. Confidentiality of methods is considered good. A formal ethics policy exists, is considered best practice and continuously updated. Policy communication is excellent and fully understood throughout the organization. Policy is considered to cover all aspects of behavior internally as well as with external parties. Ethical ValuesEmployees Ethical Values Discipline There are no consequences within the organization for unethical behavior or non-compliance with policy. Discipline for violation of the code of ethics is informal and not consistently executed throughout the organization. A formal ethics policy exists and is considered to adequately cover most aspects of ethical behavior involving internal employees and with external parties. Communication is adequate however, not all aspects of the policy are well understood throughout the organization. The policy is only periodically updated. Most employees generally display ethical behavior in most aspects of day-to-day activities. Instances may occur where inconsistent communication of policy results in questionable behavior in regards to Corporate expectations. Formal methods exist, and are considered adequate, for employees to report questions on ethical values. Methods are communicated but not fully understood or utilized throughout the organization. Some questions may exist regarding confidentiality of reporting methods. Methods are only periodically updated. Some formal disciplinary measures exist for violations to the code of ethics however; methods may not be well communicated or understood throughout the organization. Also, methods may be inconsistently executed dependent on situation and parties involved. Formal disciplinary measures exist for violations to the code of ethics. Communication and understanding of methods is considered good throughout the organization. Methods are consistently executed without bias to situation or individuals involved. Formal and well-established measures exist for violations to the code of ethics. Communication and understanding of methods is excellent throughout the organization. Methods are not questioned and execution is fair and always consisted. All employees regularly display ethical behavior in every aspect of day-to-day activities. Any question regarding appropriate activity is pro-actively addressed and resolved prior to any action. Formal methods exist, are considered best practice. Methods are continually reviewed and updated. Confidentiality rates are high. 1 Risk Assessment & Audit Services Risk Management Capability Characteristics COSO EXHIBIT B Stage A Stage B Stage C Mgmt internal control philosophy and actions Management’s understanding of internal control requirements is minimal and as such, controls throughout the organization are inadequate. Management has a basic understanding of internal controls requirements for various processes however operational needs and targets often overshadow those requirements. Internal controls throughout the organization are not considered effective. Deficiencies are not timely identified or corrected. Management has an overall understanding and acceptance of internal control requirements for the organization. Internal controls are considered effective for the majority of processes. Correction of issues is considered effective but may vary dependent on the criticality of the process. Management fully understands and is committed to establishing effective internal controls for all processes. Internal controls are considered highly effective for all processes. Timely identification and correction of any internal control deficiencies within the organization always occurs. Overall Control Environment Evaluation The overall control environment of the Company is considered ineffective and ad hoc. The overall control environment of the Company is managed on a fairly informal basis and is not considered effective. Management has a good understanding of internal control requirements for critical processes and is fairly committed to those controls. Internal controls for those processes are considered adequate. Internal control for less critical processes is not considered a priority and may be overlooked. Identification and correction of issues is considered adequate but may not always be executed timely. Identification of internal control deficiencies for less critical processes is not considered a priority and may be overlooked. The overall control environment of the Company is considered adequate. Certain aspects of the environment may need attention and should be addressed to ensure they can be relied upon. The overall control environment of the Company is considered effective. The majority of the environment is well controlled and can be relied upon. The overall control environment of the Company is considered optimal. All aspects of the control environment are controlled at a very effective level and there is no question regarding reliability. Method to identify business risks Identification of business risks (e.g. entering new markets, offering new products/services, privacy and data protection requirements, changes in the regulatory environment) is ad hoc and up to the individual efforts of employees/management. The overall risk assessment process of the Company is considered ineffective and ad hoc Methods to identify business risk are informal and not consistently executed or understood across the organization. Methods to identify business risks are formal and considered adequate for the Company. Methods may not be consistently executed and reviewed to ensure they stay in line with the organization size and needs. The overall risk assessment process of the Company is conducted on a fairly informal basis and overall, is not considered effective. The overall risk assessment process of the Company is considered adequate. Certain aspects of the process may need attention and should be addressed to ensure it can be relied upon. Methods to identify business risks are formal and considered effective for the Company. Methods are executed fairly consistently and periodically reviewed for effectiveness and their alignment with the organization’s size and needs. The overall risk assessment process of the Company is considered effective. The majority of aspects of the process is well defined and can be relied upon. Methods to identify business risks are considered best of class and highly effective for the Company. Methods are executed consistently and continually reviewed for effectiveness to ensure their alignment with the organization’s size and needs. The overall risk assessment process of the Company is considered optimal. All aspects of the process very effective and there is no question regarding reliability. Overall Risk Assessment Stage D Stage E 2 Risk Assessment & Audit Services Risk Management Capability Characteristics COSO EXHIBIT B Control Activities Information and Communication Stage A Stage B Information and Communication –Systems Reliability Systems do not provide for accurate and timely reporting of financial data. Systems produce financial data, however significant manual effort is incurred to ensure information is accurate. Timeliness of obtaining reporting information is an issue. Overall Management communication processes Methods used by management to communicate important aspects of Company business to the employee population are ad hoc and not considered open, timely and effective. Overall Control Activities The overall control activity process of the Company is considered ineffective and ad hoc Methods used by management to communicate important aspects of Company business are varied and dependent on the nature of the issue. Communication is often unclear and inconsistent throughout the company. Management makes little effort to clarify the communication. The overall control activity process of the Company is conducted on a fairly informal basis and overall, is not considered effective. Correcting Deficiencies Actions by management to correct deficiencies reported by internal audit or the external auditors are considered ad hoc and do not occur on a timely basis. Actions by management to correct deficiencies reported by internal audit or the external auditors are sporadic and inconsistently executed. Actions do not regularly results in effective resolution of issues. Overall Monitoring The overall monitoring process of the Company is considered ineffective and ad hoc The overall monitoring process of the Company is conducted on a fairly informal basis and overall, is not considered effective. Stage C Stage D Stage E Systems are considered adequate for timely and accurate reporting of financial data. Some manual effort must occur to validate information and ensure its accuracy due to either interface issues or data reporting issues. Methods used by management to communicate important aspects of Company business are considered adequate. Periodically, inconsistencies may occur in the communication and management does not always timely address these inconsistencies. Systems are considered effective for timely and accurate reporting of financial data. Manual effort is minimal to validate information and ensure its accuracy. Systems are considered optimal for timely and accurately reporting financial data. Methods used by management to communicate important aspects of the Company business are considered effective. Some instances occur of inconsistent communication however, these are timely addressed and clarified by management. Methods used by management to communicate important aspects of the Company business are considered optimal. Rare instances occur regarding inconsistent communication. The overall control activity process of the Company is considered adequate. Certain aspects of the process may need attention and should be addressed to ensure it can be relied upon. Actions by management to correct deficiencies reported by internal audit or the external auditors are considered adequate. Actions may not always be well coordinated or consistently executed on a timely basis. The overall control activity process of the Company is considered effective. The majority of aspects of the process is well defined and can be relied upon. The overall control activity process of the Company is considered optimal. All aspects of the process are very effective and there is no question regarding reliability. Actions by management to correct deficiencies reported by internal audit or the external auditors are considered optimal. Actions are extremely well coordinated and executed on a timely basis. The overall monitoring process of the Company is considered adequate. Certain aspects of the process may need attention and should be addressed to ensure it can be relied upon. The monitoring process of the Company is considered effective. The majority of aspects of the process is well defined and can be relied upon. Actions by management to correct deficiencies reported by internal audit or the external auditors are considered effective. Actions are fairly well coordinated and executed in an acceptable time period. The overall monitoring process of the Company is considered optimal. All aspects of the process very effective and there is no question regarding reliability. 3