Financial Reporting (External) Audit Work Program Audit Objectives The purpose of this work program is to evaluate the operating effectiveness of internal controls identified in the External Financial Reporting process and related sub-processes. Listed below are sample risks and controls identified for Company ABC to test for the External Financial Reporting process and related subprocesses. This work program may not be applicable to all businesses without modification. I. Sub-Process - Earnings Release A. /Risks 1. Risk – Consolidated financial statements and schedules included in the earnings release may be misstated due to inaccurate input by Corporate Accounting. 2. Risk – Earnings release text, the consolidated financial statements and schedules may not be in compliance with SEC regulations. 3. Risk – Consolidated earnings release text may be inaccurate. B. Controls 1. Pervasive - Individuals responsible for preparing the earnings release schedules and text have the appropriate skills and knowledge in order to perform their duties correctly. 2. Specific - Earnings release schedules are reviewed by the VP-Finance and VP-Accounting. 3. Specific - Earnings release schedules are prepared in a standard format each quarter in an excel spreadsheet. 4. Specific - Earnings release schedules and text are tested for clerical accuracy by the Director of Corporate Accounting and the Manager of Financial Reporting. 5. Specific - Manager of Financial Reporting and Director of Accounting agree numbers in the earnings release schedules to the amounts in the external reporting schedules. II. Sub-Process - Form 10-Q A. Risks 1. Risk – Consolidated financial statements may be misstated due to inaccurate/incomplete information provided to personnel responsible for financial reporting from business units or other corporate departments. 2. Risk – Consolidated financial statements may be misstated due to inaccurate/incomplete input of information into Form 10Q MD&A. 3. Risk – Consolidated financial statements may be misstated due to inaccurate/incomplete input of information into Form 10Q financial statements and footnotes. 4. Risk – Consolidated financial statements may be misstated due to the financial statements footnotes not being in compliance with GAAP. 5. Risk – Form 10Q may not be in compliance with SEC regulations for form and content. B. Controls 1. Pervasive - Individuals responsible for the preparation of Form 10Q have the appropriate skills and knowledge in order to perform their duties correctly. 2. Specific - Information input into Form 10Q is compared to previously filed Form 10Q's. 3. Specific - Manager of Financial Reporting agrees amounts in Form 10Q to the earnings release schedules, consolidating schedules, and other supporting documentation. 4. Specific - Manager of Financial Reporting completes a disclosure checklist from an external accounting research provider, which is reviewed by Director of Financial Reporting. 5. Specific – Director/Manager of Financial Reporting creates a disclosure items spreadsheet, based on review of Board of Director Minutes, completion of financial reporting checklist, company press releases, and discussions with legal, finance and accounting management. 6. Specific - Information input into the Form 10Q is checked for clerical accuracy and internal consistency by the Manager of Financial Reporting and the Director of Corporate Accounting. 7. Specific - Form 10Q is reviewed by Director of Corporate Accounting and VP-Accounting. 8. Specific - Form 10Q is reviewed by the Management Committee, Audit Committee Chairman, Executive Officers of the Company, and Business Unit senior management. 9. Specific - Schedules used to complete MD&A disclosures are provided in a standard format. 10. Specific - Schedules used to complete footnote disclosures are saved on the network and used each quarter for applicable footnote disclosure and are in a standard format. III. Sub-Process - Form 10-K A. Risks 1. Risk – Consolidated financial statements may be misstated due to inaccurate/incomplete information provided to personnel responsible for financial reporting from business units or other corporate departments. 2. Risk – Consolidated financial statements may be misstated due to inaccurate/incomplete input of information into Form 10K MD&A. 3. Risk – Consolidated financial statements may be misstated due to inaccurate/incomplete input of information into Form 10K financial statements and footnotes. 4. Risk – Consolidated financial statements may be misstated due to the footnotes to the financial statements not being in compliance with GAAP. 5. Risk – Form 10K may not be in compliance with SEC regulations for form and content. B. Controls 1. Pervasive - Individuals responsible for the preparation of Form 10K have the appropriate skills and knowledge in order to perform their duties correctly. 2. Specific - Information input into Form 10K is compared to previously filed Form 10K's. 3. Specific - Manager of Financial Reporting agrees amounts in Form 10K to the earnings release schedules, consolidating schedules, and other supporting documentation. 4. Specific - Manager of Financial Reporting completes a disclosure checklist from an external accounting research provider, which is reviewed by the Director of Financial Reporting. 5. Specific – Director/Manager of Financial Reporting creates a disclosure items spreadsheet based on review of Board of Directors minutes, completion of financial reporting checklist, company press releases, and discussions with legal, finance, and accounting management. 6. Specific - Information input into the Form 10K is checked for clerical accuracy and internal consistency by the Manager of Financial Reporting and Director of Corporate Accounting. 7. Specific - Form 10K is reviewed by Director of Corporate Accounting and VP-Accounting. 8. Specific - Form 10K is reviewed by the Management Committee, Audit Committee Chairman, Executive Officers of the Company, and Business Unit senior management. 9. Specific - Schedules used to complete MD&A disclosures are provided in a standard format. 10. Specific - Schedules used to complete footnote disclosures are saved on the network and used each quarter for applicable footnote disclosure and are in a standard format. IV. Sub-Process - Debt Compliance A. Risks 1. Assertion – Accuracy Risk – Footnotes to consolidated financial statements may be misstated due to inaccurate calculations of financial ratio covenants. 2. Assertion – Existence/Completeness Risk – Company may not be in compliance with debt covenants due to reporting requirements that are not provided to the bank on time. B. Controls 1. Pervasive - Individuals responsible for the debt compliance process have the appropriate skills and knowledge in order to perform their duties correctly. 2. Specific - The spreadsheets used to calculate debt covenants are completed in a standard format. 3. Specific - The supporting schedules used to complete debt covenant calculations are provided in a standard format. 4. Specific – The Manager of Financial Reporting agrees amounts input into debt covenant calculations to supporting financial statements and other supporting financial information. 5. Specific - Debt covenant calculations are reviewed by the Director of Financial Reporting and VPFinance. Project Work Step I. Project Administration – Open 1. Obtain and review the risk and control documentation created during the Sarbanes–Oxley Section 404 project to gain an understanding of the processes. 2. Obtain and review prior internal audit reports, external auditor management letters, and any design issues identified during the Sarbanes–Oxley Section 404 project. 3. Request documents needed for fieldwork. Obtain Copy of Form 10Q, 10K or earnings release from CompanyABC.com, investor relations. Other support needed for fieldwork should be made readily available during fieldwork. II. Earnings Release (See Section I. Sub-Process – Earnings Release above) 1. Document qualifications of VP-Accounting, VP- Finance, Director of Corporate Accounting, and Director and Manager of Financial Reporting. 2. Obtain earnings release work papers from Manager of Financial Reporting: a. Review tie-out for completeness. b. Agree balance sheet, income statement and supplemental schedules included in earnings release to supporting external reporting schedules. c. Ensure earnings release schedules are completed in a standard format each quarter. 3. Obtain earnings release checklist/timeline from Manager of Financial Reporting and ensure earnings release has been distributed and reviewed by applicable accounting and finance management personnel. III. Form 10-Q (See Section II. Sub-Process – Form 10-Q above) 1. Obtain 10Q work papers for one quarter during the test period. a. Review tie-out of 10Q to ensure completeness. b. Agree financial statements to earnings release. c. Agree cash flow statement to supporting work papers. d. Ensure MD&A was tied-out completely. e. Judgmentally select X footnotes and re-compute/re-perform tie-out and ensure supporting schedules are completed in a standard format. See below for additional specific steps on stock options footnote. f. Ensure Director/Manager of Financial Reporting checklist has been completed and signed-off. g. Ensure external quarterly disclosure checklist has been completed. h. Ensure internal quarterly disclosure consideration checklist has been completed. i. Ensure accounting issues list has been updated for the quarter. j. Review summary of minutes completed by Manager of Financial Reporting and ensure issues identified in memo have been considered and resolved. 2. Obtain binder of CEO and CFO “302” certifications. Ensure signatures have been obtained and ensure sub-certifications have been received from senior management. 3. Obtain support for Stock Options Footnote and complete the following: a. Agree numbers in footnote to supporting schedule. b. Review supporting work papers to ensure lead schedule agrees to administrator reports. c. Ensure work papers include tests to ensure accuracy of administrator reports. IV. Form 10-K (See Section III. Sub-Process – Form 10-K above) 1. Review tie-out of 10K to ensure completeness. a. Agree financial statements to earnings release. b. Agree cash flow statement to supporting work papers. c. Re-compute/re-perform tie-out of MD&A. d. Review support for contractual obligation disclosures made in MD&A and agree amounts in disclosure to supporting documentation. e. Judgmentally select footnotes and re-compute/re-perform tie-out and ensure supporting schedules are completed in a standard format. See below for additional specific steps on stock option and tax footnote. f. Ensure Director/Manager of Financial Reporting checklist has been completed and signed-off. g. Ensure external annual disclosure checklist has been completed. h. Ensure internal annual disclosure consideration checklist has been completed. i. Ensure accounting issues list has been updated for the quarter. 2. Review summary of minutes completed by Manager of Financial Reporting and ensure issues identified in memo have been considered and resolved. 3. Obtain binder of CEO and CFO “302” certifications. Ensure signatures have been obtained and ensure sub-certifications have been received from senior management. 4. Obtain support for Stock Options Footnote and complete the following: a. Agree numbers in footnote to supporting schedule. i. Review supporting work papers to ensure lead schedule agrees to administrator reports. ii. Ensure work papers include tests to ensure accuracy of administrator reports. 5. Obtain support for Tax Footnote and complete the following: a. Agree numbers in footnote to supporting schedule and check for internal consistency with the financial statements. b. Ensure deferred tax assets and liabilities are properly presented in footnote per company accounting policies. 6. Review disclosure checklist section that relates to income tax disclosures and ensure all necessary disclosures have been made. V. Debt Compliance (See Section IV. Sub-Process IV – Debt Compliance above) 1. For one quarter: a. Review tie-out of debt compliance calculation to supporting work papers. b. Ensure debt compliance checklist has been completed and signed-off. c. Agree a sample of amounts in the calculation to financial statements and supporting work papers and ensure completed in a standard format. VI. Project Administration – Closing 1. Review the audit program to ensure that all program steps have been completed, documented and signed-off. 2. Identify exceptions and document compensating controls. Discuss the compensating controls with the Section 404 Project Team and determine if controls should be tested. If controls are tested, document the testing performed and test results. 3. Document all findings and results of tests in audit software. 4. Document any issues and remediation plans in an issue resolution document and discuss with the appropriate individuals. 5. Communicate all issues to the Section 404 Project Team. 6. Determine overall operating effectiveness of controls.