Sarbanes Oxley for Private Companies - Best Practices
Private companies looking to adopt Sarbanes Oxley requirements as part of a “best practices” initiative should consider implementing the following:
| Recruit independent directors for the board of directors and board committees. | |
| Establish audit, nominating and compensation committees and draft related charters. | |
| Adopt a code of ethics. | |
| Evaluate and document internal controls and procedures and consider improving if deemed necessary. | |
| Review services provided by outside auditors and adopt policies regarding approval of non-audit services. | |
| Engage auditors to perform “pre-review” of internal controls if a public offering is expected. | |
| Add MD&A to financial reports. | |
| Add corporate governance information to company website. | |
| Require executive officers to certify financial reports. |

