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Managing risk
“accepted or applicable industry
practice,” as outlined in the FSG.
• Coordinate with internal analysts—It
is helpful to coordinate ethics and
compliance risk assessments with
internal audits. Completing an ethics
and compliance risk assessment
aligns company focus and resources to
address areas of greatest significance to
the organization and allows the auditor
to design a program that tests the most
important internal controls.
At the end of the risk assessment
process, an organization should be
armed with extensive documentation
of identified and prioritized risk areas.
Failing to act upon this information could
subject an organization to exposure in
the event the information is disclosed
during litigation or in connection with a
government investigation. Therefore, with
this information in mind, the organization
should revise its compliance program,
review its code of conduct, modify its
training plan, shape its compliance
communication program and appropriately
staff its ethics and compliance department. ●
96 NYSE IPO Guide