Letter to Mrs Keefer DerMrs Keefer, Internal control issues within Global-bank I have been asked by the trustees of the Shalala Pension Fund to convey our expectations of you in respect of your roles andresponsibilities in internal controls. We very much regret the circumstances that have made this reminder necessary. In linewith the COSO recommendations, the trustees of the Shalala Pension Fund expect you to adopt four major responsibilities inrespect of overseeing internal controls in Global-bank. At the outset, the trustees of the Shalala Pension Fund would like to express their disappointment that you should suggest,as you did at the recent EGM, that the loss incurred by MrMineta was ‘genuinely unforeseeable’. From our reading of thesituation, you are highly complicit in the loss through your failure in respect of the company’s internal controls. Ultimately, it is the chief executive of any organisation who must assume final responsibility for all internal controls. It is youas CEO who must assume ‘ownership’ of the systems and this ownership must be a part of the manner in which you leadthe company. In particular, this means that you must set the tone from the top in both establishing and enforcing the controlenvironment. We understand that a number of failures to return compliance information from Philos were not acted uponand this is a clear failure on head office’s part to enforce the internal control environment throughout the company. The controlenvironment is enforced through having internal control compliance embedded within the culture of the company and it was,in our view, clearly your responsibility to facilitate this. From what we can gather, the culture in the Philos office was moredriven by MrEvora’s personality than by your imposition of norms from head office and this was clearly one of the causes ofMrMineta’sbehaviour. This setting of the tone should express itself in terms of the way that managers are treated and the way that the tone iscascaded down through the company including to individual branch offices such as Philos and other subsidiary companiesif relevant. It seems self-evident, in hindsight, that the Philos office felt they could act in breach&nb
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