SOX Policy Evaluation Checklist

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1 (needs updating) Approved es Balance Sheet Assets Cash & Cash Equivalents Investments/ Foreign Exchange Accounts Receivable Cash receipts Bank account reconciliations Banking policy and relationships Cash disbursements/manual checks Check signing requirements Outstanding checks cash Petty cash Deposits Investment responsibility Foreign currency translation Fair value of financial instruments Derivatives policy Investments in associated companies Functional currency Hedging guidelines Investment portfolio composition accounts receivable Credit memos Allowance for doubtful accounts/credit risk Credit risk Credit balances Customer deposits Records maintenance Invoice billings Property and Equipment Source: Page 1

2 AFE's Acquisitions and dispositions Assets of discontinued operations Disposals Asset retirement obligations Reconciliations Physical asset security property and equipment Inventory Liabilities Other Assets Accounts Payable Inventory accounting Physical inventory procedures Multi-client library Goodwill and intangible assets Other long-lived assets Other current assets (pre-paid expenses, inventory, spares, deferred costs, advances) Software costs other assets Accounts payable Competitive bids Request for proposal Purchase requisitions Purchase orders Contracts Purchasing procedures Vendor selections Vendor file maintenance Equipment rentals Other Liabilities Source: Page 2

3 Accrued expenses (employee benefits, debt restrictions, vessel operations, interest, severance, advances) Deferred revenue Allowance for bad debts Bank overdrafts Income taxes Accrued employee compensation Deferred taxes Warranties Debt Long-term debt (Approval, debt issuance cost, accounting for current maturities) Subsidiaries with separate debt Operating and capital lease obligations Short-term debt Income Revenues Expenses Stockholders' Equity Capital stock Stock transactions Revenue recognition Revenue reporting Cost of sales Third party reimbursable expenses Payroll Operating income (expense) Capitalization Depreciation and amortization Research and development Selling, general and administrative costs Travel and entertainment Impairment of long-lived assets Source: Page 3

4 Steaming and mobilization Income (loss) from associated companies Interest expense/income Minority expense Results of discontinued operations Insurance Other expenses Fiscal adjustments Management Human Resources Chart of accounts Consolidation Segment reporting and disclosures Reporting packages Business combinations Period-end financial reporting Month-end closing procedures Reconciliations Inter-company allocations Variable interest entities Commitments and contingencies Related parties Disclosures Process change control Unusual transactions Budgeting and forecasts Release of financial/ confidential information Journal entry Employment (hiring, promotion) policies Employee benefits Compensation / Payroll Termination Performance appraisals Source: Page 4

5 Executive compensation Incentive compensation Employee handbook Attendance, holidays, vacation, sick leave Relocation payments Internal transfers Family & medical leave Americans with Disabilities Act Share-based compensation plans Fair employment practices Orientation and training Employment verifications / background check Equal opportunity Sexual harassment / other harassment New employee processing Hiring of consultants / contractors Personnel files and records IT Other Corporate Governance Information security Systems change policy Software licensing Electronic information ( ) systems Trade shows Workplace rules, safety and health Disaster management / business resumption Corporate credit cards Use of company vehicles Magazine subscriptions Record retention, storage and disposal Ethics hotline and policy on handling of complaints US Antitrust Law Compliance Delegation of authority Source: Page 5

6 Code of Conduct Entertainment and gifts Insider trading Related party transactions Conflict of interest Foreign corrupt practices act Personal loans to directors and executive officers Board of Directors Internal Audit Corporate governance guidelines Audit committee charter Remuneration committee charter Internal audit charter Pre-approval of audit and non-audit services Source: Page 6

Records Retention. 3. You file a fraudulent return; keep records indefinitely. 4. You do not file a return; keep records indefinitely.

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