Sarbanes Oxley 404

Management's methods for assessing internal control will, and should, vary from company to company. The following are the key steps in the process by which management develops sufficient evidence to support its assessment and conclusions:

• Assessing the risk of material misstatement Identifying company-level controls
• Identifying significant accounts and disclosures
• Identifying relevant financial statement assertions
• Identifying significant processes
• Determining which locations or business units should be included in the evaluation
• Documenting the process for assessing internal control
• Documenting the design of controls
• Determining which controls should be tested
• Evaluating the design effectiveness of controls
• Testing and documenting the operating effectiveness of controls
• Evaluating internal control deficiencies and concluding on overall effectiveness
• Communicating findings to the audit committee and auditor