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【正文】 Structures Law and Compliance: An independent anization, with centralized and decentralized characteristics: ? Centralized reporting lines should run exclusively to the General Counsel and Chief Compliance Officer. ? Reinforces independence。 prevents conflicts of interest in matters such as performance evaluations and pensation decisions. ? Should colocate with the businesses, to maximize munication with the entity they advise and support. Representation on business unit Risk Management and other Committees, plus: ? General Counsel and Chief Compliance Officer should present regularly scheduled reports to the Audit Committee. ? General Counsel should attend all Board and Audit Committee meetings. 8 II. Internal Controls Overview 9 Internal Controls Overview COSO – Integrated Framework of Control 10 Integrated Framework of Control – Key Concepts: 1. Internal control is a process. It is a means to an end, not an end in itself. 2. Internal control is effected by people. It’s not merely policy manuals and forms, but people at every level of an anization. 11 Integrated Framework of Control – Key Concepts: 3. Internal control can be expected to provide only reasonable assurance, not absolute assurance, to a
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