“We would like to benchmark how companies with a listing in the US consider and evaluate their disclosure controls including the effectiveness thereof. We are particularly interested in the methods used by companies to capture any disclosures that may be required in the period immediately prior to filings e.g. of Form 20-F. If you are prepared to share your processes and experience we would be grateful.”
We no longer have a US listing but when we did, we introduced a Letter of Assurance process whereby all business MDs and Corporate Function Heads were required to issue Letters of Assurance to the CEO prior to the release of quarterly US filings; these letters were pre-formatted and covered a multitude of control and disclosure issues. The CEO and CFO then selected a sample of respondents each quarter and interviewed them by telephone to test the procedures that they had applied in completing the Letters. We also had an outsourced internal audit function whose remit included the review of disclosable matters. The Letters seemed to work and were appreciated by our D&O insurers.