Our conflict-of-interest audit work program ensures trust company ethics and fair securities trading. This document provides a structured framework that outlines specific audit objectives and detailed procedures to ensure that trust companies manage conflicts of interest appropriately. It includes checks on whether employees adhere to the company’s code of ethics, whether transactions are authorized and conducted transparently, and whether fees charged are fair and comparable to those charged to other customers.

Additionally, it scrutinizes the company’s relationships with affiliates to prevent self-dealing and ensures that all fiduciary investments are made impartially and in accordance with legal standards. The work program also covers the evaluation of securities transactions, the appropriateness of loans between fiduciary accounts, and the monitoring of soft dollar arrangements. By using this document, you can systematically verify that a trust company is protecting the interests of its clients and operating in a lawful and ethically sound manner.

Audit objectives include:

• Ensure that all employees have access to and read Company A’s code of ethics.
• Ensure that the governing trust instrument authorizes Company B to act as broker.
• Ensure that Company B charges Company A fees that are in line with charges to other customers.
• Ensure that there are no loans given to Company B, any affiliates or employees other than loans to fiduciary accounts, or loans between fiduciary accounts.