Sarbanes-Oxley Program Implementation Guide

This guide provides procedures, checklists and summaries that can be used to implement changes within an organization’s Sarbanes-Oxley program. It discusses change management types, changes to processes and controls, control change process timelines, changes to control documentation, change history reports, quarterly control checklists, sample checklist reports, additional standard reports, and key roles and responsibilities.

For this guide’s procedures, process owners are required to evaluate the significance of all changes to the internal control over financial reporting each quarter. In order to do so, all controls that changed during the quarter will be updated in the SOX software. Changes to controls will be reviewed by the SOX office, internal audit and corporate, as part of the quarterly review process.