Recently, COSO auditors, link, found
- the absence of a periodically acknowledged code of conduct
- a lack of communication of management responses to conduct/ethical lapses
- employee standards of conduct are sparsely worded; ...
- no code of conduct is formally acknowledged
- management culture shows varying emphasis on integrity and ethics
- no formal metric for measuring management responses to problems
- District management's approach to allegations of nepotism, cronyism and protection of property needs improvement
- a perception that management is ineffective or ambivalent about enforcing standards of conduct, and enforces rules inconsistently
- the school board is not focused on evaluating the effectiveness of "the tone at the top"
- the district does not publish a code of conduct
- no systematic confirmation that required performance reviews are actually done
- promotion criteria do not include adherence to behavioral standards
- improprieties are not reported to appropriate personnel
- no documentation of closure of complaints made to the Service Center or to the Superintendent
- no clear metrics showing top management is aware of the volume or nature of complaints
- formal monitoring of internal controls needs improvement
- personnel are not periodically required to acknowledge compliance with the code of conduct
- the District does not conduct formal self-assessments of control processes
"When topics relating to the COSO report... arise, then I will address the related COSO recommendation. That's my method."They haven't arisen apparently, and whistleblower complaints are up 61%.
Not one of them received review and approval by anyone outside the administration of the APS, despite the fact that most of the complaints are probably about administrators, the result of an ongoing denial of due process to whistleblower complaints, driven by the need to keep administrative and executive misconduct secret from the public.
photo Mark Bralley
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