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Part of Corporate responsibility: what you owe, not just what you give

Corporate Responsibility Checklist: 12 Pre-Board Audit Tests

A [corporate responsibility](/corporate-responsibility) checklist for finance or internal audit: 12 evidence tests to run before a board review or report.

A corporate responsibility checklist for finance or internal audit should test the records behind the program, not just the language in its report. These 12 pass-or-fail checks focus on traceability: whether an effect, commitment, payment, grant, or public claim can be followed to a dated document and an accountable owner.

Run them before a board review or publication, and keep the evidence file so another reviewer can repeat the checks. A pass means the record can be produced and checked; a policy statement alone is not evidence.

Set up the review

Ask for the working register, the records used to prepare the latest report, and the relevant finance or program documents. Record the version reviewed and the person who supplied each file.

For every test, mark pass or fail and note the document that supports the result; if the document is missing or cannot be reconciled, record a fail rather than filling the gap with an explanation.

The checklist is not a rating of whether the company is responsible. It is a review of whether the program's own records support what the company tracks and says. Do not combine the results into an average that conceals a missing register or an unsupported public claim. Use the failed item to identify which file, owner, or control needs follow-up.

Check the effects register

1. Can you identify the register's coverage? Pass if the file states the period and business activity it covers, identifies its scope, and records exclusions. Fail if a reviewer cannot tell which operations or groups the register was meant to include.

A list without a defined boundary is hard to check against the rest of the evidence.

2. Can you trace a register entry to its source?
Select entries and follow each one to a document or other recorded basis. The entry should identify who is affected and show where its supporting information came from. Fail if the register contains broad labels, such as "the community," with no row-level detail or source to examine.
3. Can you tell when and why the register changed?
Pass if the file has a review date and a record of material edits, including who made them. Compare the current version with the prior one and ask for the basis of any addition, deletion, or changed description. Fail if there is no reliable way to distinguish a current entry from an outdated one.
4. Is each entry assigned to a named owner whose incentives do not control the answer?
Check the owner listed for each row and whether that person's pay or performance measure depends on the result being reported. Where the same role controls the target and the operating outcome, the owner should be elsewhere or the conflict should be recorded. Fail if the assigned owner is only a function, committee, or person unaware of the assignment.

Effects register: four tests

  • List of effects on non-customers and non-staff
  • Ranked by effect on them, not risk
  • Every effect has a named person
  • Owners whose pay does not depend on answer

Trace costs, missed commitments, and supplier payments

5. Can you trace the cost of a commitment through the records? For commitments that require spending or resources, follow the stated commitment to its approval and finance records.

Pass if the records show where it was authorized and how it is tracked; fail if the program describes a commitment but cannot identify the corresponding record or accountable owner. This test checks the audit trail, not whether a particular decision was morally or commercially correct.

6. Are slipped commitments recorded as exceptions?
Compare the commitments due during the review period with the completion records. Pass if a missed or delayed commitment has a record of who noticed it and what follow-up occurred. Fail if the program reports no slippage without supporting records, or if a known delay has no owner or documented response.
7. Can you calculate the gap between agreed and actual supplier payment dates?
For the smallest suppliers, compare agreed payment terms with the dates payments were made. Pass if the gap is recorded, has a named owner, and can be reproduced from the underlying records. Fail if nobody can produce the number or explain which records it uses. For related supplier-record questions, see corporate responsibility metrics.

Cost tests: three items

  • Last decision choosing the more expensive option
  • What happened to commitments that slipped
  • Payment terms actually met for smallest suppliers

Reconcile giving and communications records

8. Are giving records kept distinct from records of operational effects? Check the accounts, program lists, and responsibility-report drafts. Pass if giving is separately identified and the report does not use those records as evidence for effects caused by operations.

Fail if donations or volunteering are blended into a response about operational performance, or if the same item appears in both categories without an explanation.

9. Do grant records show the terms and stated purpose?
Review the grant list and a selection of grant files. Pass if the records show whether support is multi-year or annual, whether it is restricted or unrestricted, and whether its stated purpose is impact or relationship-building. Fail if the organization cannot establish the terms or purpose from its records. This makes the commitments visible without assuming that every grant should have the same design.
10. Is the communications spend-to-program spend ratio known and defensible?
Ask for the calculation and the records behind both sides of it. Pass if the categories are defined and the calculation can be followed to finance records. Fail if nobody has calculated the ratio, or if communications costs are omitted without a documented basis. The test is whether the comparison can be checked, not whether it meets an invented target.

Giving: three tests

  • Giving kept separate from effects
  • Shape of the givingmulti-year, unrestricted
  • Communications spend against program spend

Verify claims and place-decision files

11. Can a reviewer substantiate a sample of published claims? Select three statements at random from the prior year's published material. For each, check that the basis is identified as measured, estimated, modeled, or reported by someone else, and that a supporting document exists.

Fail if supplier self-reporting is presented as independently established fact, or if the methodology was selected after the result was known. The Federal Trade Commission's policy statement on advertising substantiation expects advertisers to have a reasonable basis for claims before they are disseminated.

For environmental claims, the same evidence discipline applies: identify the basis of the statement and retain the supporting record. The related discussion of what can be claimed about environmental performance is in sustainability ethics. The FTC's Green Guides explain how marketers can substantiate environmental marketing claims.

12. Is there a traceable file for the last decision affecting a place? For a closure, relocation, or large redundancy, check whether the file records the decision chronology, the stated reason, the approval trail, and what was documented as left behind. Pass if the record can be assembled from dated documents and the people responsible are identifiable. Fail if the file consists only of a final announcement or an account written after the decision, with no supporting chronology.

This is a records test, not a legal review of consultation or notice requirements. Those requirements vary by jurisdiction and circumstance; the checklist does not determine what applies. A closure can also raise ethical dilemmas that a records test does not settle.

Keep any legal review separate from the audit finding about whether the company's own decision file is complete. For a worked example of a program, see the corporate responsibility case study.

Claims and places: two tests

  • Published claims you could evidence if asked
  • Last decision that affected a place

Read the results and assign follow-up

Failed itemsWhat the review establishes
1–4The register's scope, sources, update history, or ownership cannot be reliably checked.
5–7Cost records, missed commitments, or supplier payment timing lack a reproducible trail or accountable owner.
8–10Giving, grant terms, or communications spending cannot be clearly reconciled to the program records.
11–12The basis for published claims or the file for a place decision is incomplete.

Reading the failures

Failing items

1 to 4
No register, no program to assess
5 or 6
Program has never constrained a decision
7
Financing yourself with others' working capital
8 to 10
Giving answers a question it does not answer
11 to 12
External account and internal reality separated

Reading

1 to 4
5 or 6
7
8 to 10
11 to 12

For each failure, note the missing document or reconciliation, the person responsible for supplying it, and the next review point.

Keep the original fail on the record if a document arrives later; note the follow-up rather than rewriting the result as though the evidence had been available during the review. A repeated failure may indicate that the recordkeeping process needs attention, not simply that one file was misplaced.

Finance or internal audit should run the review rather than the team whose report is being tested. That reviewer should be able to request source documents and compare them with the program's own records.

The checklist can then support a more specific board discussion: which statements have evidence behind them, which records need correction, and which items remain unresolved. Keep the working file available to the next reviewer so the checks can be repeated. Where a failure points to a design gap rather than a missing file, the corporate responsibility framework is the place to look.

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