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Ethics Assessment, Attestation and Conflict of Interest Engagements

Rigos has a group of experienced attorney-CPAs available for consultation.  There are basically two services. 

First is helping a CPA firm create a conflict of interest internal system that complies with the new AICPA standards.  All engagements are subject to a conflict of interest analysis and safeguard procedures may be used if approved by client management.  We can help you in analysis and creating appropriate documentation.

Second is rendering an independent opinion on the effectiveness of a particular safeguard intended to mitigate a particular conflict of interest risk.  This is particularly important given the new enhanced AICPA required conflict of interest rules effective in 2015 and the potential Act Discreditable characterization if the ethical safeguard is ineffective.

We also offer ethics attestation engagements for corporations. The objective at conclusion is a formal opinion letter which concludes that a corporate ethics program is adequate in design and functioning as intended. Before the final opinion is issued we may make suggestions for improvements which your enterprise may find helpful. Ideally these suggestions should be incorporated into your system so the final opinion letter covers your improved ethics system.

This final opinion and related documentation may be quite useful to an enterprise. The results may be communicated to all the enterprise's stakeholder's, including: employees, stockholders, suppliers, and customers. We recommend the annual financial report contain a section summarizing the new ethics improvements your company has implemented and at least a mention of the unqualified attestation opinion letter. This may also be useful evidence if litigation occurs; while not conclusive as to individual incidents, our independent objective attestation does evidence your CPA firm's strong commitment to a quality, continually-improving ethics program.

The actual ethics attestation (audit) will vary depending upon the nature of your accounting firm and the industry. It involves a coordinated ethics risk assessment by our team of experienced attorneys, CPAs, CMAs, employment practice insurance and personnel professionals. Ethics for Corporate USA in the new century is a little law, a little accounting, a little human resources, a little experience in the field, and a lot of common sense. Clearly the endeavor is inter-disciplinary. Our experience in conducting hundreds of ethics workshops for State CPA Societies, CPA firms and diverse corporate business enterprises gives our team a broad and objective perspective on the current state of American corporate ethics.

Our team's ethics assessment of your corporation generally includes:

  • Your corporate Mission/Vision Statement and its relationship to the detailed day-to-day Code of Conduct.
  • Thoroughness of your Code of Conduct both as it relates to the particular industry and the ever-changing federal and state laws.
  • Consistency with the core business process and financial and accounting internal control structure of the enterprise.
  • Ethics Officer Position and structure of the Ethics Office.
  • Top Management's involvement in the ethics program.
  • Employment hiring and termination procedures.
  • Employees - new and existing - professional training in ethics.
  • Surveying employee behavior perceptions of the organization's ethics environment.
  • Reporting system of both complaints and grievances.
  • Investigation procedures for both complaints and grievances.
  • Due process and appearance of fairness considerations.
  • International concerns, if applicable.
  • Employment Practices Liability insurance coverage.
  • Regular ethics committee meetings and agendas.
  • Annual report to and review by the Board of Directors.
  • Such other areas particular to your enterprise and/or industry.
  • Such other related concerns as your management may have.

If you would like more information on our ethics services for CPA firms, please contact us at 206-624-0716 or send an e-mail to


Last updated on 1/26/2017 2:06:27 PM