A Guide to Sarbanes-Oxley, Part Two

by

Niquette M. Kelcher
October 2002 -- In Part One of this series, we discussed how the Sarbanes-Oxley Act came to be, outlined its major provisions, shared accounting and finance professionals' reactions to SOA, and explained what it means to the accounting profession.

If you missed Part One, click here. Here's what's covered in Part Two:

• How managers can implement SOA into the company culture
  
• How to keep staff members educated and informed
  

How Managers Can Implement SOA Into Company Culture

Creating new laws and expecting companies to follow them is one thing, but efficient implementation of them is another. Clair Raubenstine, former president of the Institute of Management Accountants, emphasizes the crucial "tone at the top."

According to Raubenstine, "Companies need to communicate that they are resisting the pressures of the financial community and setting realistic goals. Don't set goals too high for the sales staff, for instance. Additionally, managers should encourage open lines of communication between management and staff. Management needs to 'walk the talk.'"

Ethics programs, already a staple in many companies but expected to pop up in more, also should be implemented. Raubenstine suggests companies establish ethics hotlines and assign ethics coordinators so employees can report suspected misconduct without penalization. 

"Management has to continually educate personnel what the company rules are and educate people on how their role fits in with the total organization and the overall mission of the department. Employees need to feel like they are a part of the business," explains Raubenstine.

In turn, he continues, finance and accounting professionals need to recognize that there are more penalties that could be imposed on individuals for not properly reporting financial matters throughout the ranks. "Companies will expect more from their employees so management is properly certifying the financial information," says Raubenstine.

Yvonne LaRose, a Business Management and Personnel Consultant for Executive Recruiting Entrances, agrees that managers need to set an example. "Managers lead by how they conduct themselves; their staff takes their cue on what is important and how to do things based on how managers handle situations. Thus, managers should incorporate into their routine a pattern of following good practices," she explains.

Additionally, adds LaRose, "when reports are presented to a partner or manager, there should not be a rubber stamp approval. Managers need to take the time to actually review the document(s) and ask questions about numbers -- and even sources of information -- to ensure that they know what is there. If there are red flag issues, they should be addressed. Staff should be put on notice that those types of issues are important and attended to at the source so that matters are rectified and the problem abated."

In a SmartPros FMN segment, Dr. Jonathan Schiff, professor of accounting, Fairleigh Dickinson University and president of Schiff Consulting Group, gives similar advice. Schiff says financial managers "should have good documentation of plans, as well as programs in place, that try to do more than merely react to what Congress may come up with, or what the SEC may come up with. They need to be more proactive in designing systems of control that are competitive within one's industry and which raise the level of acumen across management."

Free guidance on corporate ethics is available from a variety of associations. Through the IMA, financial professionals can now get free, confidential guidance on ethical issues via the IMA Ethics Hotline. 

"When financial professionals call the toll-free hotline, their inquiries will be forwarded to an experienced ethics counselor, who provides confidential guidance," explains IMA president Margaret Butler. "This hotline is particularly well-suited for small businesses and solo practitioners who need guidance on ethical issues."

The IMA also offers to corporations the use of its Standards of Ethical Conduct for compliance with Section 404 of the Sarbanes-Oxley Act of 2002.

Similarly, Financial Executives International encourages companies to adopt its Code of Ethics model (Word doc).

How to Keep Staff Member Educated and Informed

Despite the disruption SOA may cause, the show must go on. Says Wyatt: "As with anything new, accounting firms should encourage reading and study." Companies must continue to perform -- and given the current economy they must perform within a limited budget.

So how can managers ensure their staff is up to speed on the new requirements? SmartPros culled expert opinions and various studies on some cost-effective methods for educating accounting staff members on SOA and related topics.

E-learning.

Webcasts and online continuing professional education are among the most efficient and cost-effective means of staying on top of the profession because companies are spared many expenses by educating staff in the office or at home at their own computers.

Nucleus Research reports that thousands of ongoing return on investment (ROI) studies for Global 2000 corporations indicate that companies adopting e-learning initiatives recognize "first-tier benefits including reduced costs for travel, human resources overhead, regulatory compliance, and customer-support costs." Additionally, second-tier benefits include "improved employee performance that directly impacts profitability." Nucleus found that most organizations could gain significant returns from even modest investments in e-learning technology."

Adds LaRose: "Seminars are an extremely valuable tool in developing a greater appreciation of the terms and nuances of the Act. From these trainings, professionals and leaders will be able to get immediate, first-hand answers to the initial questions -- answers that will build understanding of what is involved and some approaches to responsible attention to details."

Books (hot off the presses)

An entire library of accounting and finance books related to the upheaval of the industry have been published, including material on detection and prevention of fraud, audit committee and ethics handbooks, investor guides, cost management resources and management primers.

Book recommendations from SmartPros:

• The Financial Numbers Game by Charles W. Mulford
  
• Take on the Street by Arthur Levitt
  
• Ethics for CPAs: Meeting Expectations in Challenging Times by D. R. Carmichael, Dan M. Guy, Linda A. Lach
  
• The Audit Committee Handbook by Louis Braiotta, Jr.
  
• Financial Statement Fraud: Prevention and Detection by Zabihollah Rezaee
  
• Paying for Performance: A Guide to Compensation Management by Peter D. Chingos
  
• Valuation of Companies in Emerging Markets by Luis E. Pereiro
  
• Essentials of Corporate Performance Measurement by George T. Friedlob, Lydia L. F. Schleifer and Franklin J. Plewa Jr.
  

Resources:

• Third Party Management for Financial Services, free Third Party Management in Financial Services Illustrated graphic download to visualize and develop an effective approach to managing third party risk in a GRC context.
  
• OCEG Events
  
• OCEG CLE Webinars
  
• OCEG Resource Collections
  

Sponsored Links:

• Building Public Trust: The Future of Corporate Reporting
  
• Fraud 101: Techniques and Strategies for Detection
  
• The Real World of Finance: 12 Lessons for the 21st Century (Wiley Finance)
  
• Chairman of the Board: A Practical Guide
  

A Guide to Sarbanes-Oxley, Part One

It was 2002. As a measure to ameliorate the financial industry atrocities that were revealed, the Sarbanes-Oxley Act was adopted. Questions arose regarding its effectiveness, its reach, implementation and adoption. SmartPros dedicated a two-part article to examine the Act and collect opinions and reactions from professionals associated with the industry. Even though 12 years have passed since its implementation and the article has been removed from the SmartPros site, it would serve financial industry newcomers to have a reference point about the "why" of the Act and the early reactions to it.

A Guide to Sarbanes-Oxley, Part One

by
Niquette M. Kelcher
October 2002 -- The groundbreaking Sarbanes-Oxley Act signed into law by President Bush in July 2002 will forever be remembered as the legislation spurred by corporate corruption, crooked CEOs and creative accounting.

In reality, the accounting industry has been heading toward a major reform for many years - it just finally came to a head. Now that it's here, financial executives find themselves at a crossroads, facing the daunting task of implementing major changes in day-to-day operations, while at the same time quickly educating their staff on the sweeping changes brought on by proactive - but also reactive - legislation.

This article provides a concise overview of the many facets of the Sarbanes-Oxley Act (SOA) including:

• How accounting reform caught up with the industry
  
• Major provisions of the Act
  
• Reaction from the trenches
  
• What SOA means to the accounting profession
  
• How managers can implement SOA into the company culture
  
• How to keep staff members educated and informed
  

How Accounting Reform Initiatives Caught Up With the Industry

It's viable to stretch back to the beginning of accounting as an "industry" to address how this recent reform effort came to be, but all we really need to do to understand this phenomenon is step back into the 1990's - a decade that proved to be incredibly tumultuous for the accounting industry overall, a decade that began with an economic slump and ended at the tail-end of a technology boom - to understand why we are here today.

In former Securities and Exchange Commission chairman Arthur Levitt's new book, Take on the Street, published this month, he writes about the politically-charged nature of Wall Street during his tenure as SEC chief in the 90's. Levitt, the 25th chairman and also longest-serving, held the reigns at the watchdog agency for seven years under the Clinton administration. A strong supporter of auditor independence, Levitt, who calls himself "pro-investor," constantly battled with accounting firms and the AICPA over the controversial issue, as firms began to package their auditing services with technology consulting.

But it was an incident involving the Financial Accounting Standards Board that Levitt cites as the biggest mistake he made as SEC chief. In the early part of the 90's, Levitt says he persuaded the FASB to soften its stock-based compensation rules because of political and corporate pressures to do so. (Of course, this same topic is in debate today.)

Levitt states that he learned a valuable lesson from this mistake: "Accounting firms were passive when it came to standing up for investor interests," he writes. "[Auditors] failed to rally to the cause of investors and instead supported the demands of corporate clients. They had become advocates. I would forever look upon the accounting profession differently after this episode."

Hence, Levitt began to tout major accounting reform efforts. At the turn of the millennium he left current SEC chief Harvey Pitt with a lot of reformation left to be done, and until Enron happened, the industry was pretty sure Pitt's "kinder" and "gentler" SEC would stem the talk of accounting reform.

However, Enron helped investors see what Levitt realized many years prior - that the self-regulated industry failed to protect them. Consequently, a weak economy and discontent voters pushed Congress to action. Suddenly Levitt's ideas weren't so radical after all; In fact, many of the reforms proposed by him while he served as SEC chairman have been adopted by the Sarbanes-Oxley Act, legislation that has yet to show its true colors.

Major Provisions of the Sarbanes-Oxley Act

Specifically, the new law, as explained in a SmartPros Financial Management Network segment:

1. Establishes an independent auditing oversight board under the SEC;
   
2. Beefs up penalties for corporate wrongdoers;
   
3. Requires faster and more extensive financial disclosure; and
   
4. Creates avenues of recourse for aggrieved shareholders.
   

One of the most fundamental changes for the accounting profession is the creation of the independent Public Company Accounting Oversight Board, a non-profit corporation funded by public companies and subject to SEC supervision. At this time the Board has yet to be formed, but it is expected to wield significant power. [See $435,000 Oversight Positions Prove Tough to Fill]

Here are links to in-depth texts on the Act:

• Summary at the AICPA Web site
  
• Overview at the Financial Executives International Web site
  
• Full text (PDF) and SOA timeline at CCBN Regulation FD Center
  

Other articles worth reading:

• Four Significant Accounting Changes of the Sarbanes-Oxley Act
  
• Audit Committee and Management Disclosure Requirements of the Sarbanes-Oxley Act
  
• Lawmakers Reach Accord on Corporate Reform Bill
  

Reaction from the Trenches

So far, the reaction from accounting and finance professionals in the field has been mixed. Many say it's about time such legislation passed, while others matter-of-factly state that all the legal ramifications in the world won't stop corporate crooks from lying, cheating and stealing.

In a recent survey conducted by CFO magazine, most financial officers voiced opposition to specific reforms. Some 52 percent, in fact, did not believe audit firms should be banned from providing consulting services to clients; 65 percent did not think auditors should be barred from going to work for clients for a specified period; and 52 percent did not think it wise to rotate auditors on a regular basis.

"For CFOs," says Julia Homer, editor-in-chief of CFO magazine, "all of these proposals are just going to make their jobs more time-consuming and expensive."

Gary Wyatt, CPA, a benefits and compensation specialist with Texas-based Travis Wolff Advisors & Accountants, says those accounting firms with a large number of public clients will be dramatically impacted.

"It will change the way they do business," Wyatt explains. "No longer can the financial statement audit be used as a 'loss leader' in hopes of selling more lucrative tax and consulting services. The largest accounting firms will likely lose many tax-consulting clients to each other. Also, high-quality regional and specialty 'boutique' accounting firms may pick up significant new tax and consulting engagements."

Wyatt also believes private companies will feel the effects of SOA: "Even though the Act is generally applicable only to public companies, the principles may eventually spread into 'best practices' affecting auditors of private companies."

William Maslo, an experienced speaker on financial topics with his own CPA practice in Reading, Pennsylvania, agrees. He speaks for the "non-SEC practitioner" who "is fearful that the concepts of the Sarbanes-Oxley Act could be adopted by state legislatures to affect non-public companies. The larger firms manage to spin off divisions and operate in a way that, at the end of the day, all is well. But for smaller firms this could spell disaster," explains Maslo.

Rebecca Wallace, a Colorado-based attorney and CPA, says the "Act is most significant for accountants because it takes away accountants ability to regulate themselves . . .. While increased oversight of the accounting firms should help to keep the audits in check, too much SEC control over the process is not necessarily a good idea. The creation of layer upon layer of bureaucracy could lead to inevitable inefficiencies in the end sought by the Act."

Bruce W. Marcus, a consultant in marketing and strategic planning for professional firms and the editor of The Marcus Letter on Professional Services Marketing, says the ramifications of the sweeping SOA "may be more damaging than the conditions they mean to correct."

In a recent article, What Sarbanes-Oxley Will Mean to the Accounting Profession, Marcus highlights the inherent challenges accountants - and accounting firms in particular - now face with the implementation of SOA, including the separation of auditing and consulting services. "Many services are relevant to improving the audit," he argues. To meet the needs of its clients, firms will need to find a way to implement consulting services that improve the audit, such as technology services that improve the flow of financial data, without the "consulting services that flagrantly taint the attest function."

Additionally, Marcus recommends the accounting profession re-examine its partnership structure by "reworking the governance structures for better management, and to allow the outside world to see more clearly how each firm is serving the clients and protecting their shareholders."

Likewise, the profession and those who regulate it should remember it does not operate in isolation to the markets it serves. "The time has come for all professionals to recognize that they exist only in their ability to meet the needs of their clients and the public – and not themselves," says Marcus.

Go on to Part Two and learn:

• How managers can implement SOA into the company culture
  
• How to keep staff members educated and informed

Sponsored Links:

• Governance, Risk Management, and Compliance: It Can't Happen to Us--Avoiding Corporate Disaster While Driving Success
  
• Building a Career In Compliance and Ethics
  

Disclosure

April was an eventful time on ERE Media. In terms of drama, it reached the height of one of the dramatic crises. Some outrageous public statements were published by no less than David Manaster, statements that were untrue, unfounded, uninvestigated, and based on hearsay.

Ethics in Recruiting

Members of the Ethics in Recruiting Group,

Over the weekend, the staff members of ERE received a number of complaints from group members regarding the group's leadership and facilitation. These are not the first complaints we have received in this regard, but they have been the most egregious, including several inappropriate bannings of group members by the group leader.

It is my responsibility, and that of the ERE staff, to make sure that the environment on ERE.net and all of the discussion groups is one that is conducive to professional discourse in the recruiting profession. Due to the recent abuse, I have made the decision to revoke the authority of the group leader in this group, effective immediately.

This decision will be welcomed by many and controversial for a few, but it is important to restore a professional networking environment and consistent leadership to this group, and after agonizing over the decision, I have come to the conclusion that this is the only way to do it. I welcome feedback from the group members on this decision, and as always, I will read every email that I get.

The leadership role for these groups will be temporarily transferred to an ERE staff member, Brendan Shields, until we can find a new permanent leader to take her place. If you have any suggestions or would like to volunteer for the responsibility (and at times it can be a time-consuming one), please email me.

I can be reached via the ERE Network or at david(at)ere.net.

Given the nature of the representations, it seemed these words were an invitation to respond. As the founder and leader of the Ethics in Recruiting group, I did on April 22, 2007 at 5:44 PM, so by saying:

Three people have been banned from the group. All but one have had the reason explained. In some manner, they have continued they conduct remotely in regard to encouraging diruptive behavior or discouraging professionalism. The three:

Karen Mattonen - July 30, 2005: A short summary of the matter is unethical behavior in many aspects in addition to disruptive conduct in other parts of the Network and encouraging others to behave in like manner both in this group and in other parts of the Network.

Dave Mendoza - April 29, 2006: The URLs that finalized the determination to eject Dave are below. In addition to the inflammatory and essentially mutinous public remarks, there was outright unethical conduct on his part in many instances, as well as harassment that continued until this past Summer.

* http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={038AE09A-CBA8-46C7-B524-1A4FB45D2040}
* http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={0DF91953-53E8-4E30-8814-B239036E4C6D}

Maureen Sharib - February 20, 2007: The explanation I gave to Maureen reads as follows:

"Last May I removed you from the L.A. Metro group. That action was taken because of the stance I interpreted you had taken with regard to the flaming that was being directed at me by Mendoza, Sunil, and Karen. The response you gave was, "I know they're a pain but somebody's gotta tell 'em like it is."

"As I said, my action was taken through my interpretation of those words. My interpretation was that you supported their flaming and encourage it.

"You've also said publicly that you do not discourage that type of behavior in your groups either on ERE, Yahoo! Groups, or anywhere else. I cannot keep someone in my groups who condones and encourages such behavior. My interpretation of your words is that you are fixed on your path."

Manaster's post goes on to say:

"It is my responsibility, and that of the ERE staff, to make sure that the environment on ERE.net and all of the discussion groups is one that is conducive to professional discourse in the recruiting profession. Due to the recent abuse, I have made the decision to revoke the authority of the group leader in this group, effective immediately."

It is interesting that his post was made almost immediately above mine that read "A Gentle Reminder." It was one of two similar stand-alone posts. Those stand-alone posts did not include the numerous others wherein I asked for discussion, not arguments; professionalism, not bullying.

Sorry, I do not have time to go through each line of each discussion thread. But the stand-alone posts can be found at:

* http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={ED0FAD73-B0B3-4CC2-B7A7-5CF43ACCE520}
040107

* http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={8A7A4AED-B689-4ABA-AAE5-07CA06629C85}
050406

Given the representations that were made in Manaster's post, it appears there was very little investigation into this matter and the determination was based on mere hearsay. As I've said on numerous occasions as private coaching as well as public recommendation and group admonition, we need to conform to discussing the issues as theoretical matters and not personal testimony; we need to be professionals and discuss. Shouting and bullying, attempts a being the "last word" or always right are not appropriate for this group. Further, I endeavor to *open* discussion, not shut it down because of deflating statements.

We should be using this forum to discuss, explore, learn, develop.

Apparently, there is very little room for discussion and plain view of the truth in that venue. Not only was the response removed, but in retaliation, I was banned from the network.

Being on ERE's network was a bit like being one of the characters in a Shakespearean play. And all it takes is being silent for a time and observing to realize the identity of the puppeteers in the drama. It is quite interesting to hear the same people toss in a name and a remark that challenges action in order to avoid being proved wrong. You have to consider why the name and the challenge are even part of the conversation as they have no relation to the real, underlying focus. And that is when the sham becomes plain, as well as the identity of some of the players. That is also when the realization occurs that gossip keeps the flames of dissention alive. That is when to focus on where your footsteps should not fall lest you find yourself nested in the trap that was laid.

Los Angeles Metro Recruiter Networking

The identical announcement was posted to the L.A. Metro group either a few minutes before or a few minutes after the Ethics notice. Again, I am the founder and was the group leader of the group. Again, in light of the same allegations and representations that were published without investigation, discussion, or regard for the truth, I had the impression there was a request for a public refutation and statement from me. To that end, I responded on April 22, 2007 at 6:52 PM as follows:

There have been 5 who have been banned from this group. Two were fake IDs and there is still one other that is suspicious and has been deleted from the Network, "Kimchi Chow." The two that were verified were

Cheese Wizzer 2/16/2007
whore wrh 10/5/2006

The other three ejected members are:

Karen Mattonen - July 30, 2005: A short summary of the matter is unethical behavior in many aspects in addition to disruptive conduct in other parts of the Network and encouraging others to behave in like manner both in this group and in other parts of the Network.

Maureen Sharib - May 18, 2006: Given the freshness of the events in May 2006, it did not appear an explanation was necessary. However, in February of this year, I discovered Maureen was also a member of the Ethics group. The explanation applied to both groups and on February 20, 2007 reads as follows:

"Last May I removed you from the L.A. Metro group. That action was taken because of the stance I interpreted you had taken with regard to the flaming that was being directed at me by Mendoza, Sunil, and Karen. The response you gave was, "I know they're a pain but somebody's gotta tell 'em like it is."

"As I said, my action was taken through my interpretation of those words. My interpretation was that you supported their flaming and encourage it.

"You've also said publicly that you do not discourage that type of behavior in your groups either on ERE, Yahoo! Groups, or anywhere else. I cannot keep someone in my groups who condones and encourages such behavior. My interpretation of your words is that you are fixed on your path.

"It was not until you began posting in the Ethics group that I realized (or remembered) that you were also in
that group. I determined that it would be prudent to be watchful of the posts and take action if it was
warranted. I asked the ERE back office to put you on "Inactive" status so that I could monitor what was
happening. They refused. I was left with no other alternative since group leaders do not have moderation
tools.

"I felt you deserved an explanation. With removal of you from the group, there is no means of measuring the
quality of the participation. The situation at present is either black or white and no grey.

"The two posts you have made have quality and good discussions have flowed from them. Perhaps this
situation will encourage ERE folk to develop some moderation tools so that we are not faced with only two choices."

Sarah White - April 6, 2007:

insulting and inflammatory post here
* http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={0CEFCEE7-1D81-43BB-92A2-71C048D78F65}
then cross-posted for effect here
* http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={A3217321-2F0E-47FC-8E2F-57D2C92173AB}
along with additional defamatory remarks posted here
* http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={0CEFCEE7-1D81-43BB-92A2-71C048D78F65}

after an email exchange where I had the impression the matter and insults were resolved. It was not; it continued.

Manaster has also said in relation to this group:

"It is my responsibility, and that of the ERE staff, to make sure that the environment on ERE.net and all of the discussion groups is one that is conducive to professional discourse in the recruiting profession. Due to the recent abuse, I have made the decision to revoke the authority of the group leader in this group, effective immediately."

As with the Ethics group, this announcement was posted almost immediately above a stand-alone reminder about decorum and protocol. That one was labelled

Some Miscellany
http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={1C021688-2530-4D09-AEAE-FF13A1360254}
on March 29, 2007

The Better to Serve
http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={348A7D24-9F01-4BB0-8E14-BB3F81AD8E47}
March 19, 2007

Reminder
http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={A5846F09-ADA7-4610-A7A9-14A1EA3B3F37}
May 4, 2006

Reminder
http://www.ere.net/erenetwork/groups/posting.asp?LISTINGID={2045690B-41D6-4FED-9379-56D1BC703DD4}
June 18, 2005

Again, I simply do not have the time to go through each line of every thread for the group. Suffice it to say that there have been reminders about protocol and encouragement to use it throughout the history of this group.

Given the representations that were made in Manaster's post, it appears there was very little investigation into this matter and the determination was based on mere hearsay. As I've said on numerous occasions as private coaching as well as public recommendation and group admonition, we need to conform to discussing the issues as theoretical matters and not personal testimony; we need to be professionals and discuss. Shouting and bullying, attempts a being the "last word" or always right are not appropriate for this group. Further, I endeavor to *open* discussion, not shut it down because of deflating statements.

But the outlandish remarks died away. Replacing them were offlist requests that I post all manner of things on the board in the stead of others. How curious it was to receive job postings that many people wanted, expected, me to rewrite, publicize, and perform a search for. I would also appreciate knowing who put out that mis-information?

I would appreciate knowing why there was an impression that I am the only one who may post to the board. The impression could not have come from me because there have been quite a number of times I have publicly asked group members to feel free to talk with one another, to post on their own behalf, and requested feedback on various issues. Encouragement of networking is part and parcel of our live and online networking meetings. And I have had time to counsel many offline as well as provide support that it doesn't appear other group leaders provide (based on lack of response from others).

Again, it appears that impression was incorrect. Not only was the post removed, I received an incendiary email regarding the post and again notifying me that I was ejected from the network.

In light of the long-standing, unabated interference with both groups and the lack of higher leadership support, I had in September 2006 determined it was time to move both groups to a new venue where the noise, jealousy, and concommitant confusion were lessened and a professional atmosphere could be restored.

I have established the new venues for both groups. As far as i am concerned, the founding venue for these groups has dissolved them and they are invalid there. It is gratifying that my pitiful part in the play revved up Manaster's site numbers to 50,000. Unfortunately, the personal and unwilling cost was greater than the benefit as there was none for me.

New Group Homes

The monthly networking meetings for the L.A. Metro group will continue both online and in person. They will continue to offer informational or educational content of or higher than that of the past. It is necessary to contact me in order to join.

The Ethics in Recruiting group has resituated itself and is striving to grow in the direction and purpose to which it was originally established. It has the appearance of suffering some malingering ailments of its past which I am striving to eradicate. Those who can walk in consonance with its purpose are invited to join and add to the discussions and goals.