• Effective Audit Committee Guide

The audit committee must establish procedures for the receipt, retention and treatment of complaints regarding accounting, internal accounting controls or auditing matters, including procedures for the confidential anonymous submission by employees of concerns regarding questionable accounting or auditing matters. This is one of the two provisions of Sarbanes-Oxley that is applicable to all organizations including nonprofits.

We recommend that audit committees adopt a formal “whistleblower policy” that includes the following:
  • Responsibilities of the audit committee
  • Procedures for receiving and investigating complaints
  • Policy for protecting whistleblowers
  • Confidentiality policies for whistleblowers
  • Policy for publication of whistle-blowing procedures

Organizations may consider an anonymous telephone hotline as a means for employees to report complaints.

For further information on assessing whistleblower policies and oversight, refer to BDO Consulting’s Fraud Prevention Program.



Andrea Espinola Wilson.
Andrea Wilson Managing Partner; Industry Specialty Services National Co-Leader, Nonprofit & Education Practice 703-752-2784
Adam Cole.
Adam Cole Managing Partner; Nonprofit & Education Advisory Practice National Co-Leader 212-885-8327
Laurie De Armond.
Laurie De Armond Assurance Office Managing Partner; Institute for Nonprofit Excellence Executive Director 703-336-1453
Marc Berger
Marc Berger National Director, Nonprofit Tax Services 703-336-1420
Lee Klumpp
Lee Klumpp National Professional Practice Partner – Nonprofit and Government Industries 703-336-1497
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