Are there any Sarbanes-Oxley provisions with which private companies and nonprofits are required to comply?
Busis: Yes. Certain Sarbanes-Oxley provisions – for example, those dealing with document destruction and whistleblower protection – apply to all organizations, not just public companies. Sarbanes-Oxley makes it a crime to knowingly destroy, conceal or falsify records with the intent to impede or obstruct a federal investigation. In addition, Sarbanes-Oxley protects the rights of a whistleblower to report wrongdoing to federal investigators without the risk of retaliation. As a result, private companies and nonprofits should review their document retention policies and policies that encourage people to report potential wrongdoing. Organizations without document retention and whistleblowing policies should be creating them, and those with such policies in place must enforce them. Question: What direct actions should private companies and nonprofits undertake to demonstrate their commitment to Sarbanes-Oxley’s principles? Haas: Private companies and nonprofits can demonstrate their corpor