Sample Internal Controls Documentation

Sample_Documents

DISCLAIMER: This is a sample template provided for informational purposes only. It does not constitute legal, tax, or financial advice. Organizations should consult their own legal and tax advisors and tailor this document to reflect their specific business needs, geographies, and applicable laws.

Document Header

Document Metadata

Field	Value
Document Title	Internal Controls Documentation - <Company Name>
Document Type	Internal Controls Documentation
Category	Compliance & Governance
Version	<Version Number> (e.g., 1.0)
Effective Date	<Date> (e.g., 01 <Month> <Year>)
Next Review Date	<Date> (e.g., 01 <Month> <Year>)
Review Cycle	Annual, or upon material regulatory or process change
Document Owner	<Title/Name> (e.g., Head of Total Rewards)
Process Owner	<Title/Department> (e.g., Total Rewards Operations)
Approver(s)	<Title(s)/Committee> (e.g., CHRO; CFO; Compliance Committee)
Confidentiality	Internal - Confidential
Geographic Scope	<Country/Region/Global>
Systems Covered	<HRIS>, <Payroll System>, <Equity Platform>, <Benefits Admin System>

Version History

Version	Date	Author	Summary of Changes	Approver
0.1 (Draft)	<Date>	<Name>	Initial draft	<Approver Title>
0.9 (Review)	<Date>	<Name>	Added control register and testing plan	<Approver Title>
1.0 (Approved)	<Date>	<Name>	Finalized for publication	<Approver Title>

Purpose and Objectives

This Internal Controls Documentation establishes a standardized, risk-based control framework for the Total Rewards function at <Company Name>. It enables consistent compliance with applicable laws, accurate financial reporting, secure handling of employee data, and effective stewardship of compensation and benefits spend. It serves as a reference for process owners, auditors, and stakeholders.

Objectives include:

• Define control objectives, risks, and control activities for Total Rewards processes.
• Clarify roles, responsibilities, approvals, and segregation of duties.
• Establish documentation, evidence, and testing standards aligned to best practices (e.g., COSO principles).
• Ensure compliance with statutory, regulatory, and contractual obligations in <Country/Region> and other jurisdictions.
• Promote operational efficiency, data integrity, and a positive employee experience.
• Provide a basis for internal and external audits, including SOX/ICFR applicability where relevant.

Legal note: This document is intended for internal governance and does not alter terms of employment or benefits plan documents. In case of conflict, applicable law, plan documents, and employment agreements prevail.

Scope and Applicability

In Scope

• Base pay administration, job architecture, and salary structures
• Annual compensation cycles (merit, promotions, bonuses)
• Variable pay programs (short-term and long-term incentives)
• Equity compensation administration
• Benefits eligibility, enrollment, and vendor management
• Payroll-impacting Total Rewards transactions and interfaces
• Special payments (sign-on, retention, relocation, allowances)
• Leaves of absence pay continuation and statutory benefits integration
• Data privacy, access controls, and records retention related to Total Rewards
• Global mobility and assignment allowances where Total Rewards is accountable
• Financial reporting and reconciliations related to compensation and benefits
• Control monitoring, testing, and remediation

Out of Scope (for this document)

• Enterprise-wide IT General Controls (covered by <ITGC Policy Name>)
• Non-Total Rewards HR processes (e.g., talent acquisition sourcing steps, performance management content outside of pay decisions)
• Treasury operations unrelated to payroll funding
• Procurement and accounts payable processes not specific to benefits vendors
• Tax authority filings administered by <Tax Department> outside of payroll withholding

Applicability

• Applies to all employees, managers, and administrators who create, approve, or process Total Rewards data and transactions in <Company Name>.
• Applies globally unless local addenda supersede specific controls due to local law in <Country>.
• Applies to third-party vendors where services impact Total Rewards data or payments, per contractual obligations and SOC reporting.

Governance, Roles, and Responsibilities

Governance Structure

• Executive Sponsor: <CHRO/CFO> provides oversight and resources.
• Total Rewards Governance Committee: Reviews policy updates, risk assessments, and key control outcomes quarterly.
• Process Owners: Accountable for design and operating effectiveness of controls in their area.
• Control Operators: Perform control activities and retain evidence.
• Compliance and Internal Audit: Provide independent oversight and testing.
• Data Protection Officer: Provides guidance on privacy controls and data transfers.
• HRIS and Payroll: Manage system configurations, integrations, and SoD management.

Roles and Responsibilities Matrix (RACI Overview)

• Total Rewards COE: Responsible for control design; Accountable for compensation policy; Consulted by HRBPs; Informed stakeholders.
• HR Business Partners: Responsible for local execution and validation; Consulted on exceptions.
• Payroll: Responsible for payroll impact validation and funding reconciliations.
• Finance/Accounting: Responsible for accruals, expense recognition, and reconciliations; Approver for material payments.
• Legal/Compliance: Consulted for regulatory updates; Approver for plan documents and equity grants.
• IT/HRIS: Responsible for role-based access, change management, and report integrity.
• Vendors: Responsible for contracted controls; Provide SOC 1/SOC 2 reports and attestations.

Control Framework Overview

Principles

• Risk-based: Controls are prioritized based on impact and likelihood.
• Preventive first: Emphasize preventive controls (e.g., SoD, approvals) supported by detective controls (e.g., reconciliations).
• Documented and evidenced: Each control has clear procedures and contemporaneous evidence.
• Measurable: Define frequency, thresholds, and success criteria.
• Auditable: Evidence is retrievable, complete, and tamper-resistant.
• Scalable and global: Allow for local variations under a common framework.

Risk Assessment Approach

1. Identify inherent risks across Total Rewards processes (e.g., unauthorized pay changes, inaccurate bonus payouts, ineligible benefits coverage).
2. Map risks to controls, considering relevant regulations in <Country/Region>.
3. Determine key vs. non-key controls based on financial misstatement risk and regulatory exposure.
4. Define control owners, operators, and approvers with appropriate segregation of duties.
5. Calibrate frequency (e.g., per transaction, monthly, quarterly, annually) and sampling approach (e.g., <Percentage>).
6. Review risk assessment annually and when material changes occur (e.g., new system, plan redesign, acquisition).

Information and Communication

• Policies, procedures, and control descriptions are stored in <Repository/Location> with version control.
• Control calendars and certifications are communicated to owners monthly/quarterly.
• Change notices are issued at least <Number> business days prior to effective date.

Monitoring Activities

• First-line self-assessments and certifications by control owners.
• Second-line monitoring by Compliance, including sample-based testing (e.g., <Percentage>% of transactions or a minimum of <Number>).
• Third-line Internal Audit periodic audits, coordinated with SOX/ICFR if applicable.

Process-Level Controls for Total Rewards

Control Design Template (Use for Each Control)

• Control ID and Name
• Process and Subprocess
• Objective and Risk Statement
• Control Type (Preventive/Detective; Manual/Automated/IT-dependent)
• Frequency and Population
• Owner, Operator, and Approver (SoD)
• Procedure Steps
• Evidence Required (format, source system, retention period)
• System(s) and Report(s)
• Thresholds and Tolerances (e.g., <Amount>, <Percentage>)
• Exception Handling and Escalation Path
• Key vs. Non-Key; SOX relevance (Yes/No)
• Link to Procedure or Job Aid

Sample Control Register

Control ID	Process	Risk	Control Activity	Frequency	Owner/Approver	Evidence	System/Report	Key/SOX
TR-01	Base Pay and Job Architecture	Unauthorized or inaccurate pay rates due to role misclassification	Salary structure updates require dual approval by Head of TR and Finance; changes effective only after HRIS configuration approval	Quarterly, or as needed	Owner: Head of TR; Approver: Finance Controller	Approved change request, HRIS config ticket, effective date record	<HRIS> Change Request Report	Key/Yes
TR-02	Merit Cycle Administration	Over-budget merit increases and inequitable outcomes	Merit budgets set at <Percentage>% of base pay; system enforces caps; managers must justify exceptions above <Percentage>% with HRBP approval	Annual	Owner: Comp Program Manager; Approver: HRBP Lead	System audit log, exception approvals, budget vs. actual report	<Comp Planning Tool> Budget Report	Key/Yes
TR-03	Promotions	Promotions processed without approvals or outside guidelines	Promotion requests require documented business case and two-level approval (Manager and HRBP); pay increase limits of <Percentage>% unless CHRO approves	Ongoing	Owner: HRBP; Approver: CHRO for exceptions	Promotion form, approval workflow record, pay change audit log	<HRIS> Workflow Audit	Key/No
TR-04	Off-Cycle Pay Adjustments	Unauthorized lump sums or pay adjustments	Off-cycle payments over <Amount> require TR and Finance approval; payroll validates against approved list prior to processing	Per payroll cycle	Owner: TR Ops; Approver: Payroll Manager	Approved payment file, signed control checklist, payroll variance report	<Payroll System> Pre-Processing Report	Key/Yes
TR-05	Short-Term Incentive Payout	Incorrect bonus calculation and payment	Bonus formula tested by TR; Finance validates pool; CFO approves final payout file; payroll ties out totals to funding	Annual	Owner: TR Analytics; Approver: CFO	Model validation memo, approved pool, CFO sign-off, payroll reconciliation	<TR Model>, <Payroll> Funding Report	Key/Yes
TR-06	Equity Grants	Non-compliant equity awards or misstatements	Board-approved grant guidelines enforced; grant list reconciled to HRIS headcount; participant eligibility validated; withholding rates verified by Tax	Quarterly grants; annual refresh	Owner: Equity Admin; Approver: Legal/Board	Board minutes, grant file, eligibility audit, tax withholding memo	<Equity Platform> Grant Report	Key/Yes
TR-07	Benefits Eligibility	Ineligible enrollments or missed coverage	Automated eligibility rules; weekly exception report reviewed; retroactive corrections limited to <Number> days	Weekly	Owner: Benefits Ops; Approver: Benefits Manager	Exception review log, corrected records, vendor file acknowledgment	<Benefits Admin> Eligibility Exceptions	Key/No
TR-08	Vendor Invoice Reconciliation	Overpayment to benefits vendor	Vendor invoices matched to enrollment counts and rates; variances over <Percentage>% escalated to Finance	Monthly	Owner: Benefits Finance; Approver: AP Manager	Reconciliation workbook, vendor invoice, variance explanation	<Vendor Portal> Invoice; <Data Warehouse> Enrollment Extract	Key/Yes
TR-09	Payroll Interface	Data transfer failures or duplicates	HRIS-to-payroll interface uses control totals; payroll rejects if totals mismatch by <Amount> or <Percentage>%	Per payroll cycle	Owner: HRIS Integrations; Approver: Payroll	Interface control total report, reject log, re-run documentation	<HRIS> Outbound; <Payroll> Inbound Control	Key/Yes
TR-10	Data Access Management	Excessive access to sensitive TR data	Quarterly access review; SoD matrix prohibits same user from creating and approving pay changes	Quarterly	Owner: HRIS Security; Approver: TR Director	Access review attestation, SoD exception log and mitigation plan	<HRIS> Access Report	Key/Yes
TR-11	Global Mobility Allowances	Incorrect allowances or tax gross-ups	Standard packages with predefined ranges; Tax review of gross-up rates; approvals required for exceptions	Ongoing	Owner: Mobility; Approver: Tax and TR	Package template, tax memo, approval record	<Mobility Tool> Case Record	Non-Key/No
TR-12	Accruals for Incentives	Under/over accrual of bonus expense	Monthly accrual model reviewed by Finance; variances over <Percentage>% investigated; sign-off documented	Monthly	Owner: Finance FP&A; Approver: Controller	Accrual model, variance analysis, sign-off	<Finance System> Accrual Ledger	Key/Yes

Control Operating Procedures (Selected Examples)

TR-02 Merit Cycle Administration

• Objective: Ensure merit increases align with budget and comply with pay equity and governance standards.
• Steps:

1. Upload approved budget percentages and ranges into <Comp Planning Tool> for each business unit.
2. Lock eligibility snapshot as of <Date>; retain immutable copy.
3. Enable system rules to cap total spend at <Percentage>% and individual increases at <Percentage>% unless exception approved.
4. HRBPs review outliers using calibration reports; document rationales.
5. TR comp team runs variance report; Finance validates total versus approved pool.
6. Approver signs off; TR releases final file to payroll with control totals and effective dates.

• Evidence: Signed approval, system configuration screenshots, variance and outlier reports, payroll file with control totals.
• Exception Handling: If budgets exceed approved caps, halt release, obtain CFO or CHRO approval, and update approval log.

TR-05 Short-Term Incentive Payout

• Objective: Accurate calculation and authorized payment of bonuses.
• Steps:

1. Lock final performance ratings and eligible earnings as of <Date>.
2. Validate plan rules, proration logic, and threshold multipliers against plan document.
3. Perform independent recalculation on a <Percentage>% sample and at least <Number> high-risk cases.
4. Finance validates total payout pool against accrual; Tax confirms withholding matrices for <Country>.
5. Obtain CFO approval; submit payment file to payroll with control totals by cost center.
6. Payroll confirms totals and verifies funding; post-payment reconciliation performed.

• Evidence: Calculation model, testing results, approval memo, payroll confirmation, reconciliation.
• Exception Handling: Correct and document discovered errors; if systemic, delay payment and issue employee communication.

TR-09 Payroll Interface

• Objective: Complete and accurate transmission of TR data from HRIS to payroll.
• Steps:

1. Generate outbound file; record employee and transaction counts and total gross amounts.
2. Validate no duplicate transactions; run data integrity checks (e.g., negative pay flags).
3. Transmit via secure channel; payroll system ingests and compares control totals.
4. If variance exceeds <Amount> or <Percentage>%, reject and reconcile before payroll close.
5. Log run ID, operator, timestamps; attach error and resolution notes.

• Evidence: Control total report, reject log, re-run confirmation.
• Exception Handling: Escalate unresolved variances to HRIS lead and Payroll Manager; document root cause and corrective action.

Implementation and Operating Guidelines

Control Design Standards

• Write risks as cause-event-impact statements.
• Align control type to risk (preventive before detective).
• Define precise frequency and population; avoid ambiguous terms like “periodically.”
• Establish measurable thresholds (e.g., variances over <Percentage>% or <Amount>).
• Ensure SoD: creator, reviewer, and approver should be different roles wherever feasible.

Documentation and Evidence Retention

• Evidence must be contemporaneous, complete, and stored in <Repository> with immutable timestamps.
• Minimum retention: <Number> years or statutory requirement, whichever is longer.
• Naming conventions: <Control ID>_<YYYYMMDD>_<RunID>.
• Acceptable formats: system reports, screenshots with metadata, signed PDFs, system workflow logs.

Access Management

• Role-based access with least privilege for TR, HRIS, Payroll, Finance, and Vendors.
• Quarterly reviews require owner attestation; remediate SoD conflicts within <Number> days.
• New access requires approval from manager and data owner; removal within <Number> hours of termination.

Report Integrity and Calculations

• Maintain report inventory with owner, definition, filters, and refresh cadence.
• Validate critical reports at least annually or upon system updates.
• For spreadsheets used in key controls, implement version control and peer review; lock formulas and protect cells.

Vendor Management Controls

• Require SOC 1 Type II or SOC 2 reports from <Vendor Name>; review exceptions and management responses.
• Validate eligibility and enrollment files; reconcile invoices to headcount and rates.
• Include right-to-audit and data protection obligations in contracts; require breach notification within <Number> hours.

Payroll Impact Controls

• Use pre- and post-payroll reconciliations; investigate net-to-gross variances over <Percentage>%.
• Validate funding requests to approved payment files before transmission to bank.
• Coordinate cutoffs; establish blackout periods during payroll calculation windows.

Equity Administration

• Ensure grants comply with plan documents and local securities/tax rules in <Country>.
• Confirm fair value and expense accounting with Finance; reconcile to GL monthly.
• Validate tax withholding and reporting (e.g., ISO/NSO in <Country>).

Global and Local Considerations

• Document local deviations in addenda with a rationale and legal reference.
• Apply currency conversion rules; fix effective dating to local payroll cycles.

Exception Management and Escalation

1. Identify exception and classify severity (Low/Medium/High).
2. Notify process owner and approver within <Number> business hours.
3. Contain and correct the issue; determine root cause using a standard method.
4. Document remediation plan with due dates and accountable owner.
5. Confirm closure and perform targeted re-testing.

Change Management

• Changes to compensation plans, eligibility rules, or system configurations require impact assessment and approvals.
• Maintain a change log with effective dates, approvals, and rollback plans.
• For system changes, follow <IT Change Policy> including testing in non-production and user acceptance sign-off.

Control Testing and Certification

• Control owners self-assess quarterly; certify operation and attach evidence.
• Compliance performs sample-based testing with defined error rates (e.g., tolerable deviation rate of <Percentage>%).
• Failures above threshold require remediation and possible re-performance of the control.

Review, Testing, and Approval Process

Annual Review and Update

1. Conduct annual risk assessment considering organizational changes, audit findings, regulatory updates in <Country/Region>.
2. Update control descriptions, thresholds, and ownership as needed.
3. Obtain approvals from TR Governance Committee and <Approver Titles>.
4. Publish updated version and communicate changes to control operators at least <Number> days before effective date.

Ongoing Monitoring and Reporting

• Monthly: Control performance dashboard provided to TR leadership, including status, upcoming certifications, and past due items.
• Quarterly: Access reviews; key metrics (e.g., exception rates, processing times, error rates).
• Annually: Plan design and system configuration validation; data privacy impact assessment for changes involving personal data.

Audit Coordination

• Maintain an audit-ready evidence library; respond to requests within agreed timelines.
• For SOX scope, coordinate key control walkthroughs and re-performance with Internal Audit.
• Track findings and remediation in <Issue Tracker> with due dates and accountable owners.

Approval Workflow

1. Process Owner drafts changes and impact assessment.
2. Legal/Compliance review for regulatory implications.
3. Finance review for financial reporting impacts.
4. Governance Committee approval.
5. Executive Sponsor final sign-off for material changes.

Data Privacy, Security, and Records Management

Privacy-by-Design Principles

• Limit collection to necessary data for compensation and benefits administration.
• Use data minimization in reports and files; mask identifiers where possible.
• Conduct Data Protection Impact Assessments for new programs or vendors processing sensitive data.

Security Controls

• Encrypt data in transit and at rest per <Security Standard>.
• Enforce multi-factor authentication for privileged users.
• Segregate production and non-production data; prohibit real PII in test environments unless tokenized.

Records Retention

• Retain payroll-impacting control evidence for at least <Number> years.
• Retain plan documents and approvals for at least <Number> years after plan termination.
• Follow country-specific retention requirements and destruction protocols in <Country>.

Legal and Regulatory Considerations

• Comply with wage and hour laws, equal pay, benefits mandates, and recognized accounting standards in <Country>.
• For equity, adhere to securities, tax withholding, and reporting obligations in relevant jurisdictions.
• Coordinate with Tax on year-end reporting (e.g., <Form Name> equivalents).

Risk and Control Mapping Summary

Primary Risks Addressed

• Unauthorized or inaccurate pay changes
• Budget overruns and inequitable pay outcomes
• Ineligible benefits enrollment and vendor overpayments
• Data privacy breaches and access abuses
• Payroll interface failures and funding discrepancies
• Misstated compensation and benefits expenses
• Non-compliance with local regulations in <Country/Region>

Key Control Themes

• Preventive approvals and SoD
• System-enforced rules and thresholds
• Reconciliations and variance analytics
• Evidence-based certifications and audits
• Vendor assurance and contract controls
• Access and change management discipline

Roles and Responsibilities Details

Total Rewards Center of Excellence

• Owns compensation and benefits control frameworks.
• Designs plan rules, budgets, and governance documents.
• Partners with Finance on accruals and with Legal on compliance.

HR Business Partners and HR Operations

• Execute local processes, ensure documentation completeness, and coach managers on compliance.
• Validate eligibility and business rationale for changes.

Payroll and HRIS

• Operate interfaces, reconciliations, and payroll validations.
• Manage access provisioning, SoD, and change tickets.

Finance and Accounting

• Validate budget adherence, approve significant payments, and perform reconciliations and accruals.

Legal, Compliance, and Internal Audit

• Provide regulatory guidance, monitor control performance, and conduct independent testing.

Vendors and Third Parties

• Meet contracted control standards and provide attestations; notify of incidents within <Number> hours.

Key Metrics and Reporting

Control Performance Indicators

• Merit cycle exception rate: target <Percentage>% or lower
• Off-cycle payment accuracy: target <Percentage>% or higher
• Vendor invoice variance: not to exceed <Percentage>%
• Access review completion: 100% by due date
• Payroll interface success rate: ><Percentage>% with no high-severity errors

Management Reporting Cadence

• Monthly TR control dashboard to TR leadership and Finance
• Quarterly compliance report to Governance Committee
• Annual attestation to Audit Committee for SOX-relevant areas

Appendices and Tools

Control Evidence Checklist (Generic)

• Control description and ID on the evidence file
• Date/time and operator name
• Source system and report parameters
• Population and sample size, if applicable
• Approver signature or system approval record
• Exception log and resolution notes

Sampling Guidance (Illustrative)

1. For high-frequency controls, test a random sample of <Number> items or <Percentage>% of the population, whichever is greater.
2. For low-frequency controls, perform re-performance on 100% of occurrences within the period.
3. Stratify samples to include high-risk transactions (e.g., large payments, executive changes).

Glossary of Terms and Definitions

• Accrual: Estimated expense recognized for compensation programs before payment occurs.
• Control Owner: Person accountable for the design and performance of a control.
• Control Operator: Person performing the control steps and collecting evidence.
• Control Total: Aggregated count and amount used to validate data transfers.
• ICFR: Internal Control over Financial Reporting, including SOX scope where applicable.
• Key Control: Control that prevents or detects a material misstatement or major compliance breach.
• Merit Cycle: Annual process to adjust base pay based on performance and market factors.
• Preventive Control: Control designed to stop an error or unauthorized action before it occurs.
• Detective Control: Control designed to identify errors or unauthorized actions after they occur.
• Segregation of Duties (SoD): Separation of responsibilities to prevent conflicts of interest and fraud.
• SOC Report: Service Organization Control report provided by vendors as assurance over their controls.
• Total Rewards: Compensation and benefits programs including pay, bonuses, equity, and benefits.
• Variance Analysis: Review of differences between expected and actual amounts to identify errors or trends.

Communication to Employees and Managers

At <Company Name>, your pay and benefits are managed with care, accuracy, and respect for your personal data. This section explains, in plain language, how our controls work behind the scenes and what you can expect during common events like raises, bonuses, and benefits enrollment.

When you receive a salary change or bonus, several checks ensure it is correct and authorized. Your manager proposes changes within our guidelines, HR reviews them, and the system applies plan rules to prevent mistakes. For example, if an increase would push a team over the approved budget, the system flags it for review. Before payments are released to payroll, totals are validated to match approved amounts. These steps help us pay you correctly and on time.

During the annual merit and bonus cycles, we freeze data on a specific date so we all work from the same information. We review outliers to make sure decisions are fair and consistent with performance. If a correction is needed, we document the change and ensure the right people approve it before anything affects your paycheck.

Your benefits eligibility is also checked automatically. If something looks off, such as an enrollment that does not match your hours or work status, our benefits team reviews and corrects it. Each month, we reconcile what we pay to benefits vendors with who is actually enrolled, to avoid over- or under-payments that could affect your coverage.

Your privacy matters. Only authorized people can see or change your pay and benefits information. We review access regularly, and we remove access promptly when roles change. We also use secure systems and encrypted connections when sending data to payroll or benefits partners. Our vendors agree to strict privacy and security standards and must notify us quickly if there is ever a concern.

If you spot an issue—like a pay change you do not recognize, a bonus amount that seems wrong, or a benefits enrollment problem—please contact <HR Support Contact> right away. We will investigate promptly. We may ask for documents such as a pay stub or a confirmation email so we can track down the source of the problem and correct it quickly. You will receive a follow-up explaining what we found and what we did to resolve it.

Here are a few practical tips:

• Keep your personal details up to date in <HRIS Self-Service> so we can calculate pay and benefits correctly.
• During merit and bonus cycles, watch for communications from your manager and HR about timing and expectations.
• Save your payroll statements and benefits confirmations; they are helpful if questions arise.
• If you are going on a leave of absence, notify <Leave Administration Contact> as early as possible so we can coordinate pay continuation and benefits.

We want these processes to be smooth for you. Controls are not about making things complicated; they are about getting things right. They help ensure fairness across teams, protect your information, and keep us compliant with laws in <Country/Region>. If you have questions, reach out to your HR Business Partner or <HR Support Contact>. We are here to help.

Legal reminder: In case of any differences between this overview and your employment agreement, plan documents, or local laws, those documents and laws control. Our goal is to be transparent about how we administer programs while following the rules that apply to <Company Name>.

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Document Information:

• Document Type: Internal Controls Documentation
• Category: Compliance & Governance
• Generated: August 28, 2025
• Status: Sample Template
• Next Review: <Insert Review Date>

Usage Instructions:

1. Replace all text in angle brackets < > with your company-specific information
2. Review all sections for applicability to your organization
3. Customize content to reflect your company's policies and local regulations
4. Have legal and HR leadership review before implementation
5. Update document header with your company's version control information
6. At bottom of the document you find a short example on how the content could be communicated to end-users, for instance employees.

This sample document is provided for reference only and should be customized to meet your organization's specific needs and local legal requirements.