Finance Ethics
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Report your integrity posture every year

A short annual report on governance, controls and speak-up, with every figure traced to a record.

Start a conversationSee the Integrity Center
Part of
Transparency Consulting
Runs as
4 stages, from scope the disclosure to publish and hand over
You receive
5 deliverables, listed below
Pricing
Quoted after a scoping call

Good governance stays invisible by default

Organizations that run disciplined finance functions rarely say so in a form an outsider can check. The audit opinion covers the financial statements, not how payments are approved or how a concern raised in March was handled. Board minutes are private. The code of conduct sits on the website with no date on it.

So funders, lenders, bank partners and prospective buyers fill the gap with questionnaires, calls and assumptions. A Financial Integrity Report answers the recurring questions once a year, in one document, with each statement tied to evidence and each commitment carried forward until it is met or explained.

Engraving of an open book whose pages become a building facade of lit windows, one in magenta.
A report you can look through.

The report covers six areas

  • Governance and oversight

    Who oversees financial integrity, which committee meets on it and how often, and how authority to approve spending and release payments is delegated.

  • Controls posture

    Management's description of the key controls over cash, payments, payroll and the close, with known gaps and their remediation status stated plainly.

  • Speak-up and concerns

    How concerns can be raised, who receives them, and statistics on reports, categories and time to close, in ranges you choose to disclose.

  • Independence of reviewers

    Who prepared each section, who reviewed it, what relationships the reviewers have with the organization, and what kind of review it was.

  • Commitments and progress

    Last year's commitments with a status of met, in progress or withdrawn, the reason for any that slipped, and new commitments with dates.

  • Basis of preparation

    The period covered, entities included, definitions used and the source of each figure, with references to GRI or ISSB concepts where you adopt them.

You get a publishable report

DeliverableWhat it isWhen
Disclosure planAgreed outline, audience list, disclosure ranges and the records that will support each sectionWeek 2
Evidence fileIndex linking every statement and figure in the report to its source record, kept by you for follow-up questionsWeek 7
Draft reportFull draft in plain language, short enough to read in one sitting, checked by a second reviewer who did no fieldworkWeek 10
Final report and summaryDesigned PDF and web version, plus a one-page summary for your board, funders or websiteWeek 12
Next-year trackerSpreadsheet of commitments, owners and data sources, so next year's report starts from a maintained recordWeek 12

Twelve weeks from outline to publication

  1. Weeks 1 to 2

    Scope the disclosure

    We agree the audience, the period, the entities in scope and the ranges you are willing to disclose, such as the number of speak-up reports in bands of five.

  2. Weeks 3 to 7

    Gather and test evidence

    We collect board and committee records, policies, the speak-up log and control evidence, and test the key statements against the ledger and system access data.

  3. Weeks 8 to 10

    Draft and review

    We draft each section, management corrects and approves it, and a second reviewer checks that every statement still matches the evidence file.

  4. Weeks 11 to 12

    Publish and hand over

    We produce the final formats, brief the people who will answer questions about the report, and hand over the tracker for next year.

Your team supplies the records

  • Board and committee minutes, charters and the delegation-of-authority matrix for the period
  • Current policies with their approval dates, including the code of conduct and the speak-up policy
  • The speak-up or hotline log, anonymized, with categories, dates opened and dates closed
  • Read-only access to the accounting system, or exports we specify, for testing statements about approvals and payments
  • Audit management letters, prior assessments and any open remediation plans
  • A named executive sponsor who approves each section, with roughly half a day a month across the project

Is this the right fit?

A good fit

  • Private companies that want to show lenders, buyers or bank partners how money is governed, without any legal duty to do so
  • Nonprofits whose foundation or government funders ask about oversight, conflicts and speak-up
  • Private-equity portfolio companies reporting on governance to a sponsor and lenders
  • Organizations that already publish an impact or sustainability report and want a governance section that holds up

Not the right fit

  • Organizations that need an audited or assured report; we do not perform audits or attest engagements, though we can prepare you for an assurance provider
  • Situations where the facts are not yet settled, such as an open investigation, and the aim is reputation management

Commitments carry forward until closed

The section readers return to is the commitments table. Each commitment is written so that a reader can tell whether it happened. "By 30 June, every vendor bank change is confirmed by a call to a number already on file" qualifies. "Strengthen payment controls" does not. The next report lists the same commitment again with a status. It can be met, still in progress with a new date, or withdrawn with a reason. It cannot quietly disappear.

Controls sections name real limits

Management describes the controls that matter most and is specific about them: payments over $10,000 need two approvers in the bank portal, manual journal entries are reviewed by the controller within five business days, user access is reviewed every quarter. Where a control is new or a gap remains, the report says so and gives the date it will be fixed.

We test these statements before publication. If the stated rule is two approvers but the bank portal shows one user releasing payments alone, either the statement changes or the control does. If the controls themselves have never been examined, a Controls Health Check is a sensible first step before you write about them.

Every figure has a source

Every number in the report appears in the evidence file with its source: the hotline log export, the user-access listing, the board attendance record. Figures that rest on judgment, such as which reports were substantiated, carry a short note on how the judgment was made. Where a figure would mislead on its own, such as zero speak-up reports from a channel launched in November, the report gives the context rather than presenting the number as good news.

It answers the recurring questions once

A board uses the report to see a year of governance in one place. A foundation reads it alongside a grant application. A lender or bank partner files it with its periodic review. A buyer finds it in the data room and starts from a documented position rather than a blank questionnaire.

If you want the same information kept current between reports, the Integrity Center publishes it on your own site and updates it by subscription. For the case for disclosing at all when no law requires it, see voluntary financial transparency for private companies.

What people ask before hiring us

Do we have to publish it?

No. Some organizations post the report on their website, others share it only with their board, funders or lenders. The content is written so either choice works, and the disclosure plan in week 2 settles which sections are public.

Why disclose speak-up statistics in ranges?

Exact counts from a small organization can identify the people involved. Ranges you set in advance, such as 0 to 5 or 6 to 10 reports, show that the channel is used and that cases are closed, without exposing individuals. You choose the ranges and can widen them for any category.

Is this the same as a GRI or ISSB report?

No. It is a voluntary report focused on financial integrity, not a full sustainability report. Where it helps comparability we draw on GRI concepts, such as disclosure 2-26 on mechanisms for seeking advice and raising concerns, and on the ISSB structure of governance, strategy, risk management, and metrics and targets. The basis of preparation says which concepts were used.

What does the independence section say about Finance Ethics?

It states our role, that we are not your auditor and did not perform an attest engagement, that we receive no fees beyond the agreed engagement fee, and that a second reviewer who did no fieldwork checked the report. If we have any relationship with a vendor named in the report, we disclose it there.

Also in Transparency Consulting

Help deciding what to disclose about financial integrity, then building the reports, public pages and questionnaire answers that prove it.

  • Integrity Center

    A public page on your own domain that shows how your organization governs money, with dated policies, management's control attestations and a change log, kept current by subscription.

  • Supplier Disclosure Readiness

    A reusable, evidenced answer library for the integrity and sustainability questionnaires large customers send, sized to what those customers can actually require.

Related work and reading

Services

  • Code of Conduct & Speak-Up Programs

    An eight-to-twelve-week project that redesigns your code of conduct and builds the reporting channel, triage, investigation protocol and anti-retaliation process behind it.

  • Board & Governance Review

    A three-to-four-week diagnostic of who holds authority, how conflicts and related parties are handled, what the board reads and how its decisions are recorded.

Articles and scenarios

Sectors

Tell us what you are seeing

A first conversation is a scoping call: what worries you, what you need to show, and to whom. You leave it with a view on where to start, whether or not you hire us.

Start a conversation
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HoursMonday to Friday, 9:00 to 17:00 Mountain Time