Sarbanes Oxley Matrix

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Records and Information Management SARBANES-OXLEY ACT Review/Analysisas of 9-18-2002

Guide to Sarbanes-Oxley Act

NOTES

Green highlight represents Registered Public

Accounting firm responsibilities

Orange highlight represents corporate

responsibilities that may be outsourced.

SUMMARY STATEMENT STUDY REPORTS RULES RECORDS RESPONSIBILITY CREATION MNTNC RETENTION

TITLE I PUBLIC COMPANY ACCOUNT

OVERSIGHT BOARD

Sec. 103

Rules required: Board will establish rules

regarding: X BOARD

1. Audit papers prepared and maintained X RPA X X 7 YRS

2. 7 yrs RPA X

3. sufficient detail to support conclusions RPA X

4. concurring/second partner review and approval RPA X

5. scope of testing of internal control structure and

procedures RPA X

6. findings of the auditor RPA X

7. Evaluation: of maintenance of records

accurately and fairly reflect the transactions and

dispositions of the assets of the issuer; provide

reasonable assurance that transactions are

recorded as necessary to permit preparation of

financial statements in accordance with generally

accepted accounting principles, and that receipts

and expenditures of the issuer are being made only

in accordance with authorizations of management

and directors of the issuer; description of material

weaknesses and material noncompliance on thebasis of such testing RPA X

Sec. 104

Responsibility designation codes include: Board or COMM=SEC Commission and/or Board; RPA=Registered Public Accounting Firm; Issuer=

Only the text that deals with the creation, maintenance, or retention of documents and information is included. The documents/records are ide

record documenting evidence of action. The text may or may not be exact text from the Act.

Yellow highlight represents Corporate responsibilities

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Board will conduct continuing program of

inspections for registered public accounting firms

that prepare audit reports for more than 100

issuers. BOARD

1. Once every 3 years BOARD X2. Identify any act or practice or omission to act BOARD X

3. Report any such act, practice or omission X BOARD X

4. Formal investigation or take disciplinary action BOARD X

engagements BOARD

6. Perform such other testing of the audit BOARD X7. Require retention of records not otherwise

required by section 103 RPA X

Board will prepare written report X BOARD

1. Transmitted to Commission BOARD

2. Appropriate detail BOARD3. Available in appropriate detail to the public BOARD

Sec. 105Board may require BOARD

1. Production of audit work papers and any other

document or information in the possession of the

registered public accounting firm or any associated

person thereof; may inspect the books and records

of such firms or associated persons X RPA X

2. Production of any document in the possession of

any other person, including any client of aregistered public accounting firm that the board

considers relevant or material to an investigation

under this section. X RPA

3. Provide for procedures to seek issuance of

subpoena to require testimony of and production of

any document in the possession of any person . .

relevant or material to an investigation under this

section. X* BOARD

Boards review shall be confidential and privileged

as an evidentiary matter. BOARD

Board will keep a record of the proceedings for any

hearing. X BOARD X

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Board sanctions will be supported by a statement

setting forth: X BOARD X

part of such sanction

No associated person of a registered public

accounting firm shall be deemed to have failed

reasonably to supervise any other person for

purposes of subparagraph A if:

procedures, and a system for applying such

procedures

If the Board imposes a disciplinary sanction, the

report shall include: X BOARD X

X

imposition X

X

Sec. 106This act is applicable to foreign public accounting

firms X RPA X X X

and furnishing of such reports

Sec. 107

Commission shall approve a proposed rule if it is

consistent with the requirements of this Act. X COMM

The Board shall promptly file notice with the

Commission of any final sanction on any registered

public accounting firm or . . any associated person

thereof. X NOTICE BOARD X

Sec. 108

The Commission may recognize any accounting

principles established by a standard setting body X* X COMM

interest



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consideration by majority vote of its members

and of high quality

the public containing audited financial statements of

that standard setting body X STANDARDS ORG X

Study on Principles-Based Accounting X 1 YR COMM X

TITLE II AUDITOR INDEPENDENCE

Sec. 201

Registered public accounting firm will not provide

any non-audit service including: X RPA

implementation

or contribution-in-kind reports

investment banking services

the audit

Sec. 202

Audit committees must pre-approve any auditing

and non-auditing services other than the

exemptions approved by the Board in subparagraph

B X AUDIT COMMITTEE

Preapproval is waived X AUDIT COMMITTEE

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total revenues paid by the issuer during the fiscal

year X AUDIT COMMITTEE

X AUDIT COMMITTEE

the audit committee of the issuer and approved

prior to the completion of the audit X AUDIT COMMITTEE

Sec. 203

A registered public accounting firm shall not provide

audit services to an issuer x RPA

primary responsibility or review responsibility has

performed audit services for the issuer in each of

the 5 previous fiscal years of that issuer

Sec. 204

Registered public accounting firm shall provide a

timely report to the audit committee X RPA X

used X

. . discussed with management X

and the management of the issuer X

Sec. 206

A registered public accounting firm cannot perform

any audit service for an issuer if the CEO,

controller, CFO, chief accounting officer, or any

person serving in an equivalent position for the

issuer, was employed by that registered

independent public accounting firm; and

participated in any capacity in the audit of that

issuer during the 1 year period preceding the date

of the initiation of the audit. X RPA

Sec. 207

Study required regarding mandatory rotation of

registered public accounting firms. X 1 YRCOMPTROLLER

GENERAL US


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Not later than 1 year after date of enactment of this

Act.

TITLE III CORPORATE RESPONSIBILITY

Sec. 301

Commission shall by rule prohibit the listing of anysecurity of an issuer that is not in compliance with

the requirements of any portion of paragraphs 2

through6X 230

DAYS COMM

Audit committee of each issuer shall be directly

responsible for the appointment, compensation,

and oversight of the work of any registered public

accounting firm employed by that issuer for the

purpose of preparing or issuing an audit report or

related work, and each such registered public

accounting firm shall report directly to the auditcommittee.

X 230DAYS AUDIT COMMITTEE

Audit committee members:X 230

DAYS ISSUER BD

issuer

compensatory fee from the issuer

subsidiary thereof

Audit Committee shall establish procedures X AUDIT COMMITTEE X

received by the issuer regarding accounting,

internal accounting controls, or auditing matters X ISSUER X

employees of the issuer of concerns regarding

questionable accounting or auditing matters X ISSUER X

Audit committee shall have the authority to engage

independent counsel and other advisers, as it

determines necessary to carry out its duties X AUDIT COMMITTEE


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SUMMARY STATEMENT STUDY REPORTS RULES RECORDS RESPONSIBILITY CREATION MNTNC RETENTIONas determined by the audit committee, in its

capacity as a committee of the board of directors,

for payment of compensation

X

FUNDIN

G ISSUER

Sec. 302

Each company filing periodic reports is required

the principal financial officer or officers, or persons

performing similar functions, certify in each annual

or quarterly report filed or submitted that:

X ISSUER

contain any untrue statement of a material fact X X ISSUER/ CEO X

financial condition and results of operation

The signing officers

internal controls X X ISSUER/ CEO X X

that material information relating to the issuer and

its consolidated subsidiaries is made known to such

officers by others within those entities X ISSUER/ CEO

controls with 90 days X ISSUER/ CEO X

effectiveness of their internal controls X ISSUER/ CEO X

audit committee X ISSUER/ CEO X

operation of internal controls X ISSUER/ CEO X


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management or other employees who have a

significant role in the issuers internal controls X ISSUER/ CEO

were significant changes in internal controls or any

corrective actions with regard to significant

deficiencies and material weaknesses X X ISSUER/ CEO X

Issuer cannot lessen the legal force of the

statement by having reincorporated or having

engaged in any other transaction that resulted in the

transfer of the corporate domicile or offices of the

issuer from inside the United States to outside of

the United States. X ISSUER

Sec. 303

Any officer or director of an issuer is prohibited from

any action to fraudulently influence, coerce,

manipulate, or mislead any independent public or

certified accountant engaged in the performance of

an audit of the financial statements of that issuer. X ISSUER

Sec. 304

When an issuer is required to prepare an

accounting restatement due to material

noncompliance, the CEO and CFO shall reimburse

the issuer for X ISSUER

based compensation received during the 12-month

period following the first public issuance or filing

with the Commission X ISSUER

the issuer during that 12-month period X ISSUER

Sec. 306

Any director or executive officer of an issuer cannot



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acquire or transfer any equity security of the issuer

(other than an exempted security) during any

blackout period if the director or officer acquires

such equity security in connection with his or her

service or employment as a director or executive

officer. X ISSUER

issuer X ISSUER

Plan Administrator shall notify in writing (electronic

or other form that is reasonably accessible to the

recipient X X

PLAN

ADMINISTRATOR X

X X PA X

rights affected X X PA X

blackout period X X PA X

evaluate the appropriateness of their current

investment decisions in light of their inability to

direct or diversity assets credited during theblackout X X PA X

Sec. 307

Rules required (within 180 days) for minimum

standards of professional conduct for attorneys

appearing and practicing before the Commission in

any way in the representation of issuers including:X 180

DAYS COMM X

violation of securities law or breach of fiduciary duty X LEGAL X

/ / ( )


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committee of the board of directors of the issuer or

to another committee X LEGAL X

Sec. 308

Study required: X COMM

5 years to identify areas were such proceedings

may be utilized to efficiently, effectively, and fairly

provide restitution for injured investors

penalties and disgorgements

House and Committee on Banking, Housing, and

Urban Affairs of the Senate within 180 days X 180 DAYS COMM

TITLE IV ENHANCED FINANCIAL

DISCLOSURES

Sec. 401

Financial reports submitted to the commission shall

reflect all material correcting adjustments.

Rules required: not later than 180 daysX 180

DAYS COMM

balance sheet transactions, arrangements,

obligations etc. X ISSUER

presented in a manner that X ISSUER

material fact or omit to state a material fact X ISSUER

X ISSUER

results of operations of the issuer under GAAP X ISSUER

Study required: not later than 1 year X 1 YR COMM

Study of filings to determine

reflecting the economics of such transactions


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Report: not later than 6 months after the study to

the President, Committee on Banking, Housing and

Urban Affairs of the Senate, and the Committee on

Financial Services X 6 MOS X COMM X

transactions including assets, liabilities, leases, and

losses of , and the use of special purpose entities X COMM X

to facilitate off-balance sheet transactions X COMM X

issuers reflecting the economics of such

transactions to investors X COMM X

special purpose entities sponsored by an issuer

where issuer has the majority of the risks and

rewards X COMM X

and quality of reporting off-balance sheet

transactions X COMM X

Sec. 402

It is unlawful to directly or indirectly extend or

maintain credit, to arrange for credit or to renew an

extension of credit in the form of a personal loan toor for any director or executive officer of that issuer.

Limitations include various vehicles to allow the

employee to transact business that is in the ordinary

course of business, generally made available to the

public, or made on market terms. X X ISSUER X

Sec. 403

Any beneficial owner of more than 10 percent of

any class of any equity security shall file the

statements required by this subsection: X 10 DAYS BENEFICIAL OWNER X

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securities

date

commission will provide the statements on a

publicly accessible internet site not later than the

end of the business day following the filing.

corporate website not later than the end of the

business day following that filing. X ISSUER

CORP

WEB

SITE

Sec. 404

Rules required:

X180

days COMM

of management for establishing and maintaining an

adequate internal control structure and procedures

for reporting X ISSUER

of the internal control structure and procedures of

the issuer for financial reporting

made by the management of the issuer.

Internal controls assessment: each RPA shallattest to, report on the assessment made by the

management of the issuer. x RPA x

Sec. 405

Exemptions to investment companies registered

under Section 8 of the Investment Company Act of

1940 XINVESTMENT

COMPANIES

Sec. 406

Rules required:X90/180

days COMM X

Each issuer to disclose whether or not and the

reason such issuer has adopted a code of ethics for

senior financial officers X X ISSUER X


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Revise regulations concerning prompt disclosure on

Form 8-K any change in or waiver of the code of

ethics for senior financial officersX90/180

days COMM X

To promote

disclosure in the periodic reports

and regulations

Sec. 407

Rules required: to require each issuer to disclose

whether or not, and the reasons therefore, the audit

committee of that issuer is comprised of at least 1

member who is a financial expertX90/180

days COMM X

accountant, auditor, principal financial officer,

comptroller, principal accounting officer of an issuer

or a position involving the performance of similar

functions including

Sec. 408

Commission shall review these disclosures

including a review of an issuers financial statement

and considering X COMM X

price compared to others

sector of the economy

Sec. 409

Issuer shall disclose to public information

concerning material changes in the financialcondition or operations of an issuer on a rapid

and current basis as is necessary for the protection

of investors and in the public interest X ISSUER X



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TITLE V ANALYST CONFLICTS OF INTEREST

Sec. 501

Rules required: not more than 1 year x 1yr COMM

To address conflicts of interest when analystsrecommend securities

of research reports X ANALYSTS

evaluation of securities analysts to off icials

employed by the broker/dealer who are not

engaged in investment banking activities X ANALYSTS

banking activities may not directly or indirectlyretaliate against or threaten to retaliate against any

securities analyst as a result of any negative

research report that may adversely affect the

present or prospective relationship X ANALYSTS

participate/have participated in public offerings

should not publish/distribute research reports

related to such X ANALYSTS

to assure that securities analysts are separated by

informational partitions from the review, pressure,oversight of those involved in investment banking

activities. X ANALYSTS

research report known or obvious conflicts of

interest including X X ANALYSTS/ BROKERS X

in the investment X X ANALYSTS/ BROKERS X

X X ANALYSTS/ BROKERS X

broker/dealer X X ANALYSTS/ BROKERS X


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research report based upon the investment banking

revenues X X ANALYSTS/ BROKERS XTITLE VI COMMISSION RESOURCES AND

AUTHORITYSec. 601

Funds are authorized to carry out functions,

powers, and dutiesx

Funding COMM

Sec. 602

Commission may censure, deny any person from

practicing before the Commission x COMM

of securities laws

Authority to prohibit persons who have participated

in an offering of penny stock. X COMM

TITLE VII STUDIES AND REPORTS

SEC. 701

Comptroller of the US will conduct a study to

identify the factors that led to consolidation of public

accounting firms since 1989; present and futureimpact; solutions to any problems identified. X COMPTROLLER U.S.

SEC. 702

Commission to study the role and function of credit

rating agencies in the operation of securities market X COMM

Sec. 703

Commission to determine number of securities

professionals who have been found to have aided

and abetted or been primary violators of a violation

of the federal securities laws; including adescription of the laws violations committed by

them including: X COMM

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imposed

Sec. 704

Study required to review and analyze all

enforcement actions by the Commission involving

violations of reporting requirements X COMM

Sec. 705

GAO study required to determine whether

investment banks and financial advisers assisted in

manipulating their earnings and obfuscating their

true financial condition. XGAO

TITLE VIII CORPORATE AND CRIMINAL

FRAUD ACCOUNTABILITY

Sec. 802

Whoever knowingly alters, destroys, mutilates,

conceals, covers up, falsifies or makes false entry

in any record, document or tangible object with the

intent . . . shall be fined, imprisoned or both. X ISSUER/ EXEC

Any accountant who conducts an audit of an issuer

shall maintain all audit or review work papers for a

period of5 years from the end of the fiscal period in

which the audit was conducted. X ACCOUNT ANT/ RPA X X 5YRS

Rules required: Commission shall promulgate such

rules and regulations relating to retention of

relevant records such as:X 180

DAYS COMM



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received in connection with an audit, review and

contain conclusions, opinions, analyses, or financial

data relating to such an audit or review conducted

by an accountant for the issuer of securities under

the SEA of 1934Anyone who knowingly and willfully violates shall be

fined, imprisoned or both X ISSUER/ RPA ETC

Sec. 804

Statue of Limitations for securities fraud is X ISSUER/ RPA ETC

X

X

Sec. 805

Whistleblower protection to prohibit discriminatebehavior against an employee for assisting an

investigation regarding a violation of the SEC

regulations X ISSUER/ RPA ETC

TITLE IX WHITE-COLLAR CRIME PENALTY

ENHANCEMENTS

Sec. 905

United States Sentencing Commission shall amend

the federal guidelines to ensure that sentencing

reflects the serious nature of the offenses and

penalties set forth in this ACT, and the growing

incidences of serious fraud offenses which are

defined above. XUS SENTENCING

COMMISSION

Sec. 906

Each periodic report containing financial statements

filed by an issuer shall include a written statement

by the CEO, CFO or equivalent of the issuer stating

that: X ISSUER/ CEO,CFO

material respects, the financial condition and results

of operations of the issuer

TITLE X CORPORATE TAX RETURNS

Sec. 1001

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Federal income tax return should be signed by the

CEO of such corporation X ISSUER/ CEO

TITLE XI CORPORATE FRAUD

ACCOUNTABILITY

Sec. 1103

A temporary freeze on assets during an

investigation an escrow subject to court

supervision in an interest bearing account for 45

days. X COMM/ ISSUER/ RPA

Sec. 1105

Commission may issue an order to prohibit any

person who has violated the rules, from acting as

an officer or director of any issuer of a class ofsecurities X COMM

Sec. 1106

Penalties increased for fines and imprisonment X COMM

Sec. 1107

Any person who retaliates against a person for

providing truthful information relating to the

commission or federal offense shall be fined,

imprisoned or both. X COMM



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Documents/Records Series Suggestions

ublic Corporation

tified as a study, report, rule (policy), or



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Board Policy/Procedures



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Purchase/contract file for each service to

document approval or exemption class,

created/retained by Audit Committee



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Board Policy/Procedure/Compliance Statement

Board Policy/Procedures; Complaint File to

document complaints received; created/retained

by Audit Committee

Board Policy/Procedure; budget allocation for

Audit Committee; Purchase/Payment File for

Services; created/retained by Audit Committee


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Records and Information Management SARBANES-OXLEY ACT Review/Analysas of 9-18-20


Company Policy/Procedure; Signature andaffidavit on all periodic reports, created/retained

by issuing officer

Company Policy/Procedure on Internal Controls;

Periodic Reports to include affidavit,

created/retained by issuing officer


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Company Policy/Procedure/Compliance

Statement


Statement; Restatement File to document

compliance, created/retained by issuing officer


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Company Policy/Procedures/Compliance

Statement;

Company Policy/Procedure; Compliance

Statement; Black Out File to document each

occurrence, created/retained by Plan

Administrator (must be included in a contract for

3rd party services)

Compliance Statement for attorneys practicing

before SEC (including 3rd party services); report

to the audit committee.


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Statement; File on Off-balance sheet transactions

including reconciliations, created/retained by

issuing officer


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Statement.


Statement; Beneficial Owner File with statement

and date issued, created/retained by issuing office


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Company Policy/Procedure; Internet Publishing,

created/retained by Corporate Communications in

hard copy

Company Policy/Procedure; Annual Report

Affidavit, created/retained by issuing office

Code of Ethics, created/retained by issuing office


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Statement; Public Information Statement

created/retained by Corporate Communications


R d d I f ti M t SARBANES OXLEY ACT R i /A l i


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R d d I f ti M g t SARBANES OXLEY ACT R i /A l i


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Statement.

Grainger currently retains all internal audit reports

and work papers, and external audit reports

R d d I f ti M t SARBANES OXLEY ACT R i /A l


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Company Policy/Procedures/Compliance

Statement;

This documentation will be found in a Litigation

Case file.


Statement.


Statement; Report with Signature and Statement,

created/retained by issuing office

Records and Information Management SARBANES OXLEY ACT Review/Analys


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Statement; Tax Return with CEO signature,

created/retained by issuing office

Compliance requirement; document any

occurrence in Legal Case File

Order to be issued as necessary

Penalties increased as necessary

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