Perspective: What conflict of interest issues can get you in trouble in regards to SOX?

Dr. Jackson: The typical example of conflict of interest in corporations arises when, for example, there is a personal relationship with a vendor, or a member of a company's staff is an undisclosed "silent partner" in a vendor's company. Conflict of interest also arises when an undisclosed situation results in a contract being awarded to a vendor that results in gain for the person authorizing the transaction. You can think of this in terms of kickbacks.

Perspective: Are non-profits organizations required to comply with SOX?

Dr. Jackson: The non-profit world is notorious for what could be called a lax attitude toward SOX. Non profits don't really think Senator Grassley (R-Iowa), chair of the Senate Finance Committee, can go after them, but believe me that he can and will.

Dean Zerby, aide to Senator Grassley, has been quote as saying, "Non-profit leaders (regarding SOX compliance) essentially fall into three categories: Ostriches, Luddites, or Fig Leaf Reformers."

The Ostriches just want to stick their heads in the sand and say, "SOX doesn't apply to non-profits." This is absolutely not true. Luddites are people who say, "Well, we don't really need to change anything." The Fig Leaf reformers are the ones who say, "Ok, I guess we had better bring in a consultant."

Those who investigate organizations that act unethically in relation to SOX see no difference between malfeasance in a corporation or non-profit. Today, the only difference between a corporation and a non-profit is their tax status. The same guidelines that relate to having a whistle blowing policy in place at a corporation apply to non-profits.

Perspective: What is the most user-friendly resource for SOX requirements for people who are not lawyers?

Dr. Jackson: The first set of resources is the series of books I have written and published with Wiley Publishers. Those books can be found at: www.wiley.com/WileyCDA/ (enter Peggy Jackson in the product search box). I also have a book coming out in the fall on SOX for small businesses.

The second resource I would mention is the website of the American Institute of Certified Public Accountants. The URL is www.aicpa.org . Their website is amazingly user-friendly.

Perspective: What proactive steps can a meeting planner take to make sure he or she is assisting with SOX compliance?

Dr. Jackson: The first thing to do is express a commitment to ensuring that all the documents you handle as a part of your department are managed according to the company's document preservation policy. Meeting planners should learn the protocols and procedures regarding document preservation. They should state that they are committed to remaining in compliance. All documents related to meeting planning activities should be easy to retrieve. Planners should commit to maintaining the confidentiality of all meetings and events, and based on that commitment they should make sure that only authorized people are in the room. Security is very important at meetings where confidential information will be discussed or shared. And lastly, planners should not take away any proprietary documents that are, for example, related to financial issues or new product information.

Perspective: What professional resources should be available to a company to help maintain SOX compliance?

Dr. Jackson: I always tell my clients that certain professional experts need to be an integral part of an organization's operations. These people include bankers, accountants, tax preparers, insurance providers and legal councils. These people know your company inside and out. And if you are a private meeting planner, this is essential. The answer to many SOX compliance questions are complex and require legal or other expert advice. Even though these experts may be outside consultants, they are the ones that will know your company's operations and will be able to give you answers and keep you out of trouble. Having a good legal council is especially important in today's environment; in fact, it is more important than ever for third-party meeting planning firms.

Dr. Jackson can be contacted at:pjackson@adjunctex.com

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