Below are a sampling of disclosures made in October that outline internal control remediation and improvement efforts. Please note that some of the disclosures below may be updates to prior remediation disclosures. Also, please be aware that the excerpts below are just that: excerpts. The complete SEC filings are available for those who would like to review the complete disclosures in greater detail. For related information on the list below, as well as inclusion and exclusion criteria, please refer to the related story from the Nov. 9 edition of Compliance Week.

Company

Date

Description

Adecco SA—

Staffing.

2003 Sales: $20.4b

Auditor:

Ernst & Young

Oct. 29

REMEDIATION EFFORTS LISTED FOR CONTROLS IMPROVEMENT —

… The Adecco Group is working to strengthen its internal controls in areas identified during the 2003 audit. The Adecco Group is committed to maintaining the highest standards of ethical business conduct. To further strengthen its group practices in this area, the Adecco Group has appointed a full-time Chief Compliance and Business Ethics Officer to oversee worldwide compliance practices and business ethics within the group reporting to the Board…

Akorn—

Pharmaceutical manufacturer.

2003 Sales: $45.5m

Auditor:

Deloitte & Touche

Oct. 13

CONTROLS ADDRESSED AFTER SEC CONSENT ORDER —

…On September 25, 2003, we consented to the entry of an administrative cease and desist order with respect to these matters. The consent order also required that we [among other items] ... retain a qualified independent consultant acceptable to the staff to perform a test of our material internal controls, practices, and policies related to accounts receivable, and … within 180 days, have the consultant present his or her findings to the commission for review to provide assurance that we are keeping accurate books and records and have devised and maintained a system of adequate internal accounting controls with respect to our accounts receivables. On October 27, 2003, we engaged Jefferson Wells, International to serve as consultant in this capacity. On February 6, 2004, Jefferson Wells reported its findings to the special committee, such findings being that we have made the necessary personnel changes and procedural improvements required to maintain control over the accounts receivable process and establish the necessary reserves. Jefferson Wells’ report was delivered to the SEC on February 13, 2004. We believe we have complied with all of the terms of the consent order.

Levi Strauss & Co—

Maker of jeans & sportswear.

2003 Sales: $4.1b

Auditor:

KPMG

Oct. 12

MATERIAL WEAKNESS IDENTIFIED —

In response to the matters described in these communications from our independent auditors, we have taken actions to address these issues, including actions described in our Annual Report on Form 10-K, and these additional actions:

• we have hired a new vice president to lead our global tax department, who has significant expertise in U.S. and international tax accounting and related SEC reporting and disclosures;

• we have hired a new tax director, who has significant SEC reporting and tax GAAP experience, and who will be responsible for our tax accruals, disclosures and income tax return preparation;

• we have reorganized our corporate controllers department to simplify our structure and reinforce accounting oversight, and have appointed a new assistant corporate controller, upgrading our technical accounting skills in this department;

• we have established an external financial reporting group, a new function, in the corporate controllers department, and have hired a new senior director for this function who has significant experience in U.S. GAAP and SEC reporting and disclosures;

• we have hired individuals for key management-level positions in our corporate controller’s and tax groups who have significant U.S. GAAP and tax experience;

• our corporate controller’s group and our tax department are focused on communicating more effectively with an increased concentration on the financial reporting aspects of tax items;

• we have retained outside experts on tax accounting to train and develop personnel in our tax and corporate controller’s groups; and

• we have instituted a quarterly trial balance review in which our chief financial officer, controller and other senior finance leaders engage in a detailed review of the financial statements for each of our businesses and functional areas.

We believe these actions will strengthen our internal control over financial reporting and address the material weakness identified by our independent auditors.

JLG Industries—

Work platforms and construction equipment.

2004 Sales: $1.1b

Auditor:

Ernst & Young

Oct. 6

REMEDIATION UPDATE FOR FEBRUARY WEAKNESSES —

As previously disclosed in our third quarter Form 10-Q, in February 2004 our disclosure controls and procedures were found to be ineffective in identifying an accounting error related to the timing of the recording of revenue in conformity with U.S. generally accepted accounting principles arising from our improper accounting for a single consignment sale. In response to the matter identified, we have taken significant steps to strengthen control processes and procedures in order to identify and rectify the accounting error and prevent the recurrence of the circumstances that resulted in the need to restate prior period financial statements. Since March 2004, we corrected the identified weaknesses in our disclosure controls and procedures that led to the above error by taking the following steps, among others:

• Strengthening our documentation and formal process to review and approve proposed revenue transactions prior to their occurrence.

• Supplementing our revenue recognition policy to include a clearly understandable summary of key elements of the policy to better ensure broader understanding of the policy among our personnel.

• Conducting training sessions for affected employees on applicable policies and procedures.

• Implementing additional detection controls to identify and correct accounting errors on a timely basis before such errors reach our financial statements.

We continue to improve upon our disclosure controls and procedures and have, in addition to the foregoing, named a Sales/Operations Compliance Officer to assure compliance with our procedures and policies relating to proper documentation of domestic and international sales transactions, expanded the scope of our quarterly internal audit activities, implemented additional controls and procedures and conducted additional training sessions for employees on applicable policies and procedures.

Richardson Electronics—

Electronic component distribution.

2003 Sales: $520.1m

Auditor:

KPMG

Oct. 6

REMEDIATION UPDATE FOR MAY WEAKNESS —

During the first quarter of fiscal 2005, the Company has made progress on remediating the material weaknesses previously described in the Company’s Annual Report on Form 10-K for the year ended May 29, 2004, including drafting new policies and procedures, reinforcement of existing procedures and documentation of management review and approval processes. These remediation efforts will continue in conjunction with the Company’s Sarbanes-Oxley compliance plan.

I-Sector Corp.—

IT services.

2003 Sales: $

62.2m

Auditor:

Deloitte & Touche

Oct. 5

REMEDIATION UPDATE TO PRIOR DEFICIENCIES —

In connection with their audit of the consolidated financial statements for the year ended December 31, 2003, Grant Thornton LLP ("Grant Thornton"), our independent accountants, identified and reported to the audit committee of the board of directors certain internal control deficiencies that Grant Thornton considered to be significant deficiencies under the standards established by the American Institute of Certified Public Accountants and the SEC. The identified internal control deficiencies relate to (i) a material weakness involving

contemporaneous documentation of all terms related to revenue transactions and conclusions regarding customer creditworthiness and (ii) a significant deficiency with respect to the review of significant agreements by our accounting personnel in order to monitor compliance with their terms.

We have taken corrective actions to address these internal control deficiencies, by implementing the following measures:

o established improved procedures for the review of revenue recognition policies and contract management polices and procedures;

o held formalized training of finance and sales staff; and

o hired an additional person in our accounting department.

College Partnership—

College and career planning and preparation company

2003 Sales: $

NA

Auditor:

Hein & Associates

Oct. 1

STEPS TAKEN TO REMEDIATE FORMER WEAKNESS —

The audit report of Hein on our financial statements as of July 31, 2003 and 2002, did not contain an adverse opinion or disclaimer of opinion, nor was it qualified or modified as to uncertainty, audit scope, or accounting principles. However, as disclosed in our Form 10-KSB for our fiscal year ended July 31, 2003, and our Form 10-QSB for the nine months ended April 30, 2004, Hein had concluded that we had a material weakness in our internal controls. This weakness was attributable to a lack of appropriate accounting staff and management information systems to support our timely reconciliation and review of accounts, resulting in a delay in our filings with the Securities and Exchange Commission. We have recognized this weakness in our internal controls, which we believed to have occurred as a result of a substantial growth in our revenues, the consolidation of accounting functions in Colorado and timing of extraction of data from our accounting system. In response to this recognition, we have hired new support staff, both temporary and permanent, and have implemented changes in our management information systems to improve the timeliness of our filings. While no assurances can be provided, we believe that with the actions we have taken to remedy this problem, we expect to be able to file future reports in a timely manner.

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