XY Co., Ltd. in order to comply with the requirements of the internal control regulations for listed companies, to improve the level of business management and risk prevention ability, and to promote sustainable development of the enterprise, in accordance with the Ministry of Finance, the Securities and Futures Commission and other five ministries and commissions issued by the basic norms of enterprise internal control and the supporting guidelines requirements, to hire external consulting firms, from March 2011 to start the construction of the internal control system work. Since March 2011, we have started the construction of internal control system. According to the requirements of the Basic Standard for Enterprise Internal Control and its supporting guidelines, combined with the experience of foreign companies, the construction of enterprise internal control system is usually divided into four phases, internal control grooming, internal control rectification and curing, internal control self-evaluation and internal control audit, of which the first three phases are the core work of the internal control construction, which needs to be completed by the enterprise to take the lead, and the internal control audit will be carried out by the auditor in the cooperation with the enterprise.

In order to do a good job in the construction of internal control system, the company in March 2011 formally set up the internal control work leading group, led by the chairman of the company, the senior leadership in charge of the headquarters of the head of each department and the general manager of each molecular company as a member of the group, responsible for organizing and leading the standardization of the construction of the company's internal control work. mid-March 2011 held a kick-off meeting of the implementation of the project of the company's internal control Construction work was deployed and mobilized, and formulated the company's internal control implementation plan and work program.

First, the establishment of internal control construction organizational structure, clear responsibilities of relevant personnel.

Internal control construction as a long-term systematic project, not overnight, the company decided to establish a long-term leadership mechanism for continuous operation. The company's internal control system construction organization chart is as follows, and clear chairman of the board of directors for the implementation of internal control of the first responsible person; general manager, deputy general manager of the company for the implementation of internal control of the specific person in charge.

(I) Responsibilities of the Internal Control Leading Group

After the deliberation and approval of the Tenth Session of the Sixth Board of Directors, the Company has established the Risk Management Committee, which comprises the Chairman of the Board of Directors, the Chairman of the Audit Committee, the General Manager, the Company's senior executives in charge of the major businesses and professionals as the leading group of the internal control work.

The Risk Management Committee is accountable to the Board of Directors and mainly performs the following duties:

(1) It is responsible for creating a favorable environment for the construction of internal control;

(2) It is responsible for formulating the strategic planning of the Company's internal control and proposing the overall construction plan;

(3) It is responsible for considering the judgment criteria for major decisions, major risks, major events and important business processes or judgment mechanism, as well as risk assessment reports for major decisions;

(4) deployment of internal control construction, implementation and supervision activities, etc.

(5) consideration of the preparation, modification and updating of Internal Control Manual;

(6) submission of Internal Control Evaluation Report;

(7) coordination of major matters in the construction of the Company's internal control;

(8) evaluation of internal control; and p>(8) To assess the personnel involved in the construction of internal control and to maintain the consistency of the overall interests and direction of the Company.

(2) Duties of internal control project team

1. The Company has set up the office of the Risk Management Committee under the Risk Management Committee as the internal control project team, which mainly performs the following duties:

(1) comprehensively carrying out and executing the spirit and guideline of the Risk Management Committee on the construction of internal control;

(2) formulating the milestone of the construction of the Company's internal control objectives and implementation programs, and submit them to the Risk Management Committee for review;

(3) to be responsible for the effective implementation and operation of the internal control construction, and to implement the specific responsibilities for the internal control construction;

(4) to study and put forward the Internal Control Evaluation Report;

(5) to be responsible for the compilation, modification and updating of the Company's Internal Control Handbook;

(6) to review and approve the internal control manual in the problems in the process of internal control construction, and supervise the departments to carry out rectification.

2. The Company has subdivided the office of the Risk Management Committee into 4 major systems, namely, the Risk Control System, the Strategy and Securities System, the Financial System and the Operation System, and clarified the specific responsibilities of each system.

3. Members of the Risk Management Committee Office mainly come from the Financial Management Department, Strategy and Securities Management Department, Risk Management Department, Management Innovation Department, Marketing Center, Quality and Customer Service Department, Supply Chain Center, Legal Affairs Department, Research and Development Center, Manufacturing Center, and Strategic Human Resources Department, with 33 full-time staff. All business units, functional departments and subsidiaries (business divisions) under the guidance of the Risk Management Committee Office*** participate in and implement internal control construction work together.

4. The Audit Committee, as the supervisory body of the effectiveness of the Company's internal control system, supervises the effective implementation of internal control and self-evaluation of internal control, audits and supervises whether the external auditing organization is independent and objective and whether the auditing procedures are effective, audits the Company's financial information and its disclosure, and coordinates the internal control audits and other related matters.

(C) Responsible Departments and Work Budget

Corresponding to the internal control working group, the Company has confirmed the responsible departments for the construction of internal control, i.e., the Risk Management Department, the Strategy and Securities Management Department, the Finance Management Department, the Management Innovation Department, the Marketing Center, the Supply Chain Center, the Quality and Customer Service Department, the Legal Affairs Department, the Manufacturing Center, the Research and Development Center, and the Strategic Human Resources Department. The budget for this internal control project work has been formulated, including internal control consulting, internal control audit and labor cost expenses, training expenses, etc. In order to ensure the professionalization, systematization and rationalization of the internal control construction work, the Company has hired the consulting company as an external consulting agency to provide professional support to the Company, assist the Company in sorting out, constructing and perfecting the overall structure of internal control, help the Company to identify the weaknesses and major risks of the internal control, and design the key processes and contents of the control in a targeted manner and assist the Company to carry out the self-evaluation of the internal control work. Risk control system personnel will be involved in risk identification and assessment, preparation of risk lists and control matrices, rectification of internal control deficiencies, internal control evaluation, etc., in order to cultivate internal control construction and evaluation talents for the company.

Two, the internal control system construction work to promote the specific

Internal control construction work, the company will be divided into five phases, the time from April 1, 2011 to January 31, 2012, the overall arrangements are as follows:

(a) Determine the scope of the implementation of internal control (completed by April 10, 2011)

According to the spirit of the documents of the Securities and Futures Bureau, combined with the company's actual, this internal control implementation scope. In accordance with the spirit of the documents of the Securities and Futures Bureau and in conjunction with the actual situation of the Company, the scope of implementation of the internal control is the Company, a subsidiary in Shanghai and a subsidiary in Guangzhou.

In accordance with the requirements of the "Basic Standard for Internal Control of Enterprises" and its supporting guidelines, and in conjunction with the nature of the Company's business, the Company will focus on three major processes at the corporate level, such as development strategy, organizational structure and human resources, as well as nine major processes at the business level, such as information systems, financial reporting, information disclosure, related transactions, comprehensive budgeting, capital activities, procurement operations, sales operations, asset management and so on.

The responsible persons for each process are as follows (× × represents the name of the responsible person):

First person responsible for the process Specific person responsible for the process Internal control coordinator Intermediary responsibility

Development strategy × × × × × ×

Organizational structure × × × × × ×

......

Note: the above The responsible person applies to each stage in the construction of internal control.

(2) Risk identification and assessment (completed before May 31, 2011)

1, process sorting: the company sorted out the processes through interviews, review of documents or questionnaires, clarified the corresponding sub-processes of the above 12 processes, perfected the organizational structure and guidelines for approvals and authorizations, and compiled the business process diagrams according to the unified template. During the process combing process, work processes with internal control deficiencies such as omissions, clutter, non-compliance with relevant laws, incompatible positions not separated or unreasonable authority settings are timely identified and recorded, and corresponding measures are taken to standardize the operation process to avoid the emergence of major risks such as internal fraud and to improve work efficiency.

2. Risk identification: Combined with the risks listed in the "Basic Standard for Internal Control of Enterprises" and the relevant supporting guidelines, the company's customer audit requirements, internal audit reports, proposals for improvement, quality accidents, and other initial information, from the possibility of the occurrence of the risk and the degree of impact of the sub-processes involved in each control point for a comprehensive analysis, identification of the inherent risks, evaluation of the risk level, and the formation of the risk list.

3, documentation: according to the risk level, identify the key control activities in the process, and numbered in the flow chart; preparation of process descriptions, risk control matrix and other internal control documents on the control activities and control points to record.

4, find internal control deficiencies: the company's existing systems and control measures flow and risk list comparison, through penetration testing, control testing and other means, to obtain evidence on the effectiveness of the design and operation of internal control, to find internal control deficiencies, the formation of the "Risk Database" and the "Diagnostic and Evaluation Report of Internal Control Risks". Significant deficiencies identified are reported to the Board of Directors and management in a timely manner, and the management shall formulate an internal control deficiency rectification program in a timely manner for the internal control deficiencies identified.

(C) Determination of internal control deficiencies rectification program (completed by June 30, 2011)

1. Preparation of Internal Control Management Proposal: The Company classifies and analyzes the internal control deficiencies found, determines the degree of importance of the internal control deficiencies, distinguishes between the design deficiencies and the operational deficiencies, and forms the Internal Control Management Proposal.

2. Formulation of internal control defects rectification program: the company, based on the Internal Control Management Recommendation and specific control defects, proposes the rectification time as well as the responsible departments and personnel to form the internal control defects rectification program.

3, submitted for consideration: internal control deficiencies rectification program should be considered and approved by the Risk Management Committee.

(D) internal control deficiencies rectification (completed before September 30, 2011)

1, the implementation of rectification, submit a report: the responsible departments will be in accordance with the internal control deficiencies rectification program for the defects found in the rectification of one by one to improve the company's various internal control management system and control measures, to submit the "Internal Control Deficiencies Rectification Report"; the internal control project team together with the intermediary institutions on the defects rectification situation The internal control project team, together with the intermediary organization, will carry out the operational effectiveness test and form the "Internal Control Operational Test Report".

2. Preparation of Internal Control Manual: The internal control project team prepares the Internal Control Manual based on the risk list and various internal control documents and other information, and provides counseling and promotes the implementation of the manual.

3. Preparation of Internal Control Self-Assessment Guidelines: The internal control project team prepares Internal Control Self-Assessment Guidelines to lay the foundation for the next step of internal control self-evaluation.

4. Submission for consideration: The Internal Control Deficiency Rectification Report, Internal Control Operation Test Report, Internal Control Manual and Internal Control Self-Evaluation Guidelines shall be submitted to the Risk Management Committee for consideration.

(V) Continuous promotion of internal control and internal control self-evaluation

The Company will continue to promote the results of the internal control system after its completion, and in accordance with the requirements of the jurisdictional Securities and Futures Commission (SFC), the Company will submit a statement on the progress of the internal control to the SFC and disclose the same in the regular report within 10 working days after the end of each quarter. The quarterly progress statement will at least include the implementation of the internal control construction work in the quarter, comparison with the planned progress in the work program, reasons for the discrepancy and measures to be taken to resolve the discrepancy.

Through the above work, the Company has initially established a sound internal control system and effectively improved the level of internal control management.

Three, the enterprise internal control system "landing" and continue to promote

XY company in the completion of the preliminary construction of the internal control system after the completion of the implementation of the specific process, some departments and employees, or because of the new internal control system is not enough to understand, or due to the long term work habits are difficult to change, or because of the change of the internal control system touches their own interests and do not want to follow, make the internal control system is not sufficient to understand, or due to the long time working habits, or because the change of the internal control system touch their own interests. Some departments and employees are unwilling to follow the new internal control system due to insufficient understanding of the system, difficulty in changing long-term working habits, or changes in the internal control system touching their own interests. How to implement the internal control system effectively and maintain the continuous improvement and enhancement of the internal control system is a problem that the management urgently needs to solve.

In order to truly "land" the internal control system, XY company through a full range of internal control training, strengthen the internal control inspection and supervision, improve the assessment and incentive mechanism, as well as with the help of the third-party professional organizations of the continuous counseling and other measures, to ensure that the continuous maintenance of the internal control construction, the company's internal control construction has made fruitful progress. The company's internal control construction has made fruitful progress.

Specifically, the main measures taken include:

(1) Improvement of the organizational structure of internal control work, establishment of the Internal Control Department, strengthening of the Audit Department, and establishment of the organizational structure and operation mechanism for promoting internal control work.

Through a comprehensive examination of the current situation and process of internal control construction of large international enterprises, XY Company found that in order to implement effective internal control, it is necessary to establish a matching organizational structure. To this end, the company has set up an internal control work leading group by the top management, and the management of each subsidiary correspondingly set up an internal control management group; in terms of departmental setup, XY Company has newly set up an internal control department, and each subsidiary has set up an internal control department or an internal control responsible post in accordance with the size of the subsidiary, which is responsible for the construction of internal control; in terms of supervision of internal control, it has transformed the original duties of the Audit Department, added the functions of evaluation and inspection of internal control and is under the direct leadership of the Audit Committee of the Board of Directors of the company. The Audit Committee of the Company's Board of Directors is under the direct leadership of the Company, and internal audit specialists have been set up at the same time in larger subsidiaries to take charge of the subsidiaries' internal control self-inspection.

(ii) Focusing on the construction of internal control environment and conducting all-round internal control training.

Through a series of training and counseling, Company XY improves the understanding of internal control concepts of all levels of management and basic staff, and creates a favorable cultural environment for internal control work. First of all, the company grasps to popularize the basic knowledge of internal control, create an environment for the implementation of internal control publicity work. The internal control department of the company organized the compilation of "internal control brochure", which was distributed to all functional departments of the joint-stock company and subordinate companies within the scope of the main management cadres to study. The brochure helps managers at all levels to unify their understanding and awareness of internal control through vivid cases and figurative language, and reduces the ideological resistance to the promotion of internal control.

Secondly, according to the progress of the implementation of the internal control standards, the company has carried out various kinds of centralized thematic trainings on various aspects of internal control, including basic concepts, management system, risk assessment, evaluation of internal control, and assessment of internal control, which have greatly promoted the preparation and implementation of the internal control system.

(3) Establishing a communication mechanism for the promotion of internal control to ensure the continuity of internal control construction and the timeliness of problem solving.

Since the construction of the internal control system has been formally promoted, in order to ensure the implementation of the promotion, the company has carried out a full range of information communication mechanism, realizing the real-time transmission of information, and smooth uploading and downloading.

First of all, Company XY has established a weekly meeting system. The leading group of internal control organizes weekly regular meetings on internal control work, chaired by the director of the company or the director of the Audit Committee, and the participants include members of the leading group of internal control, the Internal Control Department, the Audit Department, the Finance Department, and the heads of internal control of subsidiaries, etc. The leading group of internal control also organizes weekly meetings on internal control work. The functional departments of the headquarters and subsidiaries must report in writing the "weekly report on internal control work" at the meeting, reporting on the progress of internal control, problems, solutions, difficulties encountered and matters requiring assistance from the shares, and the head of the leading group of internal control on specific issues related to the advice and guidance after the meeting. After the meeting, the Internal Control Department of JSC is responsible for replying to each subsidiary to ensure that all the problems can be solved in a timely and effective manner. All meeting minutes and related documents are copied to the general manager and the board of directors of JSC after the meeting, and to the management of the relevant subsidiaries to ensure that the top management is always aware of the progress of internal control.

Secondly, the company has established a monthly work summary of the internal control system. At the end of each month, the person in charge of internal control of each subsidiary carries out a work summary on the implementation of internal control, which is communicated by the Internal Control Department among the management of JSC, the management of subsidiaries and the person in charge of the relevant internal control, so as to supervise the implementation of internal control of each subsidiary.

Thirdly, a separate reporting mechanism for major projects has been established. The person in charge of internal control of each subsidiary is required to report to the internal control leading group and the internal control department of JSC in a timely manner for major problems found in the construction of internal control of subsidiaries, so as to deal with possible major risks in real time. In addition, the contact information of the Minister of Internal Control, the Minister of Audit and the Chief Financial Officer of JSC is made public to all internal control officers and internal control specialists of the subsidiaries as an important channel for direct transmission of information to help JSC understand the internal control risks of its subsidiaries in a timely manner.

(4) Improvement of internal control evaluation and inspection mechanism and establishment of a multi-level internal control inspection system.

In order to ensure that the internal control system is on the ground and truly effective, the Company has established an all-round internal control evaluation and inspection system from the subsidiaries to the Internal Control Department and the Audit Department of JSC, and then to external independent third-party intermediaries. The Internal Control Department of the Joint Stock Company carries out regular internal control inspections of each business cycle. Through the issuance of internal control investigation checklists and on-site inspections by internal control specialists, the Company discovers deficiencies in internal control construction of subsidiaries, and issues risk contact letters, risk concern letters and risk warning letters in a timely manner, in order to help subsidiaries carry out internal control rectification and improvement in a timely manner. Among them, the contact letter is mainly a reply to the contact letter of the subsidiary; the concern letter mainly expresses concern about the business of the subsidiary and generally requires the other party to give a written explanation within a certain period of time; and the warning letter is a warning on the basis of the concern letter about the significant risks or the lack of implementation.

The Audit Department of JSC conducts internal control evaluations of its subsidiaries twice a year. In order to realize the quantitative and standardized evaluation, the Audit Department compiled the internal control evaluation draft through the inspection, the formation of the quantitative evaluation of the internal control construction of subsidiaries, and for the problems found in the inspection issued recommendations for improvement, and require the subsidiaries to be rectified within the specified time, the headquarters of the Internal Control Department of the subsidiaries of the rectification measures and rectification of the quality of the whole process of supervision, the completion of rectification, the Audit Department in a timely manner to be re-examined, to ensure that audit After the completion of the rectification, the Audit Department will review it in a timely manner to ensure that the problems found in the audit can be rectified in time.

(E) The construction of internal control is incorporated into the performance appraisal, and the effectiveness of internal control is realized through the reward and punishment mechanism.

First of all, in order to effectively bring into play the role and enthusiasm of the managers of the subsidiaries in the promotion of internal control, since the beginning of 200×, JSC has included the results of the internal control evaluation of the subsidiaries by the Audit Department into the indexes of the performance assessment of its management team, and clarified the responsibilities and key tasks of the management team for the construction of internal control. Through this kind of performance appraisal, the management team is incentivized to pay attention to and promote the implementation of internal control, so as to establish a favorable environment for the promotion of internal control work.

Secondly, the key personnel assigned by JSC to its subsidiaries are also directly linked to the construction of internal control. The company issued the "assigned internal control personnel performance assessment management measures", the implementation of the internal control of each subsidiary of the person in charge of the comprehensive assessment of the construction of internal control, a clear assigned internal control personnel performance assessment indicators, assessment methods, rewards and penalties mechanism, to further promote the implementation of the work of the assigned internal control personnel; Secondly, for the shares of the person in charge of the assignment of the financial sector, but also in the annual assessment of the total score (100-point system) to include Secondly, for the person in charge of finance assigned by the shareholders, the total score (100 points) in their annual assessment is also included in a considerable proportion of the content related to the construction of internal control, from the financial function of the subsidiaries to strengthen the promotion of internal control.

(F) Give full play to the power of professional intermediaries

XY Company hired a professional consulting firm to provide consulting services at the beginning of the establishment of the internal control system, in the whole process of establishing the system, give full play to the professional power of the consulting firm, and hired professional consultants to train the company's personnel to improve the concepts and skills of the company's personnel internal control. After the initial establishment of the internal control system, still continue to maintain cooperation with the consulting company, with the consulting company in the professional and independence advantages, *** with the promotion of the company's internal control of the continuous construction work, in the continuous construction of the internal control work, the professional consulting company provides a large number of professional advice and training and counseling services to help the company to improve the results of the company's internal control of the continuous construction of the company has achieved remarkable results.

Fourth, the experience and inspiration of the construction process of the enterprise internal control system

In the company's board of directors, managers at all levels and basic staff unremitting efforts, the construction of the company's internal control system has achieved a series of good results, the company's risk management awareness of employees at all levels has improved significantly, the understanding of the risk of attention to the various business and management loop; strengthened the standardized operation of the various business activities, to achieve the major business operations, the company has achieved a good result in the construction of the internal control system. It has strengthened the standardized operation of various business activities, realized the collective decision-making mechanism of major business activities, and effectively prevented the decision-making risks; improved the financial management level of the company, and ensured the truthfulness and fairness of the financial data at all levels from the industrial company to the joint-stock company, as well as the safety of the funds and assets; strengthened the company's attention to the management risks in the new business environment; improved the company's risk early warning mechanism, and enhanced the continuous monitoring, monitoring, and control of the potential risks of the business after the business occurrence by the various functional departments. It has improved the risk early warning mechanism of the Company and enhanced the continuous monitoring, analysis and response of each functional department to the potential risks after the occurrence of business. The main experiences and insights of the Company in the process of construction and promotion of the internal control system include:

1. Emphasis and personal involvement of the Company's Board of Directors and top management

In the Board of Directors of XY, both the major shareholder-appointed directors, non-executive directors and independent directors have attached great importance to and cared about the construction of the internal control system. As the major shareholder of the company, the Group has given great understanding and support to the construction of internal control of the joint stock company, which has strongly promoted the process of internal control construction of the industrial company. The regular meetings of the Board of Directors have taken the progress of internal control as an important topic of communication, and the Board of Directors level has always given corresponding and support to any problems arising from the advancement of internal control.

On the part of the company's management, an internal control leading group has been set up, and a lot of human and financial resources have been invested to lead the company's employees **** with the construction of internal control, which provides a good internal environment for the advancement of internal control, and at the same time stimulates the enthusiasm and initiative of the employees and promotes the development of the company's internal control in a smoother and more perfect direction.

2, the concept of internal control and its relationship with other management systems of the company's understanding of the unity

XY Company in the first stage of internal control to promote the implementation of high-frequency, substantial training to help managers at all levels as well as grass-roots employees to understand the main principles and value of internal control, to reduce the implementation of internal control of the ideological resistance. Secondly, the company has unified the understanding of internal control system and other management systems, internal control and risk management is not a set of isolated new systems and systems, but a management idea based on the framework of "goal-risk-control-supervision". It is a management idea based on the framework of "Objective-Risk-Control-Supervision", which can be integrated into all other management systems and management systems of the enterprise, and is the integration and enhancement of the original management system of the enterprise.

3, the development of a clear and precise internal control strategic planning

Company in accordance with its own actual situation, in order to develop and put forward a five-year two-step planning of internal control, and incorporate it into the company's five-year strategic planning. The first stage (3 years), through the top-down rigid requirements, to build a comprehensive unified group internal control structure, and through the concept of instilling the formation of internal control to promote the cultural scope; the second stage (2 years), through the bottom-up, conscious improvement of the internal control system, the formation of each industrial company's characteristics of internal control. This construction step from mandatory to conscious, from the popularization of the concept to the system improvement to the internal control manual of the form of enhancement, so that the company from the top management to the grass-roots staff at all levels of personnel are clear about the internal control of different periods of time and different tasks and different state of development, and steadily promote and gradually deepen the development of internal control for the development of the road outlined a clear path.

4, the implementation of enterprise-specific programs

Company XY realized that for the group of companies, internal control can not be a one-size-fits-all, the company to implement internal control, the need to choose the appropriate internal control methods according to their own type of business, the size of the company, the company is at the stage of the selection of internal control methods.

First of all, the company has absorbed the essence of the five ministries and commissions' basic norms of internal control and accompanying guidelines, and combined with its business practice, based on the principle of importance of the first and then the second, as well as the principle of cost-benefit, the company proposes to take a number of business cycles as the main cycle of the company's internal control construction scope.

Secondly, considering the company's personnel capacity and quality, there is no one-step register on the results of internal control, but rather, based on the construction of the system, through the system specification, to the optimization of the process and then to the refinement of the risk, and gradually realize the internal control of the layers of progress.

Thirdly, in the promotion of internal control, the company takes into full consideration of the business characteristics of the subordinate industrial companies, and determines the internal control methods and focuses suitable for each company.

5, the gradual implementation of the steps

(1) top-down concepts to promote the bottom-up process to promote the progress.

In the first stage of the implementation of internal control, the company emphasizes top-down conceptual advancement. The company reached the unification of the concept of internal control through internal training and various working meetings, and conveyed it to the subsidiaries, after which the subsidiaries carried out the bottom-up promotion of the internal control process, i.e., each industrial company carried out the improvement of the system according to its own internal process and implemented it after the review of the company's internal control department.

(2) From the headquarters issued a framework system to the various subsidiaries to develop targeted business process progression.

The company's internal control department combined with external forces to develop a framework system to clarify the key control points and operational requirements of the business cycle, the industrial companies according to their own business, to meet the requirements of the framework system under the premise of the development of their own management system, in order to be closer to the industrial company's business management practices.

(3) The progression of universal and generalized risk points to specialized and targeted risk points.

The company firstly draws a comprehensive risk database based on the research of the actual situation of industrial companies, and sorts out the generalized and universal main risk points, and then each industrial company constantly finds out the specialized and unique risks for different business characteristics in actual operation, so as to realize the perfection of internal control.

(4) Grasp the key companies, grasp the main cycles and risks, and grasp the typical events.

The company's internal control follows the principle of materiality, focusing on key company-level major cycles and risks, and typical events, with a view to promoting the development of internal control by focusing on the overall.

6, with the help of external professional intermediaries to promote the construction of internal control

External professional organizations have relatively richer internal control professional strength and experience in implementation, and objectivity and independence, XY company in the whole process of establishing the system, give full play to the professional strength of the consulting firms, but did not rely on the intermediary institutions to throw their hands off the matter, but to fully participate in the process of internal control construction, knowledge transfer and internal control. Instead, it fully participates and cooperates in the process of internal control construction, realizing knowledge transfer and internal control talent training, and achieving better implementation results.

-------------- from the Sina microblogging "Ma Junsheng - internal control blog"