Internal Control

The Turnbull Guidance on Internal Control

The Turnbull guidance sets out best practice on internal control for UK listed companies, and assists them in applying section C.2 of the Combined Code.

The Turnbull guidance was originally published in 1999. In July 2004 the FRC set up a group chaired by Douglas Flint (Group Finance Director, HSBC Holdings plc) to review the guidance and update it where necessary, in the light of experience in implementing the guidance and developments in the UK and internationally since 1999.

Following the review the FRC published updated guidance in October 2005. It applies to listed companies for financial years beginning on or after 1 January 2006. The revised guidance can be downloaded from this website, and printed copies can be obtained free of charge from CCH Information (tel: 0870 777 2906 or online at www.cch.co.uk).

 Revised Turnbull guidance October 2005 (56kb)

Documents associated with the FRC review and consultation can be found at www.frc.org.uk/corporate/reviews.cfm

Section 404 of the US Sarbanes-Oxley Act 2002

The US Securities and Exchange Commission (SEC) has identified the Turnbull guidance as a suitable framework for complying with US requirements to report on internal controls over financial reporting, as set out in Section 404 of the Sarbanes-Oxley Act 2002 and related SEC rules.

The FRC published on December 2004 a guide for UK and Irish companies registered with the SEC on the use of the Turnbull guidance for these purposes.

 Guide on use of Turnbull for section 404 (40kb)