He counseled that while the needs of any self-probe depend upon the circumstances at issue, certain procedures, established at the outset, can help in keeping an investigation's independence and effectiveness. They include:

o Oversight by an audit committee comprised of independent directors or by a similarly comprised special committee of the board.

o Use of a solid reputable law firm with no prior history of reporting to management.

o Use of an accounting firm to provide forensic assistance to the law firm.

o Authority for investigators to pursue all evidence of potential improprieties without constraint, no matter where they may lead.

o Consultation by investigators at the outset to ensure that the proposed scope of the probe will be sufficient to rely on for audit purposes.

o Willingness by the audit committee to actively oversee the investigation and assume responsibility for its results.

o Audit committee encouragement for all company personnel to cooperate with the investigation in both substance and spirit.

o Audit committee consideration of the need to set procedures ensuring that executives or employees potentially involved in misconduct are not informed or updated on the progress or tentative results of an investigation.

o Provision for an investigation that while moving with all possible speed is not pressured by management over artificial constraints such as a deadline for filing an annual report with the Securities and Exchange Commission.

o Provision for a report at the probe's completion that sets forth the circumstances giving rise to the investigation, the investigation's scope, the persons interviewed, sources of documents reviewed, the underlying facts, conclusions as to culpability and intent, the numerical explication of any necessary adjustments to the company's financial statements, and proposed remedial action.