Engagement Memo—Audit of Amtrak’s Ethics Program (Project code 003-2017)

We are initiating an audit of the company’s ethics program. Our objective is to assess the company’s program for ensuring ethical conduct, and preventing and detecting potential conflicts of interest. This audit will include an assessment of the program’s polices, its organizational alignment and responsibilities for administering the program, as well as its training, monitoring, and enforcement efforts. As part of this audit, we will compare the company’s program to leading practices in the public and private sectors to identify potential opportunities for improvement. We may revise our scope or modify our objective during the course of the audit.

During the audit, we plan to interview company officials and analyze documents and data related to the ethics program. Our request for documents will be made as our work progresses. We will work to minimize the impact of the audit by coordinating interviews and observations with staff in advance.