establishing and maintaining robust Controls 99 The consumer product giant, Procter and Gamble, demonstrated its com- mitment to establishing a culture of control via this statement in its 2009 annual report: Every employee ­ from senior management on down ­ is required to be trained on the Company's Worldwide Business Conduct Manual, which sets forth the Company's commitment to conduct its business affairs with high ethical standards. Every employee is held personally accountable for compliance and is provided several means of reporting any concerns about violations of the Worldwide Business Conduct Manual. xvii Is it working? Two qualitative tests of your firm's control culture This is a very simple test. Ask yourself how comfortable you would be going on holiday where there is no contact with your company as you close your books for the quarter. That's right ­ closing the quarter without your input. Not closing a month, as this should be fairly routine, and not closing the books for the year, as your financial expertise and strategic perspective