G&A102 Files and Records Management

Accounting Policies, Procedures and Forms
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SOP # Revision: Effective Date: Title: Policy:
Prepared by: Approved by:
G&A102 FILES AND RECORDS MANAGEMENT The Company will retain records in an orderly fashion for time periods that comply with legal and governmental requirements and as needed for general business requirements. To outline the methods for filing, retaining and disposing of business records. This procedure applies to all business documentation generated by the company. However, this does not necessarily cover internal or certain dayto-day business correspondence. The File Manager will be responsible for categorizing and maintaining a listing of records maintained and the location (i.e. by wall unit and shelf row number). The Controller is responsible for overseeing the execution of company policy for Record Retention, Storage and Destruction of obsolete company records.
Purpose: Scope:
Responsibilities:
Procedure: 1.0 1.1 FILING SYSTEM To ensure efficient access, filing centers will be established in each department. To reduce the amount of duplicate and unnecessary record retention, individual desk files should be avoided unless they are used in daily operations. All other departmental or company records should be filed in the departmental central filing areas. Unless necessary, records should usually only be kept by the originator or sender and not by the receiver to avoid duplicate filing systems. The following filing guidelines should be adhered to optimize filing efficiency and records access: All file cabinets and files should follow recognized rules of order, such as Left to Right, Top to Bottom, Front to Back and in the case of chronological records, newest to oldest. File markers or label headings should always be placed at the beginning or front of a file or group of files. Alphabetical files should always be filed under broad topical categories. Files should never be filed under individual employee names (except Human Resources records) to avoid confusion and re-filing in the event of turnover. Files should always be filed under the "proper" or company names whenever
1.2 1.3
G&A102 Files and Records Management
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appropriate. In the case of individuals, files should be maintained according to the persons "Last name" then First name and Middle initial. Alphanumeric codes should be attached to colored end tabs of all file sets to show type of file by subject area and sub-category. For instance, all files dealing with Accounting will have a green end tab on the lateral file folder with the alpha code of AC followed by a three digit numeric code to designate the sub-category (i.e. Financial Planning is AC 200, General Accounting is AC 300, Payroll is AC 340, etc.). Payroll is a function of Accounting thus the AC, payroll is a function of General Accounting (under Accounting) thus the 300 series numeric, and under General Accounting the Payroll file is series number 40, which translates to a file of AC 340. Refer to G&A102 Ex1 MASTER FILE GUIDE INDEX for a sample of the subject and sub-category file guide. Extra care should be used for sensitive or private information. Company financial data or personnel records that contain performance reviews, salary information, and any health related information should be kept in a secure area with limited access to only those that have a need to know such as the Director of Human Resources or the Controller.
2.0 2.1
RECORD RETENTION AND LONG-TERM STORAGE Storage of archived records will be maintained in the locked storage area of the building. Access to this area will be limited to the Controller, officers of t he Company and the File Manager. Non-permanent files will be stored in cardboard file boxes. Each file box will be labeled on the front with the contents, dates covered, and destruction date if applicable. Permanent records will be maintained in metal fire-resistant file cabinets.
2.2
2.3 Files should be stored only in boxes with similar items, dates and retention periods. This will allow easier access and purging of records. A general rule to keep in mind is that it is better to only half-fill a file box than to file dissimilar types of files in the same box. 2.4 The file manager will be responsible for categorizing and maintaining a listing of records maintained and the location (i.e. by wall unit and shelf row number).
2.5 Maintain all files for as long as is necessary but only to the extent they serve a useful purpose or satisfy business or legal requirements. G&A102 Ex2 RECORDS RETENTION PERIODS, provides a guide to the typical business life of various documents. The retention periods provided are suggested with federal requirements in mind. Be sure to check with local and state authorities for specific record retention requirements. 2.6 Copies of critical records that are vital to the daily operations of the Company should be kept off site in case of possible disasters. This may include information needed to file insurance claims (assets lists, insurance contacts, policy numbers), financial data for tax purposes (wages paid, income and expenses), contacts lists to inform or restart the business (vendors, customers, investors and employees), and other
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data that would assist in rebuilding the business (business plans, intellectual property, or proprietary information). 3.0 3.1 3.2 RECORD DESTRUCTION Three to six months after each year-end, the file manager will proceed with destruction of all files that have exceeded their recognized holding period. A listing of file categories to be destroyed will be circulated to all managers thirty days prior to destruction for review and comment. The actual listing of records destroyed will be maintained permanently for future reference. Destruction of the files will be performed by an independent, outside service for shredding and disposal. Disposal of records into the company's general trash service is not allowed.
3.3
References: (AMERICANS LAW NEED NOT TO BE A PART OF NON US COMPANIES) A. HEALTH INSURANCE PORTABILITY ACCOUNTABILITY ACT (HIPAA) The Standards for Privacy of Individually Identifiable Health Information (the Privacy Rule) creates national standards to protect individuals' personal health information and gives patients increased access to their medical records. As required by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Privacy Rule covers health plans, health care clearinghouses, and those health care providers who conduct certain financial and administrative transactions electronically. Most covered entities (certain health care providers, health plans, and health care clearinghouses) must comply with the Privacy Rule by April 14, 2003. Small health plans have until April 14, 2004 to comply with the Rule. Note: Employment records maintained by a covered entity in its capacity as an employer are excluded from the definition of protected health information. The modifications do not change the fact that individually identifiable health information created, received, or maintained by a covered entity in its health care capacity is protected health information. B. AGE DISCRIMINATION IN EMPLOYMENT ACT (ADEA) ADEA applies to employers with 20 or more employees. If an EEOC charge or lawsuit is filed, keep records until final disposition of the charge or lawsuit. Otherwise, ADEA compliance suggests keeping basic employee files from one to three years as listed: Payrolls or other records (for temporary and permanent positions) for three years. Basic employee information such as employees names, addresses, birth dates, occupations, rates of pay, and weekly compensation for three years. Applications and personnel records relating to promotion, demotion, transfer, selection for training, layoff, recall or discharge for one year.
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Job advertisements and postings for three years. Copies of employee benefit plans, seniority and merit systems must keep on file for the full period the plan or system is in effect and for at least one year after its termination
C.
AMERICANS WITH DISABILITIES ACT (ADA) ADA applies to employers with 15 or more employees. If an EEOC charge or lawsuit is filed, keep records until final disposition of the charge or lawsuit. Otherwise, ADA compliance suggests keeping employment applications and other personnel records including promotions, transfers, demotions, layoffs, and termination or requests for reasonable accommodation for at least 1 year from the making of the record or the personnel action.
D.
CIVIL RIGHTS ACT OF 1964 Applies to employers with 15 or more employees. If an EEOC charge or lawsuit is filed, keep records until final disposition of the charge or lawsuit. Otherwise, basic non-discrimination compliance suggests keeping employment applications and other personnel records including promotions, transfers, demotions, layoffs, and termination or any EEO-1 Reports for at least one year from the making of the record or the personnel action. If an employee is involuntarily terminated, his/her personnel records must be retained for one year from the date of termination.
E.
EMPLOYEE RETIREMENT INCOME SECURITY ACT (ERISA) The ERISA reporting and disclosure obligations apply to all pension and welfare plans including summary plan descriptions, annual reports, reportable events, and plan termination, unless the company plan is exempt under ERISA. ERISA suggests the company should maintain all reports, documents, information, and materials for a minimum of six years in order to disclose and or support all transactions to participants and beneficiaries (and report to certain governmental agencies), as requested or needed.
F.
EMPLOYEE POLYGRAPH PROTECTION ACT All polygraph test results and reasons for administering the test should be kept for three years.
G.
EQUAL PAY ACT Payroll records including time cards, wage rates, deductions from wages, and records explaining the difference in wage rates between men and women in similar positions should be kept for three years.
H.
EXECUTIVE ORDER 11246 Applies to federal contractors and requires the preparation of affirmative action plans. Affirmative action plans must be updated annually and retained for two years along with all applications and other personnel records that form the basis of
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the companys employment decisions. Generally, personnel and employment records must be retained for two years. I. FAIR LABOR STANDARDS ACT (FLSA) FLSA applies to employers engaged in or employees who work in interstate commerce and suggests the following records are retained for three years: Payroll and other records containing employees name, birth date, gender, and occupation. Employees beginning of workweek and time employee begins work. Regular rate of pay or other basis of payment. Hours worked per day and for workweek. Daily and weekly straight time earnings. Deduction from wages. Total wages per pay period. Date of payment and the pay period covered. For exempt professional, executive and administrative employees, and those employed in outside sales, the employer must maintain records that reflect basis on which wages are paid to permit calculations of the employees total remuneration. In addition, employers must keep for at least two years all records (including wage rates, job evaluations, seniority and merit systems, and collective bargaining agreements) that explain the basis for paying different wages to employees of opposite sexes in the same establishment.
J.
FAMILY AND MEDICAL LEAVE ACT (FMLA) FMLA applies to employers with 50 or more employees within a 75 mile radius and whose employee must have worked for at least one year and accumulated at least 1,250 hours of service with the employer during the previous year. FNLA suggests the following records are retained for 3 years Basic employee data including name, address, occupation, rate of pay, terms of compensation, daily and weekly hours worked per pay period, deductions from wages, and total compensation. Dates of leave taken by eligible employees. For intermittent leave, the hours of leave. A copy of employee notices and documents describing policies and practices regarding leave. Records of any dispute regarding the designation of leave.
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K.
IMMIGRATION REFORM & CONTROL ACT (IRCA) IRCA applies to all employers and requires a signed Form I-9 is retained for three years after the date of hire and at least one year after termination.
L.
OCCUPATIONAL SAFETY & HEALTH ACT (OSHA) OSHA applies to employers with 10 or more employees and suggest that the log of occupational injuries and illnesses is retained for five years. All other records should be retained for at least 30 years after employee separation. Other records include: Occupational injuries and illnesses. The annual summary of injuries and illnesses. Medical records and records of exposure to toxic substances.
M.
REHABILITATION ACT OF 1973 Applies to federal contractors. If a charge or lawsuit is filed, keep records until final disposition of the charge or lawsuit. Otherwise, basic compliance suggests keeping personnel and employment records including requests for accommodation, physical exams, job advertisements and postings, applications, resumes and records regarding hiring, assignments, promotions, demotions, transfers, layoffs, terminations, rates of pay and selection for training for two years (only 1 year if contractor has less than 150 employees or a federal contract of $150,000 or less). Note: Affirmative action plans also may have to be maintained by the employer
N.
RIGHT TO FINANCIAL PRIVACY ACT The act establishes specific procedures and exceptions concerning the release of customer financial records to the federal government. It provides customers of financial institutions with a right to expect that their financial activities will have a reasonable amount of privacy from federal government scrutiny.
O.
GUIDE TO RECORD RETENTION REQUIREMENTS A good source of federal retention requirements is the "Guide to Record Retention Requirements" published by the Office of the Federal Register National Archives and Records Administration. It can be purchased from the U.S. Government Printing Office in Washington DC. Additional sources of information include: IRS regulations, state and local government retention requirements or the AICPA (American Institute of Certified Public Accountants) Filing and Record Retention Procedures Guide.
P.
IRS REVENUE PROCEDURE 98-25 RECORDS RETENTION The Income Tax Regulations require that, except for farmers and wage-earners, any person subject to income tax, or any person required to file an information return with respect to income, must keep such books and records, including inventories, as are sufficient to establish the amount of gross income, deductions, credits, or other matters reported. The books or records required by must be kept
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available at all times for inspection by authorized internal revenue officers or employees, and must be retained so long as the contents thereof may become material in the administration of any internal revenue law. Note: Section 6.01 requires taxpayers to maintain and make available documentation of the business processes that (1) create the retained records, (2) modify and maintain its records, (3) satisfy the requirements of section 5.01(2) of the procedure and verify the correctness of the taxpayer's return, and (4) evidence the authenticity and integrity of the taxpayer's records. Section 6.02 sets forth four elements that the documentation required under section 6.01 must establish: (1) the flow of data through the system, (2) internal controls that ensure accurate processing, (3) internal controls that prevent unauthorized record changes, and (4) charts of account. Section 6.03 sets forth six specific types of documentation for each retained file: (1) record formats, (2) field definitions, (3) file descriptions, (4) evidence that periodic checks are undertaken to ensure that data remains accessible, (5) evidence that the records reconcile to the taxpayer's books, and (6) evidence that the records reconcile to the taxpayer's return.
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Revision History: Revision 0 Date 10/13/20 13 Description of changes Initial Release Requested By
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G&A102 Ex1 MASTER FILE GUIDE INDEX

AC AC-100 AC-200 AC-300 310 320 330 340 350 360 370 380 390 AC-400 AC-500 AC-600 AC-600 AC-700 AC-800 AC-900 AD AD-100 AD-200 AD-300 AD-400 AD-500 AD-600 AD-700 AD-800 AD-900 BU BU-100 BU-200 BU-300 BU-400 BU-500 BU-600 BU-700 BU-800 BU-900 ACCOUNTING Accounts Administration Financial Planning General Accounting Checking Account Register Accounts Payable Accounts Receivable Payroll Local, State, Federal taxes {FUTA, FICA, etc.} Banking Services Property Inventory/Fixed Assets Corporate Accountant Corporate Tax Information File Employee Benefit Programs Employee Expense Accounts Petty Cash Management Corporate Loan Management Grants Account Management Purchasing Open ADMINISTRATION General Organizational Manual Organizational Charts Corporate Correspondence Manual Policies and Procedures Records Management and Retrieval Chief Executive Officer Administrative Memorandums Interoffice Staff Administrative Memorandums Open BUSINESS Corporate Business Plan Business Project Management Sub-Corp Business Project Management Business Executive Summaries Sub-Corp Business Executive Summaries Domestic Business Development International Business Development - Europe International Business Development - Asia International Business Development - Canada/S. America
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CS CS-100 CS-200 CS-300 CS-400 CS-500 EN EN-100 EN-200 EN-300 EN-400 EN-500 EN-600 EN-700 EN-800 EN-900 IN IN-100 IN-200 IN-300 IN-400 IN-500 IN-600 IN-700 IN-800 IN-900 LG LG-100 LG-200 LG-300 LG-400 LG-500 LG-600 LG-700 LG-800 LG-900
COMPUTER INFORMATION SYSTEMS General Equipment Operation and Maintenance Training in Systems Operation Open ENGINEERING General Administration Research and Development Chemical Engineering Graphics and Technical Drawings Product Information and Technical Analysis Product Raw Materials Data Engineering Safety Data Product Test Programs Industry Information INSURANCE General Administration of Insurance Plant and Equipment Policies Corporate Officer Policies Product Liability Policies Corporate Vehicles Policies Health Program Policies Life Insurance Programs for Employees Off Site Special Coverage Open LEGAL General Reports Contracts Litigation Disputes Legal Personnel Issues Agreements/Partnerships Product Liability Open
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MA MA-100 MA-200 MA-300 MA-400 OF OF-100 OF-200 OF-300 OF-400 OF-500 OF-600 OF-700 OF-800 OF-900 OP OP-100 OP-200 OP-300 OP-400 OP-500 OP-600 OP-700 OP-800 OP-900 PE PE-100 PE-200 PE-300 PE-400 PE-500 PE-600 PE-700 PE-800 PE-900
MARKETING General Reports / Studies Marketing Plans Customer Relations OFFICE MANAGEMENT General Procedures Equipment / Furnishings / Telecommunications Information Processing/Communications Procedure Property Lease/Management Agreement Fax/Reproduction/Printing Procedures Protocol to Visitors Maintenance Open OPERATIONS General Daily Reports Weekly Reports Monthly Reports Quarterly/Annual Reports Performance Analysis Project Management Charts and Plans Manufacturing and Production Open PERSONNEL General Reports Employee Records Organizational Charts Recruiting Training Benefit Programs Open Open
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PP PP-100 PP-200 PP-300 PP-400 PP-500 PR PR-100 PR-200 PR-300 PR-400 PR-500 RG RG-100 RG-200 RG-300 RG-400 RG-500 RG-600 RG-700 RG-800 RG-900 SL SL-100 SL-200 SL-300 SL-400 SL-500
PATENTS, PERMITS AND PLANS General Reports Licenses/Permits/Plans Open Open PUBLIC RELATIONS General Reports and Studies Corporate Releases List of Clients/Industry Contacts Open REGULATORY DATA General Reports Correspondence Acts/Laws/Bills Regulations Agreements Guidelines/ Policies/ Resolutions International Regulations Open SALES General Domestic Business Development International Business Development Plans and Budgets Corporate Sales Procedures and Project Management
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G&A102 Ex2 RECORDS RETENTION PERIODS

Accident reports and claims (settled cases)..........................................................7 years Accounts payable ledgers, schedules and trial balances .......................................7 years Accounts receivable ledgers, schedules and trial balances ...................................7 years Assignments..........................................................................................................3 years Audit reports of accountants ...........................................................................Permanently Bank reconciliations .............................................................................................1 year Bank statements, cancelled checks, and deposit slips ..........................................7 years Bills of lading .......................................................................................................3 years Capital stock and bond records .......................................................................Permanently Cash books ......................................................................................................Permanently Cash receipts and disbursements .........................................................................7 years Chart of accounts ............................................................................................Permanently Checks (cancelled, all other) ................................................................................7 years Checks (cancelled, for important payments, i.e. taxes, property purchases, special contracts, etc. File checks with the transaction papers).......................Permanently Construction documents...................................................................................Permanently Contracts and leases (expired) .............................................................................7 years Contracts and leases still in effect...........................................................Expiration +7 years Corporate records and minutes .......................................................................Permanently Correspondence (legal and important matters only) ........................................Permanently Correspondence general ......................................................................................3 years Credit Applications (Consumer) ............................................25 Months (after notification) Credit Applications (Business) ......................................................1 year (after notification) Deeds, mortgages, and bills of sale ..................................................................Permanently Depreciation schedules.....................................................................................Permanently Duplicate deposit slips...........................................................................................1 year Electronic fund transfer documents......................................................................7 years Employee personnel records (after termination)...................................................7 years Employment applications .....................................................................................3 years Expense analyses and Expense distribution schedules..........................................7 years Expired contracts and notes receivable ................................................................7 years Expired purchase contracts ..................................................................................7 years Federal, state and local tax returns ..................................................................Permanently Financial statements (end-of-year trial balances) .............................................Permanently Fixed asset records and appraisals ...................................................................Permanently Forms W-4 ...........................................................................................................7 years Garnishments .......................................................................................................3 years General Ledgers (end-of-year trial balances) ...................................................Permanently I-9s (after termination)..........................................................................................1 year Insurance records, current accident reports, claims, policies, etc.....................Permanently Interim and year-end financial statements and trial balances............................Permanently Inventories of products, materials, and supplies ..................................................7 years
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Invoices 7 years Journals ............................................................................................................Permanently Licenses............................................................................................................Permanently Loan documents, notes.....................................................................................Permanently Minute books of directors and stockholders, including bylaws and charter.....Permanently Monthly trial balances ......................................................................................Permanently Notes receivable ledgers and schedules ...............................................................7 years OSHA logs...........................................................................................................5 years Paid bills and vouchers ........................................................................................7 years Payroll journals ....................................................................................................7 years Payroll records and summaries ............................................................................7 years Payroll reports (federal & state) ..........................................................................7 years Perpetual inventory records .................................................................................7 years Petty cash vouchers .............................................................................................7 years Physical inventory records ...................................................................................7 years Physical inventory tags ........................................................................................7 years Plant cost ledgers .............................................................................................Permanently Polygraph test results and reasons for test............................................................3 years Property appraisals by outside appraisers ........................................................Permanently Property records including costs, depreciation schedules, blueprints, plans.....Permanently Property titles and mortgages ..........................................................................Permanently Purchase journals .................................................................................................7 years Purchase orders ...................................................................................................7 years Receiving sheets....................................................................................................1 year Requisitions .........................................................................................................7 years Sales journals .......................................................................................................7 years Sales records.........................................................................................................7 years Savings bond registration records of employees ..................................................7 years Scrap and salvage records (inventories, sales, etc)...............................................7 years Shipping tickets ...................................................................................................3 years Stock and bond certificate (cancelled) ...................................................................1 yr Stockroom withdrawal forms ..............................................................................7 years Subsidiary ledgers ................................................................................................7 years Tax returns and worksheets, revenue agents reports and other documents....Permanently Time books/cards .................................................................................................7 years Trade mark registrations...................................................................................Permanently Uncollectible accounts and write offs ..................................................................7 years Voucher for payments to vendors, employees, etc. (includes all allowances and reimbursement of employees, officers)....................7 years Voucher register and schedules ...........................................................................7 years W-4 forms.............................................................................................................4 years Workmans comp documents..............................................................................11 years
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Accounting Policies, Procedures and Forms

SOP # Revision: Effective Date: Title: Policy:

Prepared by: Approved by: