101. Letter, 20 July 1992, from David Fifield.
Comments on ownership models, accountancy work, short-termism.
Comments in detail on sections of the draft report, approving the self regulation approach, questioning statements of compliance requirement, commenting on the role of non-executive directors, remuneration, auditing and shareholders' role.
103. Letter, 20 July 1992, from Institute of Business Ethics.
Comments on responsible leadership by boards and their remuneration, independence of non-executive directors.
104. Letter, 20 July 1992, from Andrew Robb, Pilkingon plc.
Comments on potential two-tier boards, non-executive directors, auditing.
105. Sir Adrian Cadbury's letter to Law Society Gazette, 20 July 1992.
Response to negative comments about likely compliance and shareholders representatives on the Board.
106. Letter, 21 July 1992, from Paul Girolami, Glaxo.
Comments on directors and non-executive directors roles, auditors and Code of Best Practice.
107. Letter, dated 21 July 1992, from the Foreign and Colonial Investment Trust PLC.
Comments on 'going concern', and number of non-executive directorships.
108. Letter, 21 July 1992, from Slough Estates plc.
Comments on the Code of Best Practice, financial reporting and possible regulation.
About the publication of the final report or separate code and involvement of commercial publishers.
110. Letter and comments, dated 23 July 1992, from Blenyth Jenkins, the Institute of Directors.
Comments in the context of the wider context of corporate governance, while focussing on internal control, self-regulation and enforcement, interim financial reporting and auditing.
Comments on the issue of independence of non-executive directors.
112. Comments, dated 23 July 1992, from the Chartered Institute of Management Accountants.
Comments on the separation of roles, non-executive directors , internal control systems, audit and remuneration committees and various aspects of auditing.
113. Letters from Richard Lloyd, Chairman of Vickers, 23 July 1992.
Letter to Nigel Peace gives specific comments on the draft report which is generally welcomed.
114. Comments, dated 24 July 1992, from Catherine Gowthorpe, Lancashire Polytechnic Business School.
Comments at length on non-executive directors - the qualities required, their financial interests and selection. Also includes comments on the board and in detail on aspects of auditing.
115. Letter and report, dated 24 July 1992, from the Institute of Internal Auditors.
Comments on codes for standards of conduct, the role of internal auditors and an auditing committee, fraud and compliance with the code.
116. Letter, dated 28 July 1992, from Serious Fraud Office.
Comments on auditors' statutory protection and the role of non-executive directors.
117. Letter, dated 28 July 1992, from BDO Binder Hamlyn.
Comments on Code of Best Practice, audit committees, directors' contracts, reporting and aspects of auditing.
Comments on the requirement for interim financial reports to include balance sheets, access to professional advice for non-executive directors and the roles of directors at an AGM.
119. Letter, dated 28 July 1992, from Grant Thornton.
Comments on implementation by self-regulation vs legislation, applicability to smaller companies, non-executive directors and going concern.
120. Letter, dated 28 July 1992, from McKenna & Co.
Letter covers enforcement of the code, the role of non-executive directors, separation of the roles of Chief Executive and Chairman, shareholders' role and that of the auditors with respect to fraud.
121. Letter, dated 29 July 1992, from TF Mathews, Building Societies Commission.
Largely concerns building societies and the ratio of executive to non-executive directors.
122. Letter, dated 29 July 1992, from David Jinks, Cadbury Schweppes.
Comments on potential for two-tier boards, enforcement, involvement of investors, various aspects of auditing, going concern and disclosure of directors' remuneration.
Includes a paper entitled 'Corporate governance and corporate control: self-regulation or stautory codification? A comment on the draft report of the Committee on the Financial Aspects of Corporate Governance.
Comments on board of directors, non-executive directors, audit committees, reporting and the involvement of shareholders.
125. Letter, dated 29 July 1992, from JC Kay, Gaskell plc and comments on the draft report.
Comments on alternative accounting treatments, application to smaller companies and non-executive directors.
126. Letter, dated 29 July 1992, from JNC James, Grosvenor Estate Holdings.
Comments on non-executive directors access to independent financial advice.
127. Letter, dated 29 July 1992, from LE Linaker, IFMA and list of association members.
The comments raise the issue of compliance for smaller companies and the possibility of distinctions between executive and non-executive directors.
Comments on contracts in corporate operations, accounting techniques and disclosure.
129. Letter, dated 29 July 1992, from CA Mallin, University of Liverpool.
Comments on non-executive directors' roles and independence, board remuneration and auditing.
130. Letter, dated 30 July 1992, from JD Traynor, CRH plc.
Expresses concerns about emphasis on control and monitoring, and the influence of accountants and auditors. It continues to make specific points.
The document gives detailed comment on specific paragraphs in the draft code.
132. Letter, dated 30 July 1992, from Lord Toombes of Brailes with further comments.
Rolls-Royce's comments on potential differences of responsibilities between non-executive and executive directors.
133. Letter, dated 30 July 1992, and comments from NN Graham Maw, Rowe & Maw.
Comments on the Code of Best Practice and sets out the author's own code besides commenting on other issues in the report, especially enforcement of the Code.
134. Letter, dated 30 July 1992, from RWD Hanson, Hardys & Hanson plc.
Comments on the cost of implementation for smaller companies.
Comments on the Terms of Reference and standards of practice in unlisted companies,in addition to specific points.
136. Letter, dated 30 July 1992, from PM Elliott, English China Clays.
Comments on various committees, financial reporting, auditing and the going concern disclosure.
137. Letter, dated 30 July 1992, and comments from Anthony Williams, Hay Management Consultants.
Comments on disclosure of remuneration, performance pay and access to the Audit Committee.
138. Letter, dated 30 July 1992, from Pannell Kerr Forster.
Among topics covered are: unitary boards, audit committees, financial reporting, auditing and going concern.
Welcomes the code and comments with concerns about possible two-tier board and time-limited contracts for non-executives.
These documents concentrate on auditing and its role in investment businesses. The Board supports the Auditing Practices Board, believing its primary function is to form and express an opinion.
141. Letter, dated 31 July 1992, and comments on the draft report from BT O'Driscoll, ICI Group.
The main comments relate to terms of reference of the Committee, internal control and internal audit.
142. Letter, dated 31 July 1992, from Sir Richard Greenbury.
Letter comments on board structure, especially unitary boards, the duties of directors to shareholders and the responsibilities of the external auditors.
143. Letter, dated 31 July 1992, from Sir Andrew Hugh Smith, London Stock Exchange.
Comments on statements of compliance with the code of best practice as an obligation but not a requirement of listing, responsibilities of the directors and financial reporting.
144. Letter, dated 31 July 1992, and comments from Stoy Hayward.
Comments on the draft report in detail on unified boards, separation of roles, board structures, non-executive directors, executive directors and directors' training. It also comments in some depth on audit committees, auditing, internal control systems and financial reporting.
145. Letter, dated 31 July 1992, from Clark Whitehill & Co.
The response comments on the application of the Code to smaller listed companies, the effectiveness of internal control and the Caparo case.
Comments on potential difficulties with a voluntary code and its review, for smaller companies, emphasis on non-executive directors and goes on to specific points.
147. Letter, dated 31 July 1992, and detailed comments from Arthur Andersen.
Contains detailed comments on the draft report. The main recommendation relates to the supervisory function of the board.
148. Letter, dated 31 July 1992, from Association of Investment Trusts.
Comments on the challenges that smaller companies may have in complying with the Code.
Includes summary of CBI response (13 points) and the full response under headings such as statement of compliance, review of code, board structures, separation of roles, non-executive directors, directors' remuneration, auditing and going concern. Also includes the draft response before approval by the CBI Council.
150. Letter, dated 31 July 1992, and comments from Coopers & Lybrand.
Main comments are on auditing, quality of boards and appointment to boards, monitoring compliance with the Code, two-tier boards and audit committees.