Castellano and Lightle suggest that a “cultural audit” would provide a means for

assessing the tone at the top and the attitude toward internal controls and ethical
decision-making. They believe that such an audit can play an important role in
helping management shape an ethical climate within the organization and in helping
directors and auditors assess the effectiveness of internal controls. The external
auditors would include in their internal control assessments and risk management
profiles a process designed to assess the tone at the top and its impact on a
company’s culture. The authors do not identify issues to be raised or specific
questions to address in the cultural audit, but do point out that an assessment of the
situational pressures should be an important part of the process.