Y'all recall the push for Ethics and Reporting Training and Emails in October 2021? Well, it was a failed attempt to cover up missteps in Avaya's Code of Conduct, Ethics and Compliance
Direct from SEC filing 11/29/22
"Despite
steps the Board took to ensure the concerns asserted in the email were fully examined, the Company did not appropriately log the email in accordance with the Company’s whistleblower policy, nor did the Company convey to certain members of management or the Company’s independent registered public accounting firm the existence of the email or the fact that the Board had determined to undertake an independent investigation into the matter As a result of the failure to appropriately communicate and log the email and related independent investigation, the Company determined to re- assess the effectiveness of its ICFR as of SEPT 30, 2021, as reported in the Company’s 2021 Form 10-K."
[ ICFR is one element of the broader concept of internal control defined by COSO, which provides a commonly used framework to assist companies in structuring and evaluating controls comprised of five integrated components: control environment. risk assessment. control activities. information and communication]