As many Compliance Week readers know, our company—the $44 billion supermarket operator Royal Ahold, listed on the New York Stock Exchange—was accused in 2004 of filing materially false statements to the Securities and Exchange Commission. Since then, Ahold has succesfully completed its road to recovery, and improving our system of internal controls was crucial to doing so. As such, we believe we have a unique perspective on how best to accomplish the objectives of Sarbanes-Oxley. We’ve devised a new approach to SOX Section 404 management testing, and want to share our experience with fellow Compliance Week readers.