Kodak 2008 Annual Report Download - page 210

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IV. Tax Services
The Audit Committee believes that the independent auditor can provide traditional tax services to the Company such as U.S. and
international tax planning and compliance. The Audit Committee will not pre-approve the retention of the independent auditor in connection
with a transaction initially recommended by the independent auditor, the purpose of which may be tax avoidance and the tax treatment of
which may not be supported in the Code and related regulations.
V. Other Permissible Non-Audit Services
The Audit Committee may grant general pre-approval to those permissible non-audit services (other than tax services, which are
addressed above) that it believes are routine and recurring services, would not impair the independence of the auditor and are consistent
with the SEC’s rules on auditor independence.
A list of the SEC’s prohibited non-audit services is attached to the end of this policy as Attachment 1. The SEC’s rules and relevant
guidance should be consulted to determine the precise definitions of these services and the applicability of exceptions to certain of the
prohibitions.
VI. Pre-Approval Budgeted Amounts
Pre-approval budgeted amounts for all services to be provided by the independent auditor shall be reviewed and approved annually by the
Audit Committee. Any proposed services exceeding these levels or amounts shall require specific pre-approval by the Audit Committee.
On a quarterly basis, the Audit Committee will be provided with updates regarding actual projects and fees by category in comparison to
the pre-approved budget.
VII. Procedures
All requests or applications from the independent auditor to provide services that do not require specific approval by the Audit Committee
shall be submitted to the Corporate Controller and must include a detailed description of the services to be rendered. The Corporate
Controller will determine whether such services are included within the list of services that have received the general pre-approval of the
Audit Committee.
Requests or applications to provide services that require specific approval by the Audit Committee shall be submitted to the Audit
Committee for approval by the Corporate Controller.
VIII. Delegation
The Committee Chair is authorized to pre-approve specific engagements or changes to engagements when it is not practical to bring the
matter before the Committee as a whole.
Attachment 1
Prohibited Non-Audit Services
• Bookkeeping or other services related to the accounting records or financial statements of the audit client
• Financial information systems design and implementation
• Appraisal or valuation services, fairness opinions, or contribution-in-kind reports
• Actuarial services
• Internal audit outsourcing services
• Management functions
• Human resources
• Broker-dealer, investment adviser or investment banking services
• Legal services
• Expert services unrelated to the audit