Re-published in 2003 following the Higgs Report and the Smith Guidance on Audit Committees. The Code raises corporate governance standards for listed companies, and incorporates the Turnbull report on internal control, the Smith guidance and good practice guidance from Higgs. Directors should at least annually conduct a review of the effectiveness of all internal controls including financial, operational, compliance and risk management. The FSA’s Listing Rules underpin the Code by obliging companies to state in their annual reports how they have applied the principles of the Code (www.frc.org.uk).