We have strict procedures for internal and disclosure controls and auditor independence. The Disclosure Committee monitors the procedures established by the company and advises the Executive Committee to ensure adequate and timely disclosure of material financial and non-financial information.
An Internal Control committee is responsible for maintaining the company’s internal control framework. The company-wide internal control self-assessment process was improved in 2012 and the outcome was presented to the Audit Committee. An area of continued focus in 2012 has been the control standards for our key IT systems and to make more use of automated controls in these systems.
Synergies are created between the internal control and compliance function, where the company-wide internal control self-assessment tool is strengthened by a company-wide compliance monitoring tool to discuss and monitor progress with respect to compliance-related issues. More detail on the so-called non-financial letter of representation process is available in the chapter.