Non-financial letter of representation
Annually, management verifies and confirms that they comply with laws and internal directives and rules through the NFLoR process. Exceptions must be reported and actions must be planned and documented. The NFLoR process starts deep in the organization; results are rolled-up to leadership of business units, strategic marketing units, functions and Business Areas. The results are discussed in review meetings between each of the business and functional leaders and their responsible Executive Committee member, in the presence of the Director of Compliance and Legal Counsel. At the review meetings, risks and possible weaknesses in the compliance and control framework are discussed and actions are agreed upon. The responsible Executive Committee member then reports the results of the review meetings to the CEO and the General Counsel, who review the same. A final report is presented to the Executive Committee, the Audit Committee of the Supervisory Board and to the external auditor. The outcome of this NFLoR process, in combination with the internal control self-assessment process and internal audit results, forms a basis for the Statement of the Board of Management in this Report 2015.
The General Counsel reports to the Executive Committee and the Audit Committee of the Supervisory Board on important compliance matters, developments and initiatives. Twice per year, the General Counsel submits an extensive written report on the progress of all compliance programs and on compliance matters from the preceding period to the Executive Committee and to the Audit Committee of the Supervisory Board, who review the same and agree on any necessary actions.
Competition Law Compliance Declaration
Employees who meet certain criteria, such as having contact with customers or suppliers or managing those who have, confirm their compliance with competition laws as articulated in our competition law compliance manual through our annual Competition Law Compliance Declaration program. In 2015, over 13,000 designated employees signed this declaration. The declaration reminds employees of the importance of complying with competition laws, requests their confirmation of compliance and urges them to disclose any matters of concern. This is an established process in the company. In 2015, a video message was added to the declaration to re-emphasize the importance of competition law compliance and to remind employees to contact the Compliance function in case of doubt.