AMPER, SA and Subsidiaries Consolidated Financial Statements for ...

changes approved, as well as formally notifying those affected and – through the
corresponding updated organisational diagrams – the rest of the entity, and also updating any
documentation that describes work positions.
Finally, and as regards the process of drafting financial information, the performance of
reviewing the organisational structure is the responsibility of Financial Management in
conjunction with the Corporate Head of Human Resources, and is subject to the final approval
of the Group’s Managing Director.
If the following elements are in place – especially with regard to the process of drafting
financial information:
- Code of conduct: approving body, degree of dissemination and instruction, principles
and values included (stating whether there is specific mention of the records for
operations and the drafting of financial information), body responsible for analysing
non-compliance and proposing corrective actions and penalties.
The Amper Group has a Code of Values (Code of Conduct), which was approved in November
2009 by the Management Committee, and which is available through the company intranet.
The Amper Code of Values applies to all of the people working in the Group. Such people
receive a copy of the Code, as well as having it available to them at all times in both the
internal regulations and on the company website.
The Code is subject to updates whenever circumstances require. We are currently working on
an update of the Code of Values to bring it into line with the new requirements and the new
dimension of the Amper Group.
The Code establishes the following obligation as regards financial information and the
recording of operations: the commitment to provide information that is exhaustive, truthful,
accurate and clear in order to ensure compliance with any requirements of the authorities and
the market, and to ensure that all financial transactions are correctly and properly recorded in
said books.
The Auditing Committee will, through the Internal Auditing Management, direct and coordinate
any investigations carried out regarding possible breaches, proposing, where applicable, any
corrective actions and/or penalties that might apply.
- Channel for complaints, allowing for the communication of potentially significant
irregularities, especially financial and accounting irregularities, as well as possible
breaches of the code of conduct and any irregular activities carried out by the
organisation, specifying whether such breaches involve confidential information.
Amper has implemented and encourages the use of a complaints channel to gather, among
other things, information on potentially significant irregularities in the organisation, breaches of
internal and external regulations, and any irregular accounting or financial practices, as well as
breaches of the Code of Values.
The complaints channel is confidential, and provides the possibility of lodging complaints in two
different ways: by email or on hard copy to be deposited in the complaints boxes available at the
Group’s different premises.
The Internal Auditing Department, as the body responsible for implementing the decisions of the