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

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Auditing Committee, is responsible <strong>for</strong> <strong>and</strong> is the only member of the organisation with access to<br />

the complaints, receiving the same through the channels put in place <strong>for</strong> that purpose. The<br />

confidentiality of complaints is guaranteed, as any personal data that appears on the complaint<br />

will be treated in accordance with the Organic Law on the Protection of Data 15/1999, being<br />

included in a file of internal complaints, with medium-level security measures, protected by<br />

In<strong>for</strong>mation Security Policies, to which only the Internal Auditing Department will have access.<br />

The Internal Auditing Department will study the suitability of the complaint <strong>and</strong> the need to<br />

investigate further within 15 days of receiving the complaint, <strong>and</strong> depending on the seriousness<br />

of the matter reported will decide whether or not to in<strong>for</strong>m the Auditing Commission.<br />

- Training programmes <strong>and</strong> regular refreshers <strong>for</strong> staff involved in preparing <strong>and</strong> revising<br />

financial in<strong>for</strong>mation, as well as in evaluating the ICSFI, these courses covering, at least,<br />

aspects like accounting st<strong>and</strong>ards, audits, internal control <strong>and</strong> risk management.<br />

Amper’s training policy is intended to structure training activity in order to cover employees’<br />

training <strong>and</strong> know-how requirements pursuant to the Group’s strategic objectives.<br />

As regards the ICSFI, the Amper Group has a new Training Policy that was approved in the last<br />

quarter of 2011 <strong>and</strong> which was specifically intended to ensure that all of the staff involved in<br />

preparing <strong>and</strong> reviewing financial in<strong>for</strong>mation have the training required to per<strong>for</strong>m their duties<br />

correctly.<br />

Said policy ascribes to the Economic-<strong>Financial</strong> Management the responsibility <strong>for</strong> ensuring that<br />

every fiscal year (in the last quarter of the previous fiscal year) the areas that require training are<br />

identified in order to ensure that the employees receive training on (i) new st<strong>and</strong>ards <strong>for</strong><br />

preparing financial in<strong>for</strong>mation that apply to the Group, (ii) modifications in the reporting<br />

regulations established by the capital market regulator as they apply to the Group, (iii)<br />

modifications in the Amper, S.A. internal reporting practices <strong>and</strong> procedures <strong>and</strong> (iv),<br />

modifications in Amper’s internal policies.<br />

Furthermore, this Training Policy establishes that there should be an individual training plan <strong>for</strong><br />

every member of staff involved in preparing <strong>and</strong> reviewing financial in<strong>for</strong>mation, which should be<br />

revised on an annual basis <strong>and</strong> which should indicate both the areas that training is<br />

recommended <strong>for</strong> <strong>and</strong> the specific training plan aimed at covering these.<br />

The Human Resources division of the Amper Group is responsible <strong>for</strong> monitoring the execution<br />

of training activities <strong>and</strong> individual training plans.<br />

Among the subjects taught in the 2011 fiscal year were the following training programmes:<br />

refresher course on IFRS st<strong>and</strong>ards <strong>and</strong> the General Accounting Plan, as well as general tax<br />

law <strong>and</strong> fiscal <strong>and</strong> accounting results <strong>for</strong> the 2011 fiscal year.

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