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

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A description of the scope of the evaluation of the ICSFI carried out during the tax year<br />

<strong>and</strong> of the procedure by which the person responsible <strong>for</strong> per<strong>for</strong>ming the procedure<br />

makes the results known, if the entity has an action plan that outlines possible<br />

corrective actions, <strong>and</strong> whether its impact on the financial in<strong>for</strong>mation has been taken<br />

into account.<br />

The scope of the evaluation carried out in 2011 included the supervision of the <strong>for</strong>mal<br />

implementation of the ICSFI on the part of the Economic-<strong>Financial</strong> Management, as well as the<br />

review of the key controls in the close of accounts process <strong>and</strong> the review of the procedures <strong>for</strong><br />

decision-making <strong>and</strong> estimates <strong>for</strong> all units in the Amper Group in Spain.<br />

With regard to the El<strong>and</strong>ia Group, the 2011 fiscal year was one of transition in terms of<br />

integrating Group processes, which will continue in 2012 <strong>and</strong> subsequent fiscal years. We<br />

should point out that the El<strong>and</strong>ia Group, which has a US parent company, was obliged to<br />

comply with the Sarbannes-Oxley (SOX) regulations.<br />

The 2011 evaluation process included analyses of controls <strong>for</strong> the areas that were considered<br />

relevant within the Group <strong>and</strong> checks to ensure that these operated as intended from the<br />

moment when they were <strong>for</strong>malised. We detected control flaws <strong>and</strong> opportunities <strong>for</strong><br />

improvement in the design <strong>and</strong> <strong>for</strong>malisation of some of the controls, leading to<br />

recommendations <strong>and</strong> suggestions <strong>for</strong> improved practices.<br />

The Internal Auditing service has a multi-year plan <strong>for</strong> supervising the ICSFI, which was<br />

approved by the Auditing Commission at the start of the 2012 fiscal year. The Plan includes the<br />

realisation of tests on areas that were considered relevant within the Amper Group, taking in the<br />

totality of the same during the three-year period covered by the Plan, excluding certain areas or<br />

processes that were considered to be especially relevant, among which were the process <strong>for</strong><br />

the closing of accounts <strong>and</strong> the review of decisions <strong>and</strong> estimates, the evaluation of which takes<br />

place on an annual basis.<br />

A description of the ICSFI supervision activities carried out by the Auditing Commission<br />

During the 2011 fiscal year the Amper Group implemented a supervision policy <strong>for</strong> its ICSFI,<br />

which establishes the criteria that such supervision should be ruled by, as well as the tasks<br />

reserved to the Auditing Commission <strong>and</strong> the activities delegated to the Internal Auditing<br />

service. Said policy reserves the following functions <strong>for</strong> the members of the Auditing<br />

Commission:<br />

i) Approval of the auditing plans<br />

ii)<br />

iii)<br />

iv)<br />

Establishing who is to execute them<br />

Evaluating whether work per<strong>for</strong>med is sufficient<br />

Revising <strong>and</strong> evaluating the results <strong>and</strong> considering the effect of the same on the<br />

financial in<strong>for</strong>mation<br />

v) Establishing the order of priority of the corrective actions <strong>and</strong> monitoring them<br />

The Internal Auditing managers are responsible <strong>for</strong> supporting the Auditing Commission in its<br />

supervision of the correct design, implementation <strong>and</strong> operation of the in<strong>for</strong>mation <strong>and</strong> internal<br />

control systems, including the ICSFI.<br />

The Internal Auditing reviews included total coverage of relevant risks <strong>for</strong> 2011 <strong>for</strong> all units in the<br />

Amper Group in Spain <strong>and</strong> placed special emphasis on risks of an operational-accounting<br />

nature. To this end, the Group has its own risk map, which allows it to plan the work to be<br />

per<strong>for</strong>med on all of the units in accordance with the main risk parameters <strong>for</strong> each process, unit<br />

or area, also facilitating the later development of the annual plan.

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