100 % FUTURE - ALNO

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III. KEY CHARACTERISTICS OF THE ACCOUNTING-RELATED INTERNAL CONTROLLING AND
RISK MANAGEMENT SYSTEM PURSUANT TO SECTIONS 289 (5) AND 315 (2) NO. 5 OF THE GER-
MAN COMMERCIAL CODE (HGB)
According to the reasons given for the German Accounting Law Modernization Act (BilMoG) that
came into force on May 29, 2009, the internal controlling system comprises the principles, procedures
and measures to ensure the effectiveness and economic efficiency of the accounting system,
proper accounting approaches, and compliance with the relevant legal regulations. This also includes
the Group controlling function to the extent that it relates to accounting. As is the case with the
latter, and as part of the internal controlling system, the risk management system with respect to
the accounting process relates to controlling and supervisory processes for accounting, particularly
in the case of trade law balance sheet items that report the company’s risk hedging measures.
PRESENTATION AND EXPLANATION OF THE KEY CHARACTERISTICS OF THE INTERNAL CONTROLLING
SYSTEM AND RISK MANAGEMENT SYSTEM WITH RESPECT TO THE ACCOUNTING PROCESS
The key characteristics of ALNO AG’s internal controlling system and risk management system with
respect to the (Group) accounting process can be described as follows:
• The ALNO Group is distinguished by clear organizational, corporate, and controlling and supervisory
structures.
• The company operates planning, reporting, controlling and early warning systems and processes
across the Group to ensure comprehensive analysis and steering of earnings-relevant risk factors
and going-concern risks.
• The functions in all areas of the accounting process (e.g. financial accounting and controlling) are
clearly allocated.
• The IT systems deployed in the accounting function are protected against unauthorized access.
• Recourse is predominantly made to standard software in the area of the financial systems utilized.
• An adequate system of internal guidelines (consisting of risk management and guidelines that are
valid across the Group, among other items) has been set up, and can be adjusted as required.
• The departments that are involved in the accounting process comply with quantitative and qualitative
requirements.
• The completeness and correctness of accounting data are regularly checked using random samples
and plausibility checks, as well as through individual controls and the software that is deployed.
A risk controller has been installed at all segmental levels who manages the risk management
process at the segment level, and to subject stated to plausibility checks.
• For the purpose of consolidation, ALNO AG has established processes to intra-Group receivables
and liabilities, and income and expenses.
• Recourse is made to external services (e.g. actuaries, valuation surveyors etc) for significant
complex balance sheet questions that are subject to discretionary assessment.
• Significant processes that are relevant to accounting are subject to regular analytical checks.
• The “two sets of eyes” principle is applied consistently to all accounting-relevant processes.
• The Group controlling function checks accounting-relevant processes.
• Among other matters, the Supervisory Board concerns itself with significant questions relating to
accounting, risk management, the audit mandate and its focal points.