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MICHELIN - 2008 ANNUAL REPORT

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DESCRIPTION OF INTERNAL CONTROL PROCEDURES REGARDING<br />

ACCOUNTING AND FINANCIAL INFORMATION PRODUCTION AND<br />

PROCESSING<br />

Description<br />

The Managing Partners are responsible for publication of<br />

reliable financial and accounting information. The accounting,<br />

consolidation, management control and financial communication<br />

departments: all play a part in the process of producing such<br />

financial information. This report was discussed with the<br />

Managing Partners and at a Supervisory Board meeting.<br />

Within the Group’s organization, the accounting teams mainly<br />

report to the Geographic Zones, while management controllers<br />

are typically attached to the different Product Lines.<br />

Corporate and consolidated financial statements are produced on<br />

a monthly basis, in conditions similar to the year-end closing.<br />

Necessary internal control procedures governing production of<br />

reliable accounting information are in place at local level. These<br />

include in particular physical inventory (for both fixed assets<br />

and inventory), segregation of duties and reconciliation with<br />

independent information sources.<br />

A dedicated team is in charge of standardizing Group accounting<br />

policies and of monitoring the development of new standards,<br />

updating applicable accounting reference documentation for all<br />

Group subsidiaries and following up all of the issues raised by<br />

the latter.<br />

General accounting and management accounting data are<br />

submitted simultaneously by the subsidiaries. The systems verify<br />

the consistency of the main aggregate figures (sales, operating<br />

income…).<br />

General accounting data received from the subsidiaries is<br />

controlled for consistency and consolidated into Group financial<br />

statements.<br />

Monthly changes in consolidated financial statements are carefully<br />

analyzed. The gap between plan and actual data, drawn from<br />

management information, forms the subject of monthly detailed<br />

review by the Group’s Executive Council and Product Lines.<br />

At each interim and annual closing, Geographic Zone Heads<br />

certify in writing that, to the best of their knowledge, the<br />

accounts submitted by the companies in their respective Zones<br />

are a fair reflection of their operations. The statement covers all<br />

the compliance issues which, if not respected, could significantly<br />

impact financial statements (applicable law and agreements) as<br />

well as relevant particular events (litigation, fraud).<br />

The Internal Audit Group Service proposes to the Managing<br />

Partners and carries out yearly a number of specific missions to<br />

control the Group’s financial and accounting information.<br />

The Group’s Statutory Auditors, as part of the organization of<br />

annual and consolidated financial statements auditing, direct the<br />

local auditors to apply the international auditing standards.<br />

The review of consolidated financial statements is carried out<br />

jointly by Group Statutory Auditors and local auditors. Their<br />

collaboration takes the form of audit instructions, drawing up<br />

and analysis of audit questionnaires, emission by local auditors of<br />

a review certificate for the period to June 30, and an audit report<br />

to December 31, complemented by ad-hoc control reports and<br />

regular communication throughout the year on specific points or<br />

topical issues.<br />

Group Statutory Auditors’ operations are complemented by<br />

yearly visits to a number of sites worldwide. On these occasions,<br />

the Statutory Auditors meet their local counterparts and gain a<br />

clear understanding of some of the issues at hand.<br />

The Investor Relations Department, which forms an integral<br />

part of the Group’s Finance Department, is responsible for the<br />

preparation and distribution throughout the financial community<br />

of the Group’s financial communication. Financial communication<br />

takes three main forms:<br />

● The Annual Report and the Reference Document;<br />

● The financial press releases;<br />

● Support documentation produced for meetings with analysts<br />

and investors.<br />

The Investor Relations Department in consultation with the<br />

Group’s Legal Department, and after validation by the Managing<br />

Partners, coordinates publication of the Annual Report and the<br />

Reference Document. Both Reports include contributions from<br />

different experts in the Group’s main fields of operation, thus<br />

ensuring they are information-rich and quality documents. The<br />

Annual Report and the Reference Document are reviewed and<br />

validated by the Managing Partners before publication.<br />

Financial communications and press releases are systematically<br />

reviewed by the Head of Investor Relations; those in connection<br />

with the Group’s results are also submitted to the Supervisory<br />

Board for review.<br />

Documents produced for analyst and investor meetings are<br />

drawn up by the Investor Relations Department and approved by<br />

the Managing Partners.<br />

Evaluation of the Processes Impacting the Reliability<br />

of Financial Information<br />

The financial and accounting information carried in Group<br />

consolidated financial statements is analyzed for materiality and<br />

level of risk based on different criteria (underlying operation<br />

complexity, level of decentralization…).<br />

A sample of companies representing around 80% of Group<br />

accounting balances was first selected. The sample covers<br />

all Geographic zones and operations (industrial, trading and<br />

distribution networks).<br />

15 key processes were initially identified for Michelin Group as a<br />

whole. They are gradually integrated into the approach due to be<br />

completed in 2010.<br />

The approach adopted for the 2004-2007 phase<br />

A group of 6 processes was selected for the first phase evaluation.<br />

These include the following cycles: Purchasing (from purchase to<br />

pay), Sales (from order to cash) and Inventory Management, as<br />

well as Group Financing, Financial Risk Management, Intra-Group<br />

Transactions and Commitments Identification. The Group’s<br />

Internal Control operations to cover the IT management and<br />

administration issues underlying the above processes are also<br />

part of the scope.<br />

Other Information<br />

Additional Information Consolidated Financial Statements The Managing Partners’ Report Michelin at a Glance<br />

77

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