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The list of Key Internal Controls continues to grow. In 2011, the<br />

Global Functional Department defi ned Key Internal Controls covering<br />

the Bid Creation and Administration process; these controls were<br />

self-evaluated by the major Research and Development units.<br />

A software package for the management of Internal Audit and<br />

Internal Control self-assessment questionnaires and follow-up<br />

action plans will be introduced to replace the “in-house” application<br />

used to date.<br />

A regional internal control organisation was introduced in 2011 that<br />

consists of 28 regional in-house controllers in three regions, who:<br />

• perform the duties defi ned under Section 2.3 for the units in their<br />

regional scope, covering all Operational Departments;<br />

• establish standardised procedures (e.g. for internal control<br />

assignments such as control cycles, documentation,<br />

scope defi nition, work programs etc.), in line with Internal<br />

Audit≈procedures.<br />

Internal Audit Department<br />

In addition to fi ne-tuning the general risk matrix and performing<br />

audits to ensure these risks are managed properly, the Internal<br />

Audit Department:<br />

• monitors and reviews the way that Key Internal Controls<br />

are applied;<br />

• critically reviews the audited unit’s internal control self-assessment<br />

and related action plans.<br />

The Department’s audit assignments go beyond the Key Internal<br />

Controls, and include an in-depth review of processes and their<br />

effectiveness, focusing on compliance and/or performance,<br />

depending on the size of the audited unit and the identifi ed risks<br />

and challenges.<br />

The internal auditors also review newly acquired units to assess<br />

their level of integration and ensure that Group rules and guidelines<br />

are properly applied.<br />

A summary overview of the department’s audits makes it possible<br />

to identify any emerging or recurring risks that require new<br />

risk management tools and methodologies or adjustments to<br />

existing resources.<br />

In 2011, Senior Management ordered unscheduled audits on<br />

emerging risks that led to the revision of certain internal procedures.<br />

In 2011, the internal auditors performed 22 audits, including:<br />

• full audits of medium-sized units;<br />

• audits of a number of risks or operating processes;<br />

• post-acquisition audits for newly acquired companies;<br />

• analyses of control self-assessments by the units;<br />

• follow-up audits to ensure recommendations are applied;<br />

• assistance assignments .<br />

CORPORATE GOVERNANCE<br />

INTERNAL CONTROL AND RISK MANAGEMENT<br />

Committee on Ethics and Responsibility<br />

The Committee on Ethics and Responsibility steers action in relation<br />

to the Principles of Responsibility, updates them and validates<br />

changes. It also answers employee questions that are not addressed<br />

in the companion guide to the Principles of Responsibility, or that<br />

employees’ own managers are unable to answer.<br />

(see “Sustainable development framework”, Chapter 2 Section 2.)<br />

Fraud Committee<br />

In 2010, the Fraud Committee formalised the policy against fraud<br />

and the process of reporting and treating fraud and suspected fraud,<br />

including changes in procedures or practices to avoid recurrence.<br />

Declared incidents are monitored by the Fraud Committee,<br />

which meets on a monthly basis. The Fraud Committee decide<br />

on investigations that are managed either by the local units or<br />

centrally by the Fraud Committee depending on the nature and<br />

the seriousness of the incident. A report is written and updated<br />

monthly for this purpose. The Fraud Committee presents an annual<br />

summary report to the Audit Committee.<br />

2011: stronger internal control system<br />

In 2011, further efforts were made to improve the identifi cation and<br />

control of general risks, to step up periodic reviews of results and<br />

performance, and to enhance auditing practices. The year was<br />

marked, for the internal control system, by the items set out above,<br />

in particular:<br />

• the Fraud Committee’s procedures were defi ned and implemented<br />

for investigation and analysis of the identifi ed incidents of fraud;<br />

• regional internal control units were set up in an internal control<br />

system covering three levels: management, regional internal<br />

control and internal audit;<br />

• a dedicated software package for the management of<br />

self- assessment questionnaires and follow-up action plans will<br />

be ushered in to replace the “in-house” application used to date;<br />

• internal control self-assessment questionnaires were sent out<br />

to cover 90% of the Group’s consolidated revenue (training<br />

managers in internal control practices, defi ning and implementing<br />

remedial action plans if needed) including units from the<br />

acquisition of Areva Distribution;<br />

• administrative measures were pursued regarding segregation of<br />

duties in the information systems.<br />

10.6 Internal control procedures governing the production and processing<br />

of consolidated and individual company accounting and financial<br />

information<br />

In addition to:<br />

• its regulatory tasks;<br />

• its responsibility for overseeing the close of accounts across the<br />

Group;<br />

• its audits of the Group’s results with respect to set targets (see<br />

“Internal Control Organisation and Management: Finance and<br />

Control – Legal Affairs”).<br />

2011 REGISTRATION DOCUMENT SCHNEIDER ELECTRIC<br />

139<br />

3

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