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Shareholders' Letter

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Measures are in place for most risks facing Swisscom. Strategic risks are entered into according to<br />

defined criteria.<br />

Swisscom also deploys a Group-wide internal control system in the area of financial risks. The system<br />

aims to ensure reliable internal and external financial reporting and safeguard against misreporting<br />

(disclosure violations or errors) of business transactions. Internal policies and instruments<br />

such as the Accounting Manual or the whistle-blowing platform support this goal. The<br />

internal control system incorporates all responsible units at the appropriate level, including the<br />

Audit Committee and the Group Executive Board. Swisscom sees the internal control system as<br />

an ongoing task and an opportunity to continually improve processes in bookkeeping, accounting<br />

and financial reporting.<br />

Measures are also taken to mitigate operational risks in the areas of security, business continuity<br />

management, crisis management and financial risk management.<br />

Opportunity and risk management<br />

2010 saw the launch of a six-monthly coordination process between the Strategy department and<br />

the Risk Management department, in which opportunities and risks relating to short- and longterm<br />

strategic projects are discussed and possible risk scenarios drawn up and entered in the risk<br />

profile. The Risk Management department also provides the risk input information for the business<br />

planning process.<br />

This process serves to ensure that new strategic options match the risk profile of the Swisscom<br />

Group.<br />

Risk factors<br />

Political and regulatory risks<br />

For Swisscom, telecommunications and antitrust legislation entail risks which could have a serious<br />

and sustained impact on the company’s future financial position and results. In particular, public<br />

authorities can issue rulings on prices and impose penalties which could reduce Swisscom’s profitability<br />

and lead to an outflow of funds. Regulatory decisions regarding access prices could also<br />

influence the range of products and services as well as investment decisions.<br />

A decision by the Federal Court on proceedings relating to sanctions under competition law in the<br />

mobile termination area is expected in 2011. This decision could have an impact on ongoing and<br />

future proceedings and can have important financial implications. Besides financial damage,<br />

Swisscom’s reputation could also come under pressure.<br />

Most of the issues contested by Swisscom concerning the new Telecommunications Act have been<br />

resolved. However, new parliamentary initiatives to revise the Act are once more increasing uncertainty.<br />

Swisscom also faces antitrust investigations, which primarily concern allegations of abuse of its<br />

market-dominant position. In cases where such practices are deemed by the competition authorities<br />

to be unlawful, the companies in question face the threat of sanctions.<br />

The outcome of proceedings currently under judicial consideration could lead to a revised assessment<br />

in the coming year. A key priority is to avoid antitrust legal proceedings. Swisscom operates<br />

an internal compliance scheme to ensure that its business activities adhere to the provisions of<br />

antitrust legislation.<br />

Sector-specific risks<br />

Telecommunications market<br />

A change in the structure of the telecommunications market in Switzerland could have a prolonged<br />

impact on the structure of competition and on market behaviour. Swisscom mitigates this risk by<br />

ensuring that it remains efficient and competitive.<br />

Management Commentary 70 | 71<br />

Risks

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