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REGISTRATION DOCUMENT AND FINANCIAL REPORT - Iliad

REGISTRATION DOCUMENT AND FINANCIAL REPORT - Iliad

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16. FUNCTIONING OF THE COMPANY’S ADMINISTRATIVE <strong>AND</strong> MANAGEMENT BODIES<br />

16.4 INTERNAL CONTROL<br />

An internal control system can only provide reasonable assurance – and not an absolute guarantee – that the<br />

Company will achieve its objectives.<br />

The <strong>Iliad</strong> Group’s internal control system is structured around (i) internal rules, which set out regulations to be<br />

respected by employees within each Group company, and (ii) procedures and controls inherent to the individual<br />

systems of each department.<br />

The Group does not currently have a specific Internal Audit department, but the Finance Department, as well as<br />

the accounting and management accounting control teams and the other departments described above are at the<br />

heart of the overall internal control system.<br />

Each Group company reviews its accounting and financial data on a monthly basis.<br />

(iii) Control processes for major risks<br />

The Group has set up an internal control system that enables it to manage the risks relating to its business<br />

strategy, development and decision-making processes.<br />

Risks relating to the Group’s operations and business strategy<br />

In 2000, the Group created a research and development team with a view to safeguarding its capacity to remain<br />

technologically innovative. This team reports directly to Senior Management.<br />

In addition, in view of the Group’s rapid growth and in order to anticipate recruiting needs – notably within the<br />

call center teams – a reporting procedure has been established to measure the volume of calls received and dealt<br />

with, and to monitor queuing time. These reporting schedules are relayed regularly to Management.<br />

Management is also regularly provided with technical information concerning the Group’s platform and network,<br />

as well as recruitment needs (in terms of number of staff and skills), and the financing required in order to<br />

develop the Group’s technical infrastructure.<br />

Risks relating to the Internet and telecommunications sectors<br />

In accordance with the specific regulations relating to the Group’s operations in the field of telecommunications,<br />

the Company’s compliance with the applicable laws and regulations is regularly monitored by the compliance<br />

department. Risks relating to the Group’s business sectors are principally monitored by an internal team<br />

dedicated to tracking regulations within the Internet and telecommunications sectors as well as the financial and<br />

legal impact of these regulations on the Group’s operations.<br />

This team reports to the Senior Vice-President responsible for compliance issues.<br />

Legal risks linked to Internet access<br />

In order to limit the risks relating to the potential liability of Internet access and web hosting service providers,<br />

the subscription procedure set up by Free does not permit any anonymous users on its network. This procedure<br />

does not allow a new user to connect online, as new users must wait until they have received a confirmation letter<br />

with a username and password before they can connect to Free for the first time.<br />

This procedure, which enables the Group to validate the name and address of each new subscriber, was set up<br />

when Free was initially launched and means that the Group has no anonymous users on its network.<br />

Consequently, Free can respond to and assist with any requests concerning the identity of any dubious users in<br />

the event of a legal claim.<br />

Legal risks are monitored by a specific department. In addition, the Company has taken out specific insurance<br />

policies to cover the risks arising from its operations.<br />

<strong>Iliad</strong> – Registration Document 2007 - 97

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