Non-Financial Letter of Representation
Annually, management verifies and confirms that they comply with laws and internal directives and rules through the NFLoR process. Exceptions must be reported and actions must be planned and documented. An NFLoR declaration was submitted by more than 1,000 managers. Results were rolled-up to business and function leaders and subsequently discussed in review meetings between the business and function leaders and their responsible Executive Committee member, in the presence of the Director of Compliance and Legal Counsel. At the review meetings, deficiencies and risks in the compliance and control framework were discussed and actions agreed upon. The responsible Executive Committee member then reported the results of the review meetings to the CEO and the General Counsel, who reviewed the same. A final report was presented to the Board of Management, the Executive Committee, the Audit Committee and the external auditor. The outcome of this NFLoR process, in combination with the internal control self-assessment process and the internal audit results forms a basis for the Statement of the Board of Management in this Report 2016.
Risk, compliance and control review meetings
In 2016, pilots were held with three businesses and one function to combine the internal control self-assessment, compliance and audit reporting into one report and one meeting that would take place three or four times per year. By combining these reports, business leadership gets one overview of all compliance and control deficiencies and weaknesses and is better able to coordinate and prioritize actions across functions. The results of the pilots will be evaluated in 2017.
Retailers in the UK can now immerse themselves in the customer experience and view decorative paints product innovations before they go to market at a new hi-tech customer center in the UK. Located in Slough, the facility houses industry first virtual reality technology which enables visitors to explore different store environments and experiment with product layout.
The General Counsel reports to the Executive Committee and the Audit Committee on important compliance matters, developments and initiatives. Twice per year, the General Counsel and the Director of Compliance submit an extensive written report on the progress of all compliance programs and on compliance matters from the preceding period to the Board of Management, the Executive Committee and the Audit Committee, who review the same and agree on any necessary actions.
Competition Law Compliance Declaration
Employees who meet certain criteria, such as having contact with customers or suppliers or managing those who have, confirm their compliance with the competition laws as articulated in our competition law compliance manual through our annual Competition Law Compliance Declaration program. In 2016, more than 12,500 designated employees signed this declaration. The declaration reminds employees of the importance of complying with competition laws, requests their confirmation of compliance and urges them to disclose any matters of concern. Any possible concerns are reported to the General Counsel and appropriate action is taken.