APC 2012 Annual Report Download - page 144

2012 REGISTRATION DOCUMENT SCHNEIDER ELECTRIC142
CORPORATE GOVERNANCE
3INTERNAL CONTROL AND RISK MANAGEMENT
functions within the Finance and Control - Legal Affairs Department
(see above) and through dedicated Global Functions.
An Innovation and Technology Council meets eight times per year
to ensure cross-functional coordination among the Global Function
for innovation and new products.
The Human Resources Department is responsible for deploying
and ensuring the application of procedures concerning employee
development, occupational health and work safety.
The Purchasing Department is responsible for establishing guidelines
concerning purchasing organization and procedures; relationships
between buyers and vendors; and procedures governing product
quality, service levels, and compliance with environmental standards
and Group codes of conduct.
The Global Functions also issue, adapt and distribute policies,
target procedures and instructions to units and individuals assigned
to handle their specifi c duties.
The Global Functions have internal control correspondents who
work with the Internal Control Department to establish and update
the Key Internal Controls deployed across the Group. They analyze
the results of self-assessments concerning the Key Internal Controls
that fall within their Function’s scope, identify internal control issues
that require action plans and either implement or oversee the
implementation of these plans.
10.3 Distributing information: benchmarks and guidelines
The main internal control benchmarks are available to all employees,
notably on the Group intranet. The Global Functions send updates
of these Reference Documents to the appropriate units and
individuals through their networks of correspondents.
In some cases, dedicated e-mails are sent out or messages are
posted on the intranet portal to inform users about publications or
updates.
Whenever possible, the distribution network leverages the
managerial/functional organization to distribute standards
andguidelines.
Principles of Responsibility
The Principles of Responsibility, initially published in 2002, were
updated in2009. Translated into the main languages used within
the Group, given to all new employees and available on the Group’s
intranet, they are designed to guide employees in their decisions
and actions. They defi ne the Group’s essential values and set
out individual responsibility in respect of these values, laws and
regulations. They also set out the interrogation and alert procedures.
A Committee on Ethics and Responsibility has been set up, and
correspondents appointed to steer action in this area, to make
updates and to validate changes. The correspondents also answer
employee questions that are not addressed in the document Our
Principles of Responsibility or in the complementary documents that
are available, or that managers are unable to answer (Companion
guide, e-learning module, FAQ). (see “Sustainable development
framework”, Chapter2 Section2).
In addition, communication actions and Questioning and Alert
process formalization actions have been undertaken since2011,
a “professional alert system” has been gradually implemented
since2011. The purpose of this new professional warning system
is to allow all employees to launch an alert when in their judgment,
they have been a witness to or victim of a breach of the rules of
ethics and responsibility expressed in Our Principles of Liability.
In accordance with the legal requirements inherent in the use of
such a system, an organization in charge of administration and of
background investigation has been established. It is intended to
ensure compliance with the protection of people and of those who
issue alerts.
Insider code
This code sets out the rules to be followed by management and
employees to prevent insider trading. It imposes an obligation of
confi dentiality on all employees who have access to confi dential
information and sets permanent restrictions on purchases and
sales of Schneider Electric SA shares by persons who have
access to price-sensitive information in the course of their work
(see “Organizational and operating procedures of the Supervisory
Board”, Chapter3 Section2).
International internal auditing standards
The Schneider Electric internal auditors are committed to complying
with the international standards published by the Institute of Internal
Auditors (IIA) and other bodies.
International Financial Reporting Standards
(IFRS)
The consolidated fi nancial statements for all fi scal years
commencing on and after January1, 2005 have been prepared in
accordance with International Financial Reporting Standards (IFRS),
in compliance with European Union regulation no.1606/2002.
The Group applies IFRS standards as adopted by the European
Union as of December31, 2012.
The Group’s accounting principles refl ect the underlying
assumptions and qualitative characteristics identifi ed in the IFRS
accounting framework: accrual accounting, business continuity,
true and fair view, rule of substance over form, neutrality, prudence,
completeness, comparability, relevance and intelligibility.
The Group statutory and management accounting standards
manual explains how IFRS principles are applied within the Group,
taking into account the specifi c characteristics of the Group’s
activities.
The application of Group accounting principles and methods is
mandatory for all Group units, for management reporting and
statutory consolidation.
The Group statutory and management accounting standards
manual and the IFRS principles are available on the Intranet.