APC 2014 Annual Report Download - page 164

3CORPORATE GOVERNANCE
INTERNAL CONTROL AND RISK MANAGEMENT
Operating Divisions and operating units Global Functions (Human Resources,
Purchasing, Manufacturing, Supply Chain,
The Operating Division management teams play a critical role in
Information Systems,etc.)
effective internal control.
In addition to specific processes or bodies such as the Group
All Group units report to one of the Operating Divisions, which are Acquisitions Committee (see «Risk Factors – Acquisitions») for
headed by an Executive Vice-President, supported by a Chief making and implementing strategic decisions and centralization of
financial officer. certain functions within the Finance and Control – Legal Affairs
The Executive Vice-Presidents of the Operating Divisions sit on the Department (see above), Schneider Electric centralizes certain
Executive Committee, which is chaired by the Chairman and CEO matters through dedicated Global Functions thus combining
of the Group. decision-making and risk management at the corporate level.
Within each division, the management team organizes control of An Innovation and Technology Council meets 11times per year to
operations, ensures that appropriate strategies are deployed to ensure cross-functional coordination among the Global Function
achieve objectives, and tracks unit performance. for innovation and new products.
A Management Committee led by the corporate Management The Human Resources Department is responsible for deploying
Control and Accounting unit reviews the operations of the and ensuring the application of procedures concerning employee
Operating Divisions on a monthly basis. development, occupational health and work safety.
The Operating Divisions have teams of business internal controllers The Purchasing Department is responsible for establishing
who promote Key Internal Controls in the units within their scope guidelines concerning purchasing organization and procedures;
and analyze the quality of the internal control self-assessments relationships between buyers and vendors; and procedures
(including ratings and action plans) returned by the units. governing product quality, the level of service, and compliance with
They detect internal control issues that require action plans in environmental standards and Group codes of conduct.
some or all of the units within their scope. They also identify units Global Functions also issue, adapt and distribute policies, target
that need specific assistance and either implement or oversee the procedures and instructions to units and individuals assigned to
implementation of the appropriate support. handle their specific duties.
They carry out monitoring of the remediation plans drawn up at the Global Functions have internal control correspondents who work
time of the self-assessments and control assignments on site. with the Internal Control Department to establish and update the
Lastly, the internal control teams offer suggestions for enhancing Key Internal Controls deployed across the Group.
and updating the Key Internal Controls.
Distributing information: benchmarks and guidelines 9.3
The main internal control benchmarks are available to all
Insider code of ethics
employees, including on the Group’s Intranet. Global Functions This code sets out the rules to be followed by management and
send updates of these Reference Documents to the appropriate employees to prevent insider trading. It imposes an obligation of
units and individuals through their networks of correspondents. confidentiality on all employees who have access to confidential
In some cases, dedicated e-mails are sent out or messages are information. It also sets permanent restrictions on purchases and
posted on the Intranet portal to inform users about publications or sales of Schneider ElectricSE shares by persons who have access
updates. to price-sensitive information in the course of their work (see
«Organizational and operating procedures of the board of
Whenever possible, the distribution network leverages the
directors», Chapter3 Section2). Such persons are prohibited
managerial/functional organization to distribute standards
from trading the Company’s shares at any time if they are in
andguidelines.
possession of price sensitive information and during specified
Principles of Responsibility
periods prior to (and until the day of) release of the Group’s
financial statements and quarterly information on sales.
See chapter Ethics & Responsibility, page62.
162 2014 REGISTRATION DOCUMENT SCHNEIDER ELECTRIC