Philips 2010 Annual Report Download - page 106

7 Risk management 7.1 - 7.1
106 Annual Report 2010
procedures in order to avoid conflicts of interest. Philips
did not grant any waivers of the Financial Code of Ethics in
2010.
Philips implemented a global internal communication
program to support local management in their
communications about the updated and extended GBP
Directives, thereby focusing on a consistent “tone at the
top”. A risk-based blueprint for the Compliance Officers
organization, which specifies – at country and operational
unit level – the time and profile (experience, seniority,
functional expertise) required for the Compliance Officer
function, was developed for implementation worldwide.
In the course of 2010 significant progress was made with
the roll-out of dedicated anti-corruption programs at
business and regional level:
• Standard guidelines for anti-corruption due diligence
procedure for the selection of dealers, agents and
distributors: a mandatory procedure is in place and
deployment is nearing completion.
• Company-wide anti-corruption training program: the
anti-corruption (FCPA) e-learning course was
completed by the entire target audience of approx.
35,000 executives and sales and marketing employees.
• Inventory of dealers/agents/distributors: risk-based,
sector-specific processes have been developed for
inventorying current agents and distributors, including
contracts (terms of agreement) and policies for
commission payment and supervision thereof.
The global roll-out of the updated version of the
mandatory web-based GBP training, which is designed to
reinforce awareness of the need for compliance with the
GBP, was completed.
As of 2010, a GBP self-assessment process is fully
embedded in the Philips ICS tool, a workflow application
supporting sector/function management in monitoring
internal controls. Management of reporting units (with >
10 employees) need to answer the questions in the ICS
before year-end and report their findings via a dedicated
control. Embedding GBP self-assessments in ICS ensures
that GBP compliance is now part of sector/function
management’s quarterly ICS/SOx monitoring process and
that GBP non-compliance issues, if significant, are
reported to the Board of Management via the Quarterly
Certification Statement process.
For further details, please refer to the General Business
Principles paragraph in chapter 15, Sustainability
statements, of this Annual Report.