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with each operating company to strengthen existing controls
or rectify any specific weaknesses.
The Internal Audit Department constantly monitors the
implementation status of these action plans and updates
senior management and the Control and Risks Committee
accordingly.
The Chief Executive Officer and Chief Financial Officer of
every Group operating company, and the heads of the relevant
head office functions and departments, are responsible for
maintaining an adequate system of internal control which
includes periodically testing that the key controls identified
and tested by the Internal Audit Department during the
implementation of the centrally co-ordinated evaluation
system continue to operate effectively and efficiently. These
officers are required to submit an attestation every six months
confirming that the internal control system is operating
properly. This signed attestation is sent to Prysmian Group’s
Chief Financial Officer, the Managers responsible for preparing
corporate accounting documents, and to the Head of Internal
Audit. To support this attestation the officers must also
confirm that they have specifically tested the operation of
key controls and that evidence supporting their conclusions
has been retained for future independent review. To achieve
this Prysmian requires each operating company to submit a
detailed “Internal Control Questionnaire” (ICQ). These ICQs
document the key controls for each critical business process
and describe how the control works in that operating unit
and what type of tests have been performed in the reporting
period to confirm the adequacy of the control. The owner of
the business process must update the ICQ every six months.
The Internal Audit Department reviews the ICQ submissions
and accordingly will select a number of operating companies or
processes for detailed follow-up audits to confirm the integrity
of the submission. The results of these reviews are reported in
accordance with the Internal Audit reporting process.
During 2012 the system has been fully implemented to analyse
all critical business and financial processes within 10 of the
largest reporting entities from the former Draka business
perimeter, and partially implemented within a further 6
reporting entities also from the former Draka business
perimeter.
The Company believes that the number of processes analysed
and reporting entities incorporated within the evaluation
system is sufficient to satisfy its on-going Law 262/05
obligations.
