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87

Department during the implementationphase of the centrally

co-ordinated evaluation system, to confirm that they

continue to operate effectively and efficiently. These officers

are required to submit an attestation every six months con-

firming 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 reporting entity

and what type of tests have been performed in the reporting

period to confirm the adequacy of the control. The ICQs are

updated every six months by the owners of each process.

The Internal Audit Department centrally reviews the ICQ sub-

missions and accordingly will select a number of reporting

entities or processes for detailed follow-up audits to confirm

the integrity of the submission. An action plan is agreed

with each reporting entity to strengthen existing controls or

rectify any specific weaknesses.

The Group believes that the number of processes analysed

and reporting entities incorporated within the evaluation

system is sufficient to satisfy its ongoing Law 262/05 ob-

ligations.