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71 Sustainability Report 2014 Commitments and future challenges Sustainability at PRISA shareholders, markets and regulators. Likewise, there are also performance standards aimed at ensuring that all operations are clearly and accurately reflected in the Group’s records, statements and books. Requests, incidents and queries that arise regarding the interpretation and implementation of the Code of Conduct are dealt with by the Group’s Departments of Human Resources, and ultimately the General Secretary, who report regularly to the Corporate Governance Committee on the compliance by employees with the standards. The Corporate Governance Committee will publish an annual report on evaluation and the degree of compliance with the Code of Conduct, which shall be distributed among the relevant PRISA governing bodies. Complaints and concerns channel that enables communication to the audit committee of any financial and accounting irregularities, as well as any breaches of the Code of Conduct and malpractice within the organization. PRISA has a complaints channel for receiving and dealing with complaints and concerns regarding accounting, internal controls or other auditing matters. This is a confidential and anonymous communication channel between PRISA employees and the Audit Committee. Additionally, there is a confidential complaints channel available to third parties related to the Group. The complaints are channeled through a special email address or P.O. Box and are received by the Chairman of the Audit Committee, who determines the appropriate resources, methods and procedures for the investigation of each complaint. Training courses for staff involved in the preparation and review of financial information, as well as in the evaluation of ICFR, covering at the very least accounting standards, auditing, internal control and risk management. Over the course of the year, Group employees who are significantly involved in the implementation of the system of internal control over financial reporting (more than 200), have participated in a general course on internal control, which covers a specific description of the model for internal control over financial reporting of the Group. Furthermore, finance personnel from the business units and Group companies receive bulletins updating them on accounting standards, and in 2013, they completed a specific course on developments in international accounting standards that are due to take effect in 2014. Risk assessment regarding financial information Main features of the process for identifying risks, including risk of error or fraud: ƒƒ When the process exists and is documented. The Group has a system for the identification and assessment of risk with regards to internal control over financial reporting, which is formally documented and updated at least annually. In the risk assessment of financial information, PRISA applies a top-down approach based on the Group’s most significant risks. This approach starts with identifying significant accounts and PRISA takes into account both quantitative and qualitative factors. The quantitative evaluation is based on the materiality of the account, and is supplemented by qualitative analysis that determines the associated risk depending on the nature of the transactions, the nature of the account, the complexity of the accounting and reporting, the likelihood of significant contingent liabilities as a result of the transactions associated with the account, and susceptibility to losses due to error or fraud. In order to perform a full risk assessment, this analysis is performed in each Group Business Unit, as these ultimately generate financial information which serves as the basis for preparing PRISA’s consolidated financial statements. For each of the business units considered significant, the relevant headings and sections are identified. Having identified the significant accounts and break-downs at the consolidated level and in each business unit, the relevant associated processes are identified, as well as the major types of transactions within each process. The objective is to document how the major transactions of the significant processes are initiated, authorized, recorded, processed and reported. ƒƒ When the process covers all objectives of financial reporting, (existence and occurrence, completeness, valuation, presentation, disclosure and comparability, and rights and obligations), when it is updated and how often. For each account, there is an analysis of the significant accounting controls that will ensure the reliability of financial reporting, ie. that the reported transactions have taken place and pertain to that account (existence and occurrence), that the transactions and assets have been reported in the correct amount (valuation), that the assets, liabilities and transactions of the Group are properly broken down, classified and described (presentation and disclosure) and that there are no assets, liabilities, or significant unreported transactions (completeness). Annually, and in addition to this review, there is also a review of controls that may mitigate any such risks.


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