57 Social Responsibility and Sustainability Report 2017 | PRISA Our governance structure and risk management The Group’s System for Risk Management opera-tes by business unit, and is then consolidated, in turn, at the corporate level. The Group continuously monitors all of the most significant risks that might affect business units. To this end, a risk map is used as a tool for the graphic representation of the risks inherent in the Group. It is used to identify and assess any risk affecting the development of the activities of the various business units. The identification of risks is carried out by the ma-naging bodies of the business units and of the corporate center. Data are then consolidated and standardized by the Internal Audit, which reports the results periodically to the Audit Committee. The managing bodies of the respective businesses are entrusted with determining who shall be res-ponsible for managing each risk and for the action plans and associated controls to be implemented. In addition, one of the responsibilities of PRISA’s Compliance Unit is to identify, manage and mitiga-te compliance risks. The Audit Committee raises issues of relevance to the Board, which in turn, oversees the Group’s risk map. Internal Control Over Financial Reporting (ICFR) is subject annually to an independent evaluation of the effectiveness of the system by the external au-ditors of the Group. A description of the most significant risks and im-pacts for the Group, as well as details of the proce-dures for their identification, assessment, analysis and management, are set out in the Annual Report for the year, as well as in the Annual Corporate Go-vernance Report and the Annual Report. Compliance and Code of Ethics PRISA’s Compliance Unit is an independent body with autonomous powers of initiative and control and is made up of the Secretary General, the Di-rector of Internal Audit and the Director of Human Resources This unit reports to the Audit Commi-ttee and is entrusted with identifying, managing and mitigating compliance risks and ensuring and promoting compliance with applicable laws, the Code of Ethics and the internal regulations gover-ning all the Group’s activities. In addition, the main business units of the Group have their own compliance units. The Compliance Unit reports regularly to the Corporate Governance Committee on all inci-dents and decisions related to the Internal Code of Conduct as well as the Code of Ethics, so as to enable this Committee to assess compliance with corporate governance rules and accordingly make the necessary proposals for improvement (a task entrusted to the committee by the Board Regulations). As already indicated, 2016 saw the completion of the process of reviewing the Crime Prevention Mo-del, spearheaded primarily by the Compliance Unit. As part of this process and with a view to develo-ping the Code of Ethics, the Compliance Unit has promoted the adoption of a range of internal rules, among which are the following: Guidelines on Mo-ney Laundering, Gifts Policy, Policy on Anti-Corrup-tion and a Policy for the Defense of Competition. Code of ethics PRISA’s Code of Ethics encompasses a range of principles and rules of conduct that govern the actions of the companies that form part of Gru-po PRISA and its professionals (members of the governing bodies, managers, workers, trainees and interns —regardless of the legal form of their employment or service, their rank, geographical or functional location or the specific Group company they provide services for) in order to ensure ethical and responsible conduct in their business activity. The Code sets out general ethical principles (such as human rights and civil liberties, professional development, equal opportunities, non-discrimi-nation and respect for people, health and safety at work, as well as environmental protection) and general rules of conduct relating to: i. Regulatory compliance and integrity of professional conduct. ii. Use of resources for the performance of professional activity.
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