The Board has ultimate responsibility for the Group's system of internal control and for reviewing its effectiveness. The Board has reviewed the Group’s system of controls including financial, operational, compliance and risk management on a regular basis throughout the year. However any such system can only provide reasonable and not absolute assurance against any material misstatement or loss.
The Group has established a risk management framework and procedures necessary to enable the Directors to report on internal controls in compliance with the Code. The risk management procedures involve the analysis, evaluation and management of the key risks to the Group.
The other key elements of the Group’s system of internal control include:
The Group has 'whistle blowing procedures' under which staff may report any suspicion of fraud, financial irregularity or other malpractice. There is also a process in place for staff to report operational risks and issues to the Risk committee.
The Group has continued to develop its risk management and has reappraised its risks in the light of the changes in the external environment during the last year.
The Group has also considered the requirements of the Bribery Act 2010 and taken steps to ensure that is has adequate procedures as set out by the act.
The Group continues to strengthen its risk management processes to ensure these are embedded as part of the Group's culture. The Turnbull Guidance sets out best practice on internal control to assist companies in applying the Codes principles with regards to internal control. The Board, with advice from the Audit Committee has completed its review of the effectiveness of internal control since 1 April 2009 with no significant failings or weaknesses identified.