Compliance Integrated compliance THE INTERNAL CONTROL SYSTEM
For the purposes of meeting company objectives, the risk management activities conducted by Sabaf also take into account compliance requirements. The internal control system governing this activity is based on the following elements: - organisation of the internal control and risk management system; - concrete implementation procedures and mechanisms of the control principles; - processes of continuous auditing and monitoring carried out at the various levels of the organisation, both within the scope of business processes and through independent structures. Specifically, Sabaf has an integrated Audit Plan, which breaks down according to specific control objectives (e.g. operational, compliance with Law 262/2005 and Legislative Decree 231/2001, the security and profiling of corporate information systems). The implementation of measures is outsourced to a single structure, Internal Audit, in turn responsible for reporting the results of the activities conducted to the delegated supervisory bodies.
INTERNAL AUDIT FUNCTION AND MANAGER IN CHARGE
• Charter of Values • Corporate Governance Manual • Operational Guidelines • Model 231
nt ty me fe on Sa vir nd En lth a a He
cy
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• Accounting Control Model • Body of Procedures • Quality and Environmental Management System • Company training and information
Int e Pro llectu pe al rty
F Co raud rru an pti d on
Quality
All this translates into a culture and tools based on integrated compliance
Information Security INTEGRATED AUDIT ACTIVITIES
Integrated compliance and the Corporate Governance Manual OPERATIONAL GUIDELINES
The Manual contains certain operating guidelines, which were approved by the Board of Directors and last updated in September 2013. These guidelines were issued to ensure that the management and control bodies of Sabaf properly carry out their duties.
Self-evaluation of Board of Directors Management, coordination and control of Group subsidiaries
ISSUES GOVERNED
Following adhesion to the Borsa Italiana Corporate Governance Code and in order to internalise within its processes good governance practices in this sponsored document, Sabaf has adopted a Corporate Governance Manual* which governs principles, regulations and operational procedures. This Manual, adopted by board resolution of 19 December 2006, has been updated several times over the years, in order to reflect changes in laws and regulations regarding corporate governance, as well as best practice adopted by the Company.
Means of compliance with disclosure obligations to unions, pursuant to Article 150 TUF Assessment of the Group internal control system Process of periodically identifying and measuring Group risks Management of significant transactions in which directors have an interest Assignment of professional mandates to the statutory auditing firm
* The latest version of the text, updated pursuant to the Borsa Italiana Corporate Governance Code as amended in December 2011, approved by the Board of Directors’ meeting of 25 September 2012, is available in the Corporate Governance section of the website www.sabaf.it.