Comentario sobre 1 Timoteo
11. en conformidad con el glorioso evangelio del Dios bendito.
Pursuant to Sec. 315 (2) No. 5 Handelsgesetzbuch (hgb, German Commercial Code), the main features of the internal control and risk management system with regard to the group accounting process are described below. Our understanding of a control and risk management system with regard to the group accounting process is a comprehensive system to ensure the appropriateness and effec- tiveness of the accounting process as well as compliance with applicable legal requirements. With regard to group accounting, the risk management system is designed to detect any risk of misstatement in group accounting and is in line with financial reporting. Not even an appropriate and functioning internal control and risk management system can identify and manage risks with absolute certainty, however. As part of the requirements of Gesetz zur Modernisierung des Bilanzrechts (BilMoG, German Accounting Law Modernisation Act) which
entered into force in 2009, we launched a project in 2010 to refine the group-wide internal control and risk management system and to make it more systematic. The following structures and processes are a fixed component of the group accounting process:
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The Management Board bears overall responsibility for the internal control and risk management system. All business units included in the consoli- dated financial statements are incorporated via a defined management and reporting organisation. The Supervisory Board – and its Audit Committee in particular – as well as the internal audit department are responsible for monitoring the effectiveness of the system independently of the process. The Audit Committee therefore regularly addresses the topic of the internal control and risk management system.•
Our group guidelines and organisational instructions set out the principles governing the structures and procedures of the internal control and risk management system relating to group accounting. In particular, these include the group accounting manual pursuant to uniform International Financial Reporting Standards (ifrss) to be employed across the group, guidelines governing the scheduling and procedural process for annual and interim financial statements, a uniform group chart of accounts and standardised forms for recording notes disclosures at the level of the divisions included in the consolidated financial statements. We revise our guidelines at regular intervals and in urgent cases to reflect current external and internal develop- ments and provide ongoing training for the employees responsible for the financial statements.•
The consolidated financial statements are based on the separate financial statements prepared by the subsidiaries’ bookkeeping departments. In some cases, these are directly prepared in accordance with uniform group accounting standards, otherwise they are reconciled to them from locally prepared accounts. Various decentralised it systems are in use at the subsidi- aries. Data reporting for the consolidated financial statements is carried out using a centrally managed group reporting and consolidation package as well as an it platform for preparing the disclosures in the notes. Inclusion in the consolidated financial statements generally takes the form of subgroup statements for business areas at the country level, with several legal entities combined. In addition to an internal review, data reporting is also subject to a statutory audit or review by independent auditors. The group accounting department is responsible for further consolidation into the consolidatedfinancial statements. The group accounting department monitors reporting deadlines and the quality of data reported, ensuring that this complies with group provisions. It also serves as a central contact for any accounting or consolidation queries. The process of preparing the financial statements is divided into hard close as of 30 September of a given year, almost equivalent to preparing separate financial statements in terms of nature and scope, and the fast close as of 31 December.
In connection with the group accounting process, we attach particular impor- tance to the following components of the internal control and risk management system – these safeguard group accounting and the overall picture conveyed by the consolidated financial statements as well as the group management report:
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Identification by the group accounting department of the significant areas of risk and control relevant for the group accounting process. In particular, this includes unusual and complex business events as well as non-routine transactions.•
Judgements in recognition and measurement of assets and liabilities. There is an inherent risk here that they may not be presented correctly in the consoli- dated financial statements. Our group accounting department regularly reviews the significant areas of risk based on findings arising in the course of preparing the consolidated financial statements as well as the ongoing assessment of special accounting questions. Through the hard close and other interim financial statements, we can identify any new critical issues at an early stage and deal with these before year-end.•
Preventative control measures in the finance and accounting departments of the group and divisions included in the consolidated financial statements. Operating and business processes are also included since these generate important information for the preparation of the financial statements of the divisions incorporated as well as for the consolidated financial statements including the group management report. In this respect, we would like to highlight the segregation of functions in group accounting and at the busi- ness units incorporated, the principle of dual control and the predefined approval processes in the relevant areas. This approach is supported by the it system in place across the group as well as the later preparation of the consolidated financial statements. We perform an annual check that processes and systems are effective in the meaning of the internal control system required by the BilMoG.•
Monitoring of the group accounting process and its findings at the level of the Management board or relevant departments and at the level of the busi- ness units operated. In particular, this consists of monitoring the accounting on a rolling basis by submitting monthly reports to the Management Board, performing quality control on reported data in group accounting and group controlling as well as assessing the significant accounting judgements made by the divisions included in the consolidated financial statements.•
Measures to safeguard the appropriate use of computer-assisted processingof issues and data relating to group accounting, including but not limited to centrally managed user access to the group reporting package, access controls on accounting-related it systems as well as automated validation of reported data applying centrally defined controls prior to further processing by the group accounting department.