7.1. The control environment
The control environment is the foundation of the internal control system, as it promotes the awareness and the compliant behavior of all employees. It is made up of various elements that set up a clear structure of principles, rules, roles and responsibilities, while showing the commitment of general management.
The Management Book explains the organization and governance of the Group: its guiding principles, the roles and responsibilities of the Executive Committee (Comex), Global Business Units and functions are defined, as well as their scope. It also set forth a management framework expressed in the Group’s Management and People Models, including accountability and transparency. The Management Book also contains an approval matrix, displaying the level of authority required for the approval of major decisions (financial commitments, sales or purchase contracts, capital investments, acquisitions or divestments, and legal settlements). Finally, it contains 25 “red lines” that are tackling key risks of the Group. These rules are mandatory for all employees.
The Code of Conduct highlights the principles that are intended to guide employees in their daily activities. It is based on a strong tradition of values that are deeply rooted in the Company’s culture. As to the financial reporting, the Code states that employees must ensure that it is accurate and compliant with applicable regulations.
An Ethics Helpline, managed by a third party, is being made available to employees to enable them to report potential violations of the Code of Conduct, in case they cannot go through their managers or through the Compliance organization, or wish to report anonymously. The Helpline is available for reporting concerns via the internet in more than 45 specific countries/ regions as well as in the general category “other location”. Thus, anyone may contact the Ethics Helpline from wherever he or she may be located in the world. In addition, the Ethics Helpline web tool is available in more than 40 languages. The phone line has more than 20 languages available by prompt, depending on the number dialed. Toll-free access is given to Solvay employees and is available 24 hours a day, 365 days a year.
All these documents are accessible widely through the Group intranet, and regular training courses on the Code of Conduct are provided to all employees.
Standardized human resources processes are in place to allow development, training and appraisal of personnel. The job descriptions for key positions are organized consistently by professional family: Finance has its own job description reference system, covering the key positions that ensure the timeliness, compliance and quality of the financial reporting.