NWG // CORPORATE GOVERNANCE
parts of the control environment are documented in the form of policies as well as instructions, such as authorization instructions, financial reporting manual and process documentations.
Corporate Governance policy The different corporate governance aspects of the Group are summarized in the Corporate Governance policy, which is also a governing document for other Group policies.
Finance policy The Finance policy stipulates guidance for financial and internal control, with the purpose of establishing a well-functioning and efficient control environment. The policy also includes areas such as financial reporting, tax and related party transactions.
Tax policy The policy describes the group ' s handling of tax internationally and transfer pricing. The policy also specifies frameworks for how the group ' s operations should act in the event of updates to tax legislation and similar areas.
Risk policy The policy describes the Group’ s process for risk assessment and risk management, regarding both financial and non-financial risks. The policy also sets out frameworks for how the Group’ s operations shall be financed and guidance on how risks such as currency risks and interest rate risks shall be dealt with.
IT policy The Group’ s IT policy describes the Group’ s principles for application and safety within IT.
Information policy The Group’ s Information policy is a document that describes the Group’ s rules for handling and communication of information, both internally within the Group as well as externally.
Insider policy The policy sets out rules for handling and communication of insider information.
CSR and environmental policy The Group’ s CSR and environmental policy sets out guidelines for the social and environmental work within the Group and its value chain.
Anti-corruption policy The Group’ s Anti-corruption policy describes the Group’ s principles for work against corruption.§ Anti-money laundering policy Stipulate guidance to reduce the risk for money laundering.
Whistleblowing policy Contains instructions and rules related to the Group’ s whistleblowing function.
Control activities
In order to ensure the internal control works, there are both automatic controls in IT systems, which handle authority and authorization rights, as well as manual controls such as reconciliations and physical counts. Detailed economic analyses of the result plus follow-up of forecasts supplement the controls and provide a general confirmation of the quality of the financial reporting.
The Group performs reviews of the companies’ accounting on a monthly basis, which is reported to Group management. CFOs in all Group companies report directly to Group CFO. No CEO for a Group company is permitted to appoint or dismiss a finance manager on their own. The Group’ s risks related to the financial reporting lay in the risk that material misstatements may occur when reporting the company’ s financial position and results. The Group’ s finance policy and financial reporting manual, together with established follow-up routines, serve to minimize these risks.
Follow-up
The most important control documents in the form of policies and instructions are updated regularly and communicated via relevant channels. Any deviations from Group policies shall be regularly reported to each policy owner, and major deviations shall be communicated to the audit committee and the Board. Finance personnel and management at company and Group level analyze the financial reporting in detail every month. New Wave Group’ s decentralized corporate structure means that each company ' s financial department is responsible for ensuring that the financial reporting from each unit is correct, complete and on time. The controls in respect of the various processes and risk elements are evaluated by means of self-assessment, Board meetings and via the company’ s external auditors. Several processes are fully or partly centralized at Group level, such as purchasing, payments, financing, IT, consolidation and reporting.
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