Lenovo 2015 Annual Report Download - page 73

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2014/15 Annual Report Lenovo Group Limited
Additionally, Lenovo has a strong corporate culture based on good business ethics and accountability. Lenovo’s
Code of Conduct (the “Code”), which applies to all employees, forms the basis of Lenovo’s commitment to
conducting all business with uncompromising integrity and ethical behavior. The Code also helps employees
determine when to ask for advice, and where to obtain it. All Lenovo employees are required to comply with the
Code, which is available in multiple languages and is accessible on the Company’s website and internal intranet, and
to participate in regular training to reinforce the Company’s commitment to compliance and conducting business
with integrity. Lenovo regards any violation of the Code as a serious matter and is committed to investigating all
reported concerns. Furthermore, in keeping with best practices, Lenovo has developed and implemented an Anti-
Bribery and Anti-Corruption Policy which reinforces the Code and provides additional specific guidance regarding
compliance with rules and laws related to bribery and corruption.
Along with establishing guidelines, principles and values, Lenovo recognizes that an environment where employees
feel free to bring concerns to management is also required to make our internal control system successful.
Lenovo’s corporate policy on reporting unlawful or inappropriate conduct makes it clear that all reports will be kept
anonymous and confidential to the extent possible. Most importantly, if employees seek advice, raise a concern
relating to a potential compliance issue, or report suspected misconduct, Lenovo will not tolerate any form of
retaliation or harassment.
The comprehensive controls framework established by the Company covers all activities and transactions.
Management performs periodic enterprise wide risk assessments and continuously monitors and reports progress
of action plans to address these key risks. Management also assesses business risks when formulating corporate
strategies, and tracks and reports on the implementation of strategic initiatives, business plans, budgets and
financial results regularly to the Board. Additionally, as part of our commitment to financial integrity, all relevant
senior executives regularly verify the accuracy and completeness of the quarterly financial statements and confirm
compliance with key internal controls.
Another feature of our internal control system is the execution of key control self-testing by management to
reasonably assure that internal controls are working as intended and that necessary actions have been taken to
address control weaknesses. Specific employees with controls knowledge and expertise have been embedded
across the business functions to further assist management with designing, executing, and monitoring controls. The
Group Controller oversees and coordinates the activities of these individuals who in turn help to clearly communicate
control requirements across all organizations and process owners.
To assist the Board’s Audit Committee in its oversight and monitoring activities, the Company maintains an
independent, worldwide Internal Audit function. Internal Audit provides objective assurance to the Audit Committee
that the system of internal controls is effective and operating as intended. The mission of Internal Audit is to provide
the Board and Lenovo management with:
• Independent and objective assessment of Lenovo’s system of internal controls;
• Guidance to Lenovo stakeholders for improving risk management;
• Proactive support to improve Lenovo’s control posture; and
• Independent investigations regarding certain allegations of fraud and violations of the Code and other company
policies.