Lenovo 2016 Annual Report Download - page 83

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2015/16 Annual Report Lenovo Group Limited
Additionally, Lenovo has a strong corporate culture based on good business ethics and accountability. 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 how 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 the Company’s 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, report
suspected misconduct, or cooperate with an investigation, Lenovo will not tolerate any form of retaliation
or harassment.
Another feature of Lenovo’s 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 identified within the business to further assist management with designing, executing,
and monitoring controls. The Group Controller oversees controls related activities of these individuals
across all organizations and process owners.
This comprehensive internal 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
Lenovo’s 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.