BT 2015 Annual Report Download - page 109

107
Overview
The Strategic Report
Purpose and strategy Delivering our strategy 0ur lines of business Group performance Governance
Financial statements Additional information
Governance and compliance
overnance and copliance proraes
s roup director of ethics and copliance presented at our first
eetin of the ear on his strateic priorities for the ear ahead.
heseincluded drivin ethics and copliance as interal coponents
of s culture and learnin. e also discussed at that eetin
s prorae to onitor copliance with our  obliations
iproveents that had been ade and the continued focus on
onitorin aents copliance with these obliations. esubseuentl
reviewed the proposed approach to our reviews of leal entit and
aent copliance with our  policies and our plan throuh to 01
includin how internal audit and roup copliance wor toether to
assure copliance with  policies inparticularurisdictions.
e reviewed durin the ear a nuber of s other core copliance
proraes
 our international telecommunications regulation and compliance
prorae which is aied at both anain telecounications
reulator ris and also supportin business rowth
 our environent copliance prorae includin iproveents
in the control fraewor in the UK and planned iproveents in
environental trainin and awareness
 enhanceents to the operation of our conicts of interest polic
includin additional pre-eploent checs and the creation of a
central reister of potential conicts of interest and
 our conict inerals copliance prorae its proress and
futureplans.
e supported the proposal to roll out a bespoe face-to-face
copetition law trainin prorae for all UK-based lines of business.
he prorae will tailor the trainin to the riss relevant to the line of
business and ae it relevant to peoples da ob.
n epteber we reviewed the proress ade to put in place the
iproveents identified earlier in the ear to pea Up s
whistleblowin confidential hotline. ver uarter we received a
presentation fro the roup director of ethics and copliance who
provided an overview of the pea Up statistics and trends as well asa
suar of e cases and outcoes.
e discussed the proress ade on a proect outside the UK to clarif
our countr anaers overnance and copliance role.
Joint meeting with the Audit & Risk Committee
e held a oint eetin in eceber 01 with the udit  is
oittee
to cover areas of coon interest to both coittees.
e discussed
 an interi report on the review of the current  suppl chain
 due dilience process for the on-boardin and on-oin
anaeent of suppliers
 s international assurance overnance fraewor includin the
proress ade b nternal udit on the ealth hec rorae
which provides assurance over e operational and financial
controls in s subsidiaries outside the UK
 an update on our privac and data overnance copliance
prorae with focus on the riss threats and opportunities both
in and outside the UK and
 the proress on a proect established to clarif and siplif our
non-financial control fraewor.
e also received the annual review of the aturit of s
copliance proraes. his provided a benchar aainst which
our copliance prorae panel will assess the proress of each
copliance prorae and a suar of proress and net steps
for each.
Key areas Actions
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 Keep under review
the eectiveness of
pea Up
 s roup director of ethics and
copliance reported at each of our
uarterl eetins on his analsis
of the pea Up trends as well as
individual case data
 e received a report in epteber
on the ipleentation of the
iproveent opportunities previousl
identified for pea Up includin
the positive results fro a hih profile
awareness capain.
Other Priorities
 Design and
implement a robust
and integrated non-
financial copliance
fraewor in order to
siplif the current
compliance control
fraewor.
 his prorae ais to increase
the eectiveness of our copliance
activities siplif the nuber of
control fraewors currentl in
eistence and uide and epower
our countr anaers. e received
an update on the proress of this
prorae at our oint eetin with
the
udit  is oittee .
 tatutor accounts
and filins non UK
copleted on tie.
 he  has deleated accountabilities
to country managers for a set
of activities which includes the
completion on time of statutory
accounts and filins in non UK
territories. his is reected in new ob
descriptions for country managers and
suppleents the current reportin b
the finance teas on this activit.
oard evaluation 011
e areed that the oards eectiveness evaluation for 011
be undertaen internall b electronic uestionnaires. he oard
uestionnaire includes a focus on oard coposition and epertise
howthe oard wors its role in settin strate its understandin of
the e riss facin the roup succession plannin the eectiveness of
Board committees and case studies on the oards role in the proposed
acuisition of  and purchase of  reier eaue rihts. he oard
uestionnaire and a separate uestionnaire for this coittee were
circulated in arch 01. oard ebers and the opan ecretar
have also received separate electronic uestionnaires to coplete on
their own individual contribution.
he oard will discuss the results of the evaluation at a future oard
eetin. he hairan will also conduct one-to-one interviews with
directors on their perforance and the enior ndependent irector
ic ose will conduct the annual evaluation of the hairan.
e noted the list of eternal directorships and other interests held b
theebers of the
peratin oittee as at arch 01.