In a climate where the governance arrangements in large companies are increasingly under scrutiny, the Board has implemented a transparent approach, driven by our Framework for Responsible Business, and underpinned by a suite of policies, public position statements and our internal control process.
Our internal control process is intended to provide a rigorous assessment of the robustness of management controls. The Board, together with the Executive, Audit and Risk & Responsibility Committees, is central to the internal control process. Throughout the year the Board receives reports from each of these Committees and as part of the year-end process receives the Group Chief Executive's Letter of Assurance. This process seeks to confirm compliance with all major internal and external requirements along with the existence of appropriate controls and processes to manage risks and to provide details of material risks and control weaknesses. The Board additionally conducts a formal review of the effectiveness of internal controls based on the information and assurances provided to it directly and via the Committees mentioned.
More details on our approach to coporate governance and internal control can be found in the Annual Report and Accounts 2004 and in the Corporate Governance section of the Group website.
We expect all employees, including our Non-executive Directors, to operate to the highest standards of business conduct. Delivering sustainable value depends on the trust and confidence of our stakeholders and this can only be earned by conducting our business in a responsible manner. Our US employees are expected to adhere to our Standards of Conduct setting out our expectations of responsible business practice. A UK Code of Business Conduct was issues to employees in April 2004 and to support this we established an ethics committee, a business conduct office and a 24-hour ethics advice line for our UK employees complimenting those already in place in the US.
In response to Section 406 of the Sarbanes- Oxley Act of 2002, the Board has adopted a Code of Ethics for senior financial professionals. This code is available in the Corporate Governance section of the Group website (where any amendments or waivers will also be posted).