2020

INTERNAL
CONTROL
MANUAL
ARaymond
INTERNAL CONTROL
MANUAL

Presidency note
Our Enterprise evolves  in a world of increasing changes
and disruptions offering numerous promising new oppor-
tunities along with many new risks and obligations.

Our internal growing complexity is accompanied and

nourished by the external increasing world risks and com-
pliance intricacy.

In order to maintain the integrity and reputation of our

Network, keep our values and commitments alive,  insure
the integrity and safety of our  organization and of our
personnel, we need to maintain and reinforce the nature
and quality of our internal controls.

For this important matter, we count on you for your full

support and contribution.

Antoine RAYMOND C.E.O

2
TABLE OF CONTENTS

WHAT IS INTERNAL CONTROL? p4

HOW TO READ THIS MANUAL ? p6

PROCESSES
1 . PURCHASE p8

2 . CAPEX AND LT LEASE p 10

3 . FINANCE p 11

4 . SALES & ENGINEERING p 13

5 . HR p 15

6 . HSE p 16

7 . QUALITY p 17

8 . LEGAL p 18

9 . RISK & COMPLIANCE p 19

10 . IT p 21

11 . LOGISTIC p 22

12 . CUSTOMS p 23

13 . MANUFACTURING p 25

14 . SUMMARY OF SAPIN II KEY CONTROLS p 26

3
WHAT IS INTERNAL
CONTROL?

What is internal control?

The ARaymond internal control system aims at proactively mitigating risks in all our bu-
siness areas, improving our efficiency and ensuring our long-lasting success. It covers:

• Compliance with laws and regulations.

• Application of NCG’s (read and share the latest version up-to-date).

• Efficiency of internal processes.

• Reliability of financial and non-financial information.

What is not internal control?

• Internal control is not limited to a set of procedures dedicated to financial and accounting
processes… it gathers for all domains (operations, sales, HR, legal…), behaviours and
values applicable at every level of the organisation.

• Internal control does not take time away from our core activities… but are built into
business processes.

• Internal control is not only internal auditors’ concerns… but it is everyone’s business.

4
To clarify and support Internal Control within
AR Network, a set of tools are available:

THIS INTERNAL CONTROL HANDBOOK PRESENTS FOR KEY PROCESSES.

• Compliance with the Law SAPIN II (French anti-corruption law applicable in all our
network companies)
• the major risks incurred;
• the related internal procedures;
• the top Internal Control principles.

3 LINES OF DEFENCE:

• Level 1 = Management control - daily & operational controls

• Level 2 = Controller review - test sheet and analytical review
• Level 3 = Internal or external audit report
All certifications (ISO, IATF, QS,…) do not substitute for the completion of Level
1 and Level 2 controls or an internal audit review. This will, however, make these
controls easier to perform.

AR NETWORK NORMS AND PROCEDURES: NCG’S, EXECUTIVE HANDBOOK,…

TRAINING AND DEDICATED COMMUNICATION.

AN ANNUAL UPDATE OF SELF-ASSESSMENT CAMPAIGN WITH THE LATEST

VERSION AVAILABLE BEFORE EACH ON-SITE INTERNAL AUDIT ICARE AIMING TO:

• provide a set of best practices;

• have a clear vision of your Internal Control quality level;
• be better prepared for internal audits;
• perform a follow-up of action plans.

5
 HOW TO READ
THIS MANUAL ?

The following chapters present a mapping of ARaymond’s processes. For each of them,
a reminder of the key internal control principles is spelled out.
You will come across the icons displayed below. They help you to quickly identify inter-
nal control principles applicable to your level within ARaymond organization.

PLANT SSC

PLANT SHARED SERVICES CENTER /

Addressed to HUB REGION
the plant daily works.
Addressed to the AR’s Shared
Services Center.

COMPANY NETWORK

COMPANY NETWORK / CORPORATE

Addressed to local Senior Addressed to AR Network HQ as a consolidating
or Executive Management. company. IC principles are managed by network Process
Officer and aim at implementing network procedures,
norms, transversal activities…

6
PROCESSES

7
 1 PURCHASE
AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:
• NCG’s note 6 • Inadequacy of terms of local or international purchase
• Procedure related to new supplier registration and Master contracts with AR Network requirements
• file change (supplier ID form) • Inappropriate / unauthorized PO are placed due to a lack
• ARaymond Network Accounting Manual of monitoring
• ARaymond Code of Conduct & Ethics • Misappropriation of funds (unauthorized change to
• Anti-corruption Guideline the suppliers master file)
• Conflict of Interest Guideline • Infringements with respect to Personal & Company
• ATOMS data protection

1 - PURCHASE PROCEDURE 4 - SPECIFIC ETHICAL RULES FOR PURCHASES

Purchasing is the formal process of buying We believe being compliant with all applicable
goods and services. It usually starts with a laws and regulations and having high ethical
demand or requirements. In general, the pro- standards is the way to secure the long-term
cess includes 7 main steps: success of ARaymond.
These standards are detailed in the Code of
ALL 1. The definition of the specifications (RFD/RFI); ALL
Conduct & Ethics.
2. Sourcing and analysis of the supplier market;
ARaymond understands that its Employees
3. The definition of the purchasing strategy; know instinctively what is right and what is not.
Our general rule is, if something doesn’t feel
4. The selection of suppliers: check the
right, don’t do it.
supplier financial aspect and sign the NDA
agreement if needed;
5 - PURCHASE FORM
5. Due diligence checks on conflicts of interests
and integrity of the business partner; Ensure that all purchases comply with the
ARaymond Network Collaboration guidelines
6. The negotiation; PLANT and reviewed by direct management.
COMPANY
7. The contract deployment, PO and supplier Procedure of PR has to be applied for all pur-
development. chase forms.
SAP entities: 6 - QUOTATION FOR CAPEX
Specific procedure with Purchase Request (PR)
and Purchase Order (PO). One time vendor to All CAPEX has to have 3 different quotations
be used only exceptionally, refers to a specific with a minimum of 2 to be compliant with
procedure. NETWORK
ARaymond Network guidelines. The country or
ATOMS principles should be the base of
COMPANY BU will have to adapt it according to the sub-
Business Support organisation (transversal flow category and the amount defined locally with
orientation, value creation, autonomous team). a procedure.

7 - MOLD & TOOLS PURCHASE

All moulds & tools purchases must have 3
2 - ENGAGEMENT DELEGATION PROCESS different quotations with a minimum of 2 to be
Ensure that Delegation matrix has been imple- COMPANY
compliant with ARaymond Network guidelines.
mented with threshold for PR and PO. For M&T the Customer PO is required before
PO. The country or BU will have to adapt it
NETWORK according to the sub-category and the amount
COMPANY
defined locally with a procedure.

8 - OVERHEAD & SERVICES PURCHASE

3 - GENERAL PURCHASE CONDITIONS
All overheads must have 3 different quotations
The current general purchasing terms and with a minimum of 2 to be compliant with
conditions have to be reviewed and approved ARaymond Network guidelines. The country or
by both the Finance and Legal departments. NETWORK
NETWORK COMPANY BU will have to adapt it according to the sub-
COMPANY category and the amount defined locally with
a procedure.

8
9 - SUPPLIERS PAYMENT IN ADVANCE 15 - SUPPLIER INSURANCE
Mostly applied for CAPEX, all payments made Ensure that we obtain all the supplier insurance
in advance have to respect the SAP down certificates, and control their level of coverage
payment process. annually.
NETWORK COMPANY
COMPANY

10 - CREATION OF A SUPPLIER ACCOUNT 16 - GIFTS & INVITATIONS OFFERED OR RECEIVED

Creation of a new supplier account, we must The current threshold for gifts, business meals,
have a formal authorization with an approval invitations and other Benefits is 50 € / per
by the purchasing department and with credit person. No gift or invitation should be received
COMPANY COMPANY
analysis and integrity evaluation. or offered regularly.
In the event of any gifts or invitations payed
for with an expense note, the information
provided must be sufficiently detailed to ensure
transparency and appropriate controls may be
operated correctly.
11 - SUPPLIERS COMPETITION AND RATING Any gift or invitation > 50€ should be declared
At least once a year, your relevant suppliers on the Safecall Gift & Invitation Platform.
must be evaluated (audit / rating check list,
internal evaluation, credit & integrity analy-
COMPANY
sis…).
Always promote competition (negotiation,
contracting, risk and control on cost) to have
the best TCO (price, quality, service). SAPIN 2 – LEVEL 2

17 - CONSULTING FEES
Testing of a selection of consulting fees based
on location of the services, nature and value of
services rendered is required.
12 - SUPPLIER BANK DETAILS MODIFICATIONS
COMPANY
Ensure that you check with your regular
contact of your supplier before ALL bank details
modifications. The SAP double checks have
COMPANY
to be done after this control (phone / email / 18 - GIFTS OR INVITATIONS OFFERED
confirmation letter). OR RECEIVED
We expect that our Employees or anyone
acting on our behalf, do not offer, grant or
accept any benefits that could be considered
as inappropriate or could result in improper
performance of the person’s professional duties.
13 - PURCHASE COSTS VARIATION COMPANY
Not recommended & must declare via the
The purchasing department have the possibility SAFECALL gift & invitation platform when the
to provide all the information, documents, files, amount per person if > 50 €
graphics etc. in order to explain the RM prices www.safecall.co.uk/gift
COMPANY
evolution that impact our P&L. Id : Araymond
Password : Araymond
Please refer to anti-corruption guideline.

14 - SECURING PLAN FOR SUPPLIER

It is highly recommended to deal with several
suppliers to avoid mono-sourcing.
The world wide double source initiative should
COMPANY
allow us to better secure our business ; (to be
check locally)

9
 2 CAPEX AND LT LEASE
AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:
• NCG’s note 6 • Error on depreciation method
• ARaymond Network Accounting Manual • Investment not approved
• Capital expenditure process in ARaymond • Intellectual Property
• Standard specifications for CAPEX 

1 - CAPEX PROCEDURE 5 - AMORTIZATION RULES

The primary objective of the procedure Capital Useful life is the period over which an asset is
expenditure process in ARaymond and ARay- expected to be available for use by an entity.
mond Network Accounting Manual is to esta-
PLANT For start of depreciation and useful life duration
blish and maintain a framework for evaluating, COMPANY
please follow the ARaymond Network Accoun-
selecting and funding Capital Projects but also
ting Manual.
ALL to establish uniform depreciation methods and
estimated useful lives. Any unused asset not fully amortized or if a
shorter useful life is identified then an impair-
All CAPEX have to be requested and validated
ment should be calculated and booked accor-
by local management. If >50k€, validation is
dingly. Network CFO must be informed when
mandatory by Finance, Operations and Purcha-
the amount is over 50K€.
sing Officers (except M&T).
Any equipment installed in the factory free of
charge for testing purposes with the intention
to buy has to follow the same CAPEX approval
process. 6 - MOLDS & TOOLS PROTECTION
Access to molds and tools must be limited, pro-
tected against flood and fire and the ownership
2 - CAPEX MONITORING PLANT is easily identifiable.

All CAPEX have to be monitored in the ERP

accounting system individually (with all CAPEX
related costs).
NETWORK
COMPANY
7 - ASSETS DISPOSAL
The Finance department approves the asset
disposal and updates the accounting asset
3 - MOLDS & TOOLS ACCOUNTING PROCESS ledger with proper documentation.
PLANT
COMPANY
All M&T investment costs include all direct costs
including internal costs such as time spent by
tooling department to create the asset.
NETWORK
COMPANY
Accounting process is based on the M&T 8 - ASSET MAINTENANCE
ownership: asset or inventory. All strategic assets must have a maintenance
Please refer to the ARaymond Network Accoun- plan and/or contracts.
ting Manual. PLANT
COMPANY

4 - ASSET INVENTORY
The asset inventory has to be carried out at 9 - LONG TERM LEASE
least every 5 years. This inventory has to be Any long term lease over 12 months where the
reconciled with the asset accounting ledger. original amount is above 50 K€ must follow the
Any corrections have to be validated by the same treatment for authorization as a regular
local Finance and Operations managers. capital expenditure.
ALL
ALL

10
 3 FINANCE
AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:
• ARaymond Network Accounting Manual • Inadequacy of terms of local or international law / norms
• NCCP with AR Network requirements

• NCG’s • SOD conflicts

• Procedures related to Reporting/Consolidation • Frauds / corruption / errors

• Code of Conduct & Ethics

• Anti-corruption Guideline

1 - NETWORK ACCOUNTING MANUAL 5 - ERP AND REPORTING MATCH

The Manual defines all ARaymond accoun- Ensure the accounts are comprehensive
ting principles and reporting rules. It is then between ERP and BOARD and follow Network
considered as the reference for all AR Network accounting rules.
accounting matters. These policies are appli-
cable to all ARaymond Network’s entities.
ALL ALL
Any deviation to these policies should be dis-
closed and approved by the Network CFO and
coordinated by Network Accounting Manager. 6 - STATUTORY CONSOLIDATION PROCESS
It is the responsibility of local controllers to en- The consolidation perimeter has to be known
sure the accuracy of their respective reporting by all the people involved in the process.
and financial statements in accordance with PLANT Reconciliation between local accounting rules
the ARaymond Network Accounting Manual. COMPANY
and consolidation must be documented.
Intercompany account balances should be
declared in the BFC system using the ARay-
mond Network reporting package line items.
2 - PAYABLES, RECEIVABLES & LOANS
REEVALUATION Intercompany accounts should be reconciled
at least twice a year (October month-end
All your payables, receivables and loans in and December month-end) and any invoice
foreign currency have to be evaluated monthly received by a sister company must be booked
at the closing rate sent by the Network accoun- during the same period for all.
NETWORK
COMPANY ting manager.

3 - GRANT, INCENTIVE 7 - SEGREGATION OF DUTIES

Any request for a grant or incentive shall be first All entities should implement SAP SOD
authorized by the Network CFO. If any commit- SUSAND and must reach and maintain silver
ment has been taken, please report status every certification.
COMPANY
NETWORK
COMPANY
year to the Network Accounting Manager. Any company not using SAP must respect SOD
standards.

4 - CREDIT CARD
A procedure that defines who, what and how 8 - OFF-BALANCE SHEET COMMITMENTS
(uses / thresholds etc. ...) must be in place. Any off balance sheet commitments such as
COMPANY Credit cards should be linked to the personal guarantees from/to bank, long term lease,
bank account and must only be used for profes- mortgage, swap, exchange rates hedging, pen-
NETWORK
sional expenses. A temporary card verification COMPANY sion… must be approved by Network CFO.
code (CVC) is recommended.

11
9 - BANK RECONCILIATIONS 15 - FRAUD
The bank reconciliation has to be done regu- In the event of an attempted fraud, inform both
larly, verified and approved by the Finance the Internal Audit & Control Department and
manager or MD (if Finance manager is alone) the Risk & Compliance Department.
COMPANY
for all banks and all accounts.
In the event of evidence of fraud, inform both
the Internal Audit & Control Department and
ALL
the Risk & Compliance Department and the
Network CFO.

10 - PAYMENT >1500€ 16 - ATOMS

For all payment file/run/campaign > 1500€ or ATOMS principles should be the base of
currency equivalence, a double signature is Business Support organisation (transversal flow
mandatory to release payment to the bank. orientation, value creation, autonomous team).
COMPANY

ALL

11 - BANK ACCOUNTS OPENING AND CLOSING

Only the Network CFO may authorize a new SAPIN 2 – LEVEL 2
bank partner.
COMPANY Obligation to inform the Network Accounting 17 - TAX FINE
Manager before opening an new account in an
existing bank or closing an account. A testing on a selection of the tax fine have to
be performed on the same period and country
where payment occurred.
COMPANY

12 - PETTY CASH
18 - LOCAL ANALYTICAL REVIEW
It is not recommended to have petty cash in
All key variations are explained and docu-
place in local entity. If one exists, all operations
mented on a periodic basis as an analytical
have to be justified, limited in terms of amounts
COMPANY review of BS and P&L of your activity and valida-
/ nature and a petty cash inventory has to be COMPANY
ted by the MD.
operated and approved at least quarterly.
On a quarter basis, the Finance Manager for-
malizes the review of Gifts offered / Consulting
fees / Customs duties / Tax fine, commercial
intermediaries and donations and sponsoring
accounts (political contributions are strictly
13 - STATUTORY AUDITORS forbidden by AR Anti-corruption Guidelines).

All network companies are required to provide

to the Network CFO and the Network Accoun-
ting Manager the external audit report.
COMPANY
Any change of auditors must be approved by
Network CFO. 19 - REPORTING REVIEW
All comments or observations have to be A quarterly periodic review must be performed
reported to the Network CFO and the Network by the corporate finance department inclu-
Accounting Manager. ding an analytical review then reporting P&L
NETWORK
and BS and other KPIs are by finance manager,
reviewed by MD and presented to the corpo-
rate. This review must be formalized.

14 - TAX AUDIT
Any new audit from Tax must be reported to
Network accounting manager and Network
CFO when announcement is received.
COMPANY

12
 4 SALES & ENGINEERING
AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:
• NCG’s note 2 and 3 • Inadequacy of terms of local or international sales
• Procedure related to new customer registration/Master contracts with AR Network’s clients
file change (client ID form). • Quality
• Code of Conduct & Ethics • Negative margin
• Anti-corruption Guideline • Fraud / Corruption
• Conflict of Interest Guideline • Infringements with respect to Personal & Company
• Automotive Pricing Tool data protection

1 - BASIC PRINCIPLES 3 - MASTER DATA

All deals have to have a contract. CLIENT MASTER DATA:
The access to the client master data file
All contracts generate an invoice and all has to be limited to a restricted number of
PLANT
deliveries generate an invoice (a review of COMPANY employees, secured and only with authori-
delivery or services without invoice should zation from Sales manager or MD.
ALL be performed).
A process has to exist for the creation of a
Always use the current sales terms and client in the database. All client database
conditions validated by the Legal depart- modifications have to be validated by the
ment. Sales manager or MD.

All sales agreements have to be validated by

the legal department.
All business is to be conducted in an ethical PRODUCT MASTER DATA
and legal manner. CAD DATA Management :
CAD Data creation and management (3D
GAM instructions have to be validated by models and Drawings and CAD related
the legal department and correctly imple- documents) should be done following
mented. Guidelines mentioned in P08
ATOMS principles should be the basis of (https://araymond.jiveon.com/docs/
Business Development organisation (flow DOC-9501)
orientation, value creation, autonomous
team). Product Creation process:
Product creation process should be done
following guidelines mentioned in NP09
(https://araymond.jiveon.com/docs/
2 - TRANSFER PRICING RULES DOC-8899)
The Data Premium Classification Code pro-
Calculation of AR Network Intercompany cess has to be respected (Catia/Creo).
prices has to respect the process defined in
the current ARaymond NCG’s. Engineering Resources sharing:
When required, Engineering resources
needs should be addressed using PSP tool
ALL
and following the procedure embedded
into the tool.
http://psp.ar.ray.group/psp.html

13
4 - ADVANCED PAYMENT 11 - GIFTS OFFERED OR RECEIVED
Any advanced payment for obtaining a custo- Employees should not offer or accept gifts that
mer contract is forbidden (except where valida- are not in line with the restrictions as defined in
tion has been provided and contract signed by the Anti-corruption Guideline.
NETWORK COMPANY
COMPANY MD, Network BDO and Network CFO). The current Netowkr threshold for gifts, busi-
ness meals, invitations and other Benefits is
50 € / per person. No gift or invitation should
5 - CLIENT OVERDUE PAYMENTS be received or offered regularly.
In the event of any gifts or invitations payed
Client overdue payments are managed in the for with an expense note, the information
client database and followed at a local level and provided must be sufficiently detailed to ensure
reminders sent on a monthly basis. transparency and appropriate controls may be
NETWORK
COMPANY operated correctly.
Any gift or invitation > 50€ should be declared
6 - CLIENT OUTSTANDING on the Safecall Gift & Invitation Platform.

The client outstanding has to be followed on Any local procedure must contain the following
daily basis and a process exists in case of client points: Dedicated thresholds, People authorized
outstanding excess, taking into account the to offer gifts, Nature of gifts, Approval workflow
NETWORK
credit limit of that client. & Restricted periods and frequency.
COMPANY
ARaymond only permits Benefits in the form of
gifts or invitations to cultural or sports events.
7 - CASH COLLECTION No Benefit should represent a significant per-
sonal value for the person receiving or offering
A cash collection procedure has to be in place, the gift or benefit.
with specific client review by the Sales manager All gifts have to be declared and recorded in a
and his/her team. dedicated account with accurate and detailed
NETWORK
COMPANY wording.

8 - PRICE SETTING
SAPIN 2 – LEVEL 2
Automotive direct customer pricing should be
set by using the Pricing Tool and in line with the 12 - MARGIN LEVEL AND PROFITABILITY
local Pricing Guideline agreed margin levels.
NETWORK
COMPANY
(http://pricingtool.ar.ray.group/pricingtool. On a monthly basis, the Finance manager for-
html) malizes the profit level by reference/client and
carries out a review with the MD.
For other markets, margin level must be vali- COMPANY
dated locally by Sales Manager and by MD if
under defined threshold. 13 - GIFTS OR INVITATIONS OFFERED OR RECEIVED
Referring to point 11, a Testing on a selection of
gifts based on risky population, specific periods
9 - CREDIT NOTE (e.g. tender process), nature and value of the
COMPANY
A credit note procedure has to be in place. gift offered has to be performed quarterly.
All credit notes have to be documented and We expect that our Employees or anyone
justified. acting on our behalf, do not offer, grant or
NETWORK
COMPANY • Quality issue: Quality manager approval accept any benefits that could be considered
• Price variance: Sales manager approval as inappropriate or could result in improper
• Rebates: contract approved and signed by performance of the person’s professional duties.
Sales manager and MD.
Not recommended & must declare via the
SAFECALL gift & invitation platform when the
amount per person if > 50 €
10 - COMMERCIAL INTERMEDIARIES www.safecall.co.uk/gift
& DISTRIBUTORS Id : Araymond
Password : Araymond
In case of use, a Commercial Intermediaries or
Distributors contract has to be implemented Please refer to anti-corruption guideline.
including:
NETWORK
COMPANY
• Definition of services and associated revenue;
• Limits on commissions paid; 14 - COMMERCIAL INTERMEDIARIES
• Agreement with anti-corruption clauses; Referring to point 10, a testing on a selection of
• Specific control regarding payments. commercial intermediaries based on : location,
The selection & evaluation process for new or nature of services, fees and percentage of
NETWORK
existing partners must include screening with remuneration has to be performed quarterly.
respect to AR Code of Conduct & Ethics.
See refer to Risk & Compliance requirements.

14
 5 HUMAN RESOURCES

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• HR Global Reporting Handbook • Inappropriate / unauthorized
• AR Network Travel Policy recruitment or compensation and benefit

• International SOS training • Payroll system modifications

• Code of Conduct & Ethics • Inappropriate expense reimbursement

• Anti-corruption Guideline • Fraud / Corruption

• Conflict of Interest Guideline • Infringements with respect to Personal

& Company data protection
• ATOMS

1 - HR PROCEDURE 4 - PAYROLL IT SYSTEM

HR procedures must define the following topics : The access to the payroll system has to be secu-
• Recruitment red with a restricted access according segrega-
• Training & development with respect to opera- tion of duties rules.
tional, legal or regulatory requirements
Any changes to Payroll outsourcing has to be
• Departure
declared to Finance & HR corporate.
ALL • Local regulation monitoring ALL
• The minimum documentation expected for a
new employee 5 - PAYROLL FRAMEWORK
• HR data management in compliance Network On a monthly basis, Finance department
standards (ex. GDPR) match : calculated pay / uploaded pay / paid
• Key people back up / continuity plan amount and perform a pay analytical review.
PLANT
ATOMS principles should be the base of COMPANY
Business Support organisation (transversal flow
6 - TRAVEL POLICY AND EXPENSE
orientation, value creation, autonomous team)
Travel Policy and Expense process are under the
responsibility of HR department, the control is
2 - TEMPORARY AND PERMANENT RESOURCES performed by Finance department.
A procedure has to be in place to validate the Expense claims must be subject to hierarchical
requirements and qualifications of staff recruit- validation and documented justification.
ments. ALL
In the event of any gifts or invitations, the infor-
NETWORK
COMPANY All recruitment requests have to be approved mation provided must be sufficiently detailed
by local HR (for temporary) and corporate HR to ensure transparency and appropriate
(for permanent positions). controls may be operated correctly according
compliance rules.
All employment contract templates have to be They must be reviewed and approved by
reviewed and approved by a labor law lawyer. manager (including for MD).
Fixed and variable remuneration have to be The highest level of management must pay
approved by Local HR. expenses for events or invitations where a num-
MD Compensation and Benefits package is ber of ARaymond personal are present.
managed by corporate HR. Automatic blocking controls have to be in
place in the Expense management software
(e.g.: expense greater than authorized amount).
3 - PAYSLIPS
All these topics has to be checked by local
All payslips have to be produced at least once a Controller.
month and according to local regulation.
NETWORK The different payroll topics such as shift pre- 7 - ANNUAL REVIEW
COMPANY mium , days off, sickness, salary A formalized annual review has to be realized
increase are handled by HR under local mana- with each employee once a year to debrief the
gement accountability and local controller achievements and discuss new objectives.
control

ALL

15
 6 HEALTH, SAFETY, ENVIRONMENT

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• Procedure related to new supplier registration • Lack of efficiency
and Master file change (supplier ID form) • Business relationship
• Internal Environmental Guidelines • Human
• Internal Health & Safety Guidelines • Continuity of activity
• Code of Conduct & Ethics • Fraud / Corruption
• Anti-corruption Guideline • Infringements with respect to Personal
& Company data protection
• Conflict of Interest Guideline
• ATOMS

1 - INTERNAL ENVIRONMENTAL GUIDELINES / 4 - FIRE AND SECURITY

INTERNAL HEALTH & SAFETY GUIDELINES
Management of dangerous products starts with
Internal environmental guidelines and internal a secure storage area.
health & safety guidelines have to be in place, PLANT Fire detection systems must be in place, opera-
known and applied by every AR employee in COMPANY
tional and verified by an external company. Fire
their daily work.  fighting equipment is easily identifiable and
Leadership in Energy and Environmental Design accessible.
ALL
is known and applied. Furthermore, ensure that a fire alert procedure
is implemented and an evacuation exercise is
carried out at least once a year.

2 - HEALTH, SAFETY & ENVIRONMENT PROGRAM M&T have to be stored in a dedicated fired
secured area.
A local correspondent must be identified.
In case of certification, an HSE program exists
PLANT and is audited independently.
COMPANY
A yearly report has to be produced and provi- 5 - ENVIRONMENT
ded to the local management.
In an approach to reduce the environmental
ATOMS principles should be the basis of busi- impact, HSE people have to implement indica-
ness organisation (transversal flow orientation, tors to follow water & energy consumption and
value creation, autonomous team). PLANT
COMPANY savings.
An environmental impact study relative to the
company’s activities on the neighborhood
3 - HEALTH AND SAFETY should be carried out.

Safety rules have to be explained, shared, LEED Silver certification is required for new
displayed and reminded frequently to mitigate buildings.
professional risk and health exposures.
PLANT
COMPANY Individual protective equipment has to be worn
by all employees and visitors on site.
Machines have to be correctly protected and
verified frequently.
Safety figures have to be reported on a monthly
basis through the global tool, available in the
SHARE group “Environmental and Safety team”.
Incidents have to be shared among the team
upon occurrence.

16
 7 QUALITY

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• NCG’s note 4 • Lack of efficiency
• Procedure related to new supplier registration • Business relationship
and Master file change (supplier ID form) • Continuity of activity
• Red Alert Form • Fraud / Corruption
• Code of Conduct & Ethics • Infringements with respect to Personal
• Anti-corruption Guideline & Company data protection
• Conflict of Interest Guideline
• ATOMS

1 - INTERNAL ENVIRONMENTAL GUIDELINES / 4 - QUALITY SYSTEM / QUALITY CULTURE

INTERNAL HEALTH & SAFETY GUIDELINES
The organization must be formalized and
High quality delivery starts with : enables ARaymond to meet the business
• Supplier selection follows a formalized decision purpose.
COMPANY
process (criteria); The implementation of a quality system must
NETWORK
COMPANY • Control of the incoming product quality; be considered.
• Quality controls performed during and at the
end of the manufacturing process; When the company has a quality system, it
• Specifications have to be defined by dedicated is based on the latest version of the market’s
& qualified people; referential.
• Certification audits are performed by inde- The quality system must be owned by the MD.
pendent agencies;
• Quality program is in place; Quality culture principle is based on “Bien Faire”
• Process exist for items that fail quality criteria; Quality Mindset.
• Supplier audits; ATOMS principles should be the base of busi-
• Serial deliveries are conditioned by the formal ness organization (transversal flow orientation,
approval of the PPAP by the partner/customer; value creation, autonomous team).
• AQP status is given after 3 consecutive and
different successful batches.

5 - CLIENT INCIDENTS
In the event of a major incident, a Red Alert
Form has to be formalized by the entity
2 - SUPPLIER SELECTION involved and communicated to all the mana-
PLANT
COMPANY gement team (Raygroup Officers + Quality
All suppliers should be selected through a Coordinator + Risk & Compliance Manager).
robust selection process.
At Network level specific insurance contracts
NETWORK AR entities (partners) are treated as Supplier/ have to cover the potential first and third party
COMPANY Customer (serial deliveries conditioned by PPAP financial exposures.
approval between entities).

6 - NON QUALITY
The entity has a structured problem solving
activity (based on QRQC). The entity shares its
3 - SUBCONTRACTING SERVICE QUALITY lesson-learned (LLC) with sisters companies.
PLANT
There must be a robust selection process for COMPANY
The Local Management has to follow monthly
subcontractors based on commonly agreed KPI (e.g. number of incident, cost of non qua-
criteria by dedicated and skilled personnel. lity, …)
NETWORK
COMPANY Organization and processes have to be in place Quality improvement plan related to this Qua-
to ensure a high quality of service. lity KPIs must be in place.

17
 8 LEGAL

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• NCG’s note 2 • Continuity of activity
• Anti-corruption guidelines • Business relationship
• Code of Conduct & Ethics • Fraud / Corruption
• Anti-corruption Guideline • Infringements with respect to Personal
• Conflict of Interest Guideline & Company data protection

• ARaymond Network accounting manual

• ATOMS

1 - EXTERNAL LEGAL ADVISOR 6 - NETWORK COMPANY

The external legal advisor and the standard daily Articles of association may only be produced
fees for Commercial, Corporate and IP have to be and held by the Corporate Legal department.
approved by the Corporate Legal department. Certified or standard copies may also be held
NETWORK
locally.
The HR legal matters (Labor law) are covered by COMPANY

the HR department with external legal support. Companies may only be created following the
ALL The Fiscal legal matters (Tax) are covered by the validation of Corporate Legal department &
Finance department with external legal support. Presidency.
Any changes/modifications related to the
2 - CLAIMS Companies (corporate matters: change of HQ
address, etc.) need to be notified to the Corpo-
All the Commercial, Corporate and IP claims rate Legal department
must be managed according to the Claims
Management Procedure (in progress) as defi- All other Network companies’ legal documen-
ned by the Corporate Legal department. tation related to Corporate law are held by the
Corporate Legal department in the Headquar-
ALL ter in Grenoble.

3 - DISCLOSURE
A non disclosure agreement (NDA) has to be 7 - ATOMS
systematically used in your business relation-
ships. ATOMS principles should be the base of
The standard AR NDA and confidentially Business Support organization (transversal flow
contracts should preferably be used. orientation, value creation, autonomous team).
ALL Any deviation from this practice should be
validated by Legal department.
ALL
4 - CONTRACTS
All contracts should be managed according
to the Contract Management Procedure using
the Enterprise Content Management (ECM) SAPIN 2 – LEVEL 2
platform (replacing LYS).
8 - LEGAL AND ADVISORY FEES
ALL
Testing of a selection of consulting fees based
5 - IP AND LICENSES on location of the services, nature and value of
services rendered is required.
Ensure that all Intellectual property or license COMPANY
transfers are approved by Corporate Legal
department.
All patents are filed by the Corporate Legal
department.
ALL Any local filing must be approved by the Legal/
IP Department.

18
 9 RISK & COMPLIANCE

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• NCG’s • Fraud / Corruption
• Code of Conduct & Ethics • Infringements with respect to Personal
• Anti-corruption guidelines & Company data protection

• Conflict of Interest Guidelines • Continuity of activity

• Whistleblower procedure • Business relationship

• ARaymond Network Accounting Manual

1 - CODE OF CONDUCT & ETHICS 4 - FIRE AND SECURITY

The Code of Conduct & Ethics should be disse- Due diligence serves two purposes:
minated with the organization and incorporated 1. It informs the decision to start, continue
into the training provided to the organization’s or end a business relationship;
employees. 2. It enhances the effectiveness of measures to
Insofar as the Code of Conduct & Ethics is used prevent and detect corruption implemented
ALL
to define the compliance required of employees, ALL on the basis of the risk map & third party due
it should be incorporated into the employment diligence.
regulations. Due diligence focuses on the third parties with
The Code of Conduct & Ethics should be made which the organization has or is about to start
available to the employees in paper and digital a relationship.
format and easily accessible via the ARaymond This includes suppliers, service providers,
intranet platform. clients, joint ventures and acquisitions.

2 - WHISTLEBLOWING 5 - TRAINING

The internal whistleblowing system is the A robust, appropriately designed internal

procedure that enables ARaymond employees training system is an effective way to embed a
to disclose potentially non-compliant behaviors culture of integrity and compliance across an
and situations to the Risk & Compliance Mana- organization.
ger. The Objective is to eliminate such beha- While compliance related training should be
ALL viors and situations and to impose sanctions ALL geared towards managers and employees with
where appropriate. the greatest exposure, it is nevertheless useful
to raise awareness of the issues throughout an
Information concerning the Whistleblower organization’s workforce.
system should be made available to the em-
ployees in paper and digital format and easily A training oversight process can help organiza-
accessible via the ARaymond intranet platform. tions maintain high standards and ensure that
training provision is effective.
3 - GLOBAL & CORRUPTION RISK MAPPING A training plan should be defined and imple-
mented to ensure that all staff members have
Each ARaymond entity should have an updated completed the necessary compliance related
Global Risk Map and also a Corruption Risk Map. training and understood the content.
Risk Mapping helps ensure a more secure busi-
ness model, insofar as: 6 - PERSONAL & COMPANY DATA PROTECTION
It provides knowledge of the organizations ARaymond is responsible for ensuring the pri-
ALL
specific internal & external risks and of the vacy and protection of personal and company
managerial, operational and support processes data.
for its activities; Registers and procedures must be in place and
Risk mapping requires identifying the roles and regularly updated to identify and detail :
responsibilities of the players involved at every 1. The data treatments and their finalities;
ALL
level of the organization. 2. The data subjects information requests;
Each Risk Map should have an associated 3. The data breaches that have been detected.
Action Plan the defines the risk owner, actions, Data Protection Impact Assessments should
deadlines and appropriate KPIs. be carried out when necessary and updated
The Risk Maps & Actions plans are reviewed as required upon a change in an aspect of the
regularly by the Management team. data treatment.

19
7 - COMMUNICATION & AWARENESS SAPIN 2 – LEVEL 2
A compliance communication & awareness
plan should be defined annually and its delivery
9 - CODE OF CONDUCT & ETHICS
monitored. The code of conduct is available in both
paper format and easily accessible via the
intranet.
NETWORK
ALL
COMPANY
Information concerning the code of conduct,
whistleblowing and other compliance sys-
8 - CHARITIES CONTRIBUTIONS - LEVEL1 tems is posted so that ARaymond personnel
are appropriately informed.
A donation and sponsorship practices including
content agreement, contractual formalization,
authorization and validation levels are defined
in the Anti-corruption guideline. 10 - GLOBAL & CORRUPTION RISK MAPPING
Where possible the validation workflow for The Global and Corruption Risk Maps have
ALL
donations and sponsorship should always been produced and updated.
follow the process as defined in SAP. Risk owners have been identified.
Political contributions are strictly prohibited. Actions plans have been defined and imple-
mented.
COMPANY KPIs relative to the action plan level of com-
NETWORK pletion are updated regularly.

11 - EVALUATION OF BUSINESS PARTNERS

Due diligence campaign on the third parties
has been carried out correctly for suppliers,
service providers, clients, joint ventures and
NETWORK
COMPANY
acquisitions.

12 - TRAINING
The Risk & Compliance manager (or person
designated manager) ensures that the
compliance related training programme is
NETWORK
COMPANY
working as it should and in particular that the
right module types and formats are being
delivered at the prescribed frequency.

13 - CHARITIES CONTRIBUTIONS
Referring to point 8, a “testing” on a selec-
tion of contributions and should take into
account :
NETWORK specific period (e.g. tender process);
COMPANY
nature and value of the contribution.
With respect to sponsorships, testing on
counterpart effectiveness and proportionality
of the counterpart have to be performed by
the controller.

20
 10 IT

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• Code of Conduct & Ethics • Fraud / Corruption
• Anti-corruption guidelines • Hacking
• Conflict of Interest Guidelines • Revenue leakage
• Network IT Committee minutes • Strategy
• IT Terms of use • Continuity of activity
• IT Server Rooms standard • Infringements with respect to Personal
• ATOMS & Company data protection

1 - NTIC 5 - IT AREA
The Network IT Committee (NITC) minutes are The local IT Server rooms must respect the
produced and shared with the EXCO members. AR Network IT Standard. This area should be
restricted to authorized persons and protected
PLANT
COMPANY against fire and water damage.
The Raynet back up process has to be respec-
ALL
ted and physically kept outside of the site.
2 - IT SYSTEM CARTOGRAPHY
An IT system cartography is in place detailing the
infrastructure, the systems and the applications. 6 - CYBERSECURITY
The links between these different elements are
The current IT terms of use have to be signed
explicit in order to identify and manage potential
by all employees.
risks to the Network’s activity.
ALL
To protect the IT system and the applications
It is the responsibility of the Raynet manage-
the following points have to be respected on all
ment and the local MD to report all information
machines/computers (PC, production compu-
regarding the cartography (e.g, local internet ALL
ter, …):
access, …).
• software updated with security patches;
3 - LOCAL IT MANAGER • anti-virus regularly updated;
• firewall regularly tested;
A local IT manager or contact has to be named • anti-intrusion tests performed regularly;
to be the liaison to Raynet and in capacity to • back ups kept outside of the site;
manage IT rights. • emergency line exists between the headquar-
PLANT
ters and the subsidiary;
COMPANY The local IT manager is in charge of local appli-
• IT exploitation continuity plan is implemented,
cations, local back up, IT access rights review
maintained and tested regularly.
(ID and password), test environment and IT
incidents). Under the responsibility to the local IT Manager,
all hardware supplied by an external manu-
A periodic review of IT access rights has to be
facturer and including network connection
performed in coordination with Raynet in order
must be connected by Raynet and not by the
to identify and correct any anomalies.
supplier (eg, press, coffee machine...).
ATOMS principles should be on the basis of
Business Support organization (transversal flow
orientation, value creation, autonomous team).
7 - IT CERTIFICATION (ISO 27001)
4 - BUSINESS CONTINUITY
In 2019, the 5 year ARaymond IT objective plan
Ensure that an automatic back up process for all is to achieve the certification ISO 27001 for all
data is in place and operational. ARaymond Network locations.

PLANT An IT hotline has to be operational and available

COMPANY to all subsidiaries.
ALL
The connectivity to Internet must be approved
by Raynet and include 2 physical lines with a
back up line from a different provider.

21
 11 LOGISTICS

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• NCG’s note 5 • Penalties
• ATOMS • Lack of efficiency
• ARaymond Network Recommandation HS Code • Errors
• Incoterms 2020 CCI • Supply disruption
• Code of Conduct & Ethics • Penal risk for directors
• Anti-corruption Guideline • Fraud / Corruption
• Conflict of Interest Guideline

1 - ATOMS PROCESS 4 - CUSTOMS DUTIES

ATOMS process has to be in place within the Customs duties guidelines should describe the
logistic department to manage all logistic and process to follow, including dedicated approval
production flows. flows and appropriate documentation to be
provided and stored.
The Supply Chain Management Principle, along
with the ARaymond TOtal Management System
ALL ALL
(“ATOMS”) are the guidelines that have been
developed to assist each AR Network Entity to
reach its goal of ultimately supporting the Third
Party Customer order requirements.
5 - CUSTOMER SERVICE
An action plan to reduce lead time and lot size
has to be implemented and updated regularly. Global logistic agreement should be signed
with all customers.
PLANT ALL premium fret has to be approved by ope-
COMPANY rations or logistic manager or MD. A review has
to be in place to follow extra cost of exceptio-
2 - SALES OPERATION PLANNING nal carriage.
The process of “demand management” has to EDI connection with customers has to be per-
be implemented and known. formed whenever it is feasible.
PLANT 3 steps have to be implemented and known: Customer Demand Evolution must be moni-
COMPANY • Sales plan building (including new products/ tored with SAP IT solution available (Control
end of life) Tower).
• Production plan building (capacity analysis) An action plan to improve customer service
• Stock management (refer to point 3) level has to be performed.

3 - STOCK MANAGEMENT
The average for ARaymond Network is 35 days
coverage (including RM, WIP, SFG, FG).
PLANT A monthly review has to be done by category
COMPANY with a clear focus on slow mover and dead
stock (depletion action plan).
A cycle counting is recommended to improve
reliability of flow. All variances have to be ana-
lyzed and approved by the logistic manager/
the financial controller.

22
 12 CUSTOMS

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• NCG’s note 5.1 • Penalties
• ATOMS • Lack of efficiency
• ARaymond Network Recommandation HS Code • Errors
• Incoterms 2020 CCI • Supply disruption
• Code of Conduct & Ethics • Penal risk for directors
• Anti-corruption Guideline • Fraud / Corruption
• Conflict of Interest Guideline

1 - CUSTOMS MANAGEMENT - TRAINING 5 - CUSTOMS MANAGEMENT – EXPORT CONTROL

It is prerequisite to have a customs representa- The BDU (dual-use) and military regulations
tive and a back-up. It is necessary to cross-train (EAR / ECCN) must be known.
the finance, purchasing, sales and logistics
PLANT PLANT It is necessary to respect SPL rules and embargo
departments on customs fundamentals, fraud
COMPANY COMPANY (via GTS).
risks and criminal risks for managers.

2 - CUSTOMS MANAGEMENT 6 - CUSTOMS MANAGEMENT – INCOTERMS

– TARIF CLASSIFICATION (HS CODE)
The management of commercial contracts and
ARaymond Network recommendations in terms flows (import / export) must be based on the
of HS code (ARaymond Network Recommenda- CCI incoterms 2020 regulations.
tion HS Code) must be known and applied. PLANT
PLANT COMPANY It is recommended that you do not use the
COMPANY The design owner and family design owner EXW and DDP incoterms for international flows.
rules must be known and applied in GTS.
It is essential to respect the harmonization rules
of the Network in place since January 1, 2019.

7 - CUSTOMS MANAGEMENT – IMPORT/EXPORT

DECLARATION MANAGEMENT
3 - CUSTOMS MANAGEMENT - ORIGIN It must be ensured by monthly monitoring of
The different notions of origin must be maste- the clearance of export declarations.
red (preferential origin, non preferential origin, PLANT On import, it is necessary to ensure the pay-
country of origin, ...), COMPANY ments of levies and taxes.
PLANT
COMPANY S-LTVDs and C-LTVDs (Long Term Vendors Archiving must follow at least the local regula-
Declaration) must also be managed for the tions.
calculation of preferential origin in GTS.

4 - CUSTOMS MANAGEMENT - VALUE 8 - CUSTOMS MANAGEMENT – DEB/DES/INTRASTAT

The control of the different values (customs On a monthly basis, a declaration must be sent
value, commercial value, value for the VAT base, to customs:
etc.) is essential for the calculations of customs • DEB: introduction + shipping
PLANT
COMPANY
duties and VAT. PLANT
• DES: shipping only
COMPANY
A reconciliation between DEB and CA3 have to
be performed.

23
9 - CUSTOMS MANAGEMENT
– CERTIFICATION AEO/ C-TPAT
For non-AEO entities, it is recommended to
pass the FULL certification (future prerequisite),
PLANT For certified entities, it is necessary to ensure
COMPANY the respect and the application of the proce-
dures allowing to proceed to the renewal every
3 years.

10 - CUSTOMS MANAGEMENT
– CUSTOMS AUTHORIZATION
It is necessary to strictly follow the customs
authorizations and put in place the correspon-
ding procedures.
PLANT
COMPANY

11 - CUSTOMS MANAGEMENT
– CONSIGNMENT STOCK
A strict management of the consignment
stocks must be done according to the customs
and fiscal regulations and this according to the
PLANT
COMPANY countries concerned.

24
 13 MANUFACTURING

AR NETWORK NORMS / PROCEDURES: KEY RISKS / CONCERNS:

• NCG’s note 5 • Inadequacy of accounting inventory
• ARaymond Network accounting manual and real inventory

• NCCP • Security stock

• ATOMS • Supply disruption

• Standard specifications for CAPEX 

• Code of Conduct & Ethics 
• Anti-corruption Guideline
• Conflict of Interest Guideline

1 - PROCUREMENT MANAGEMENT 4 - STORAGE AREA

The procurement management is only perfor- This area, especially for FG product, should be
med by procurement assistant (Segregation Of restricted to authorized persons.
Duties with the purchase department).
PLANT
COMPANY The procurement assistant follows a production
prevision plan according to the demand mana-
ALL
gement process.
For all orders, the procurement assistant checks 5 - INVENTORY MANAGEMENT
if the delivered quantity matches with the orde-
red quantity. The level of stock is defined according to the
demand management process.
A regular inventory should be done by area. The
PLANT
COMPANY cycle counting is recommended.
2 - NOMENCLATURES Inventory gaps should be approved by the
Logistic Manager or the MD.
The production nomenclatures (BOM and
Ensure that an inventory valuation is carried out
Routing) have to be correctly uploaded into the
and that obsolete references or slow movers
PLANT system. The nomenclatures (BOM and Routing)
are depreciated following the Network rules.
are reviewed, corrected and updated after the
test production (3 serial runs).

6 - STOCK FOLLOW-UP
3 - MANUFACTURING MANAGEMENT
Ensure that stock levels (RM and component,
RAYPRO is used to monitor and control the WIP, FG) / critical items / stock rotation and
manufacturing process (metal plastic assembly). stock destruction are followed by the person in
NETWORK
All the production gaps (variances on produc- COMPANY charge of manufacturing or logistics.
NETWORK
COMPANY tion orders) are followed and analyzed.
A formal remediation plan has to be imple-
mented concerning the key gaps. The
nomenclatures (BOM and Routing) have to
be reviewed and updated on a yearly basis at
minimum.
ATOMS principles should be the base of manu-
facturing organisation (Autonomous produc-
tion ilot) and flow management (VSM Value
Stream Mapping).
Investment should respect the harmonization
rules regarding M&T and Machines.

25
 14 SUMMARY
CONTROLS
OF SAPIN II KEY

AR NETWORK CONTACTS SAPIN II

For any question do not hesitate The French anti-corruption law addressing transparency,
to contact Raygroup : anti-corruption and economic modernization, also known as the SAPIN II
• Internal Control department law, entered into force on 9th of December 2016.
The law stipulates that companies must establish an anti-corruption pro-
• Risk & Compliance department gram and implement comprehensive measures to prevent and detect acts
• Network Officers of corruption or influence peddling in France or abroad.
• Network Coordinators Contacts :
Risk & Compliance Manager, Raygroup

1. PURCHASE 7. QUALITY
Level 1 Level 1
1. Purchase procedure N/A
3. General purchase conditions Level 2
4. Specific ethical rules for purchases N/A
8. Overhead and services purchase 8. LEGAL
ALL 10. Creation of a supplier account
11. Suppliers competition and rating Level 1
1. External Legal Advisor
Level 2
17. Consulting fees (testing) Level 2
NETWORK
18. Gifts or invitations offered or received (testing) COMPANY 8. Legal and advisory fees (testing)
2. CAPEX
Level 1 9. RISK & COMPLIANCE
1. CAPEX procedure Level 1
Level 2 1. Code of conduct & Ethics
N/A 3. Global & Corruption risk mapping
NETWORK
COMPANY
5. Training
ALL
8. Charities contributions
3. FINANCE Level 2
9. Code of conduct & Ethics
Level 1 10. Global & Corruption risk mapping
1. Network accounting manual 11. Evaluation of business partners
7. Segregation of duties 12. Training
9. Bank reconciliations 13. Charities contributions (testing)
10. Payment >1500€
10. IT
ALL 12. Petty cash
Level 1
Level 2
N/A
17. Tax fine (testing)
18. Local analytical review Level 2
19. Reporting review N/A
4. SALES
11. LOGISTIC
Level 1
Level 1
1. Basic principles
N/A
3. Master data
NETWORK
9. Credit note Level 2
COMPANY
COMPANY N/A
Level 2
12. Margin level & profitability (analytical review)
13. Gifts or invitations offered or received (testing) 12. CUSTOMS
14. Commercial intermediaries (testing) Level 1
5. HR N/A
Level 1 Level 2
6. Travel Policy and Expense N/A

COMPANY 13. MANUFACTURING

6. HSE Level 1
Level 1 N/A
N/A Level 2
Level 2 N/A
N/A
26
NOTES

27
CONTACT [email protected]