Accurate accounting and record-keeping


Accurate accounting and record-keeping

Honest, accurate and objective recording and reporting of financial and non-financial information is essential to the Group’s reputation, its ability to meet its legal, tax, audit and regulatory obligations, and for supporting business decisions and actions by Group companies.


Accurate information and data

All data that we create, whether financial or non-financial, must accurately reflect the transactions and events covered.

We must follow applicable laws, external accounting requirements and Group procedures for reporting financial and other business information.

This applies whether the data is in paper or electronic form, or any other medium.

Failing to keep accurate records is contrary to Group policy and may also be illegal.

There is never any justification for falsifying records or misrepresenting facts.

Such conduct may amount to fraud and result in civil or criminal liability.


Records management

Group companies must adopt records management policies and procedures reflecting the Group Records Management Procedure. We must manage all of our critical business records in line with those policies and procedures, and never alter or destroy company records unless permitted.

We should be familiar with the records management policy and procedures that apply to us.


Documenting transactions

All transactions and contracts must be properly authorised at all levels and accurately and completely recorded.

All contracts entered into by Group companies, whether with another Group company or a third party, must be evidenced in writing.

If we are responsible for preparing, negotiating or approving any contract on behalf of a Group company, we must make sure that it is approved, signed and recorded in accordance with the relevant contracts approval policy and procedures.

All documents prepared by a Group company in connection with sales of its products, whether for domestic or export, must be accurate, complete and give a proper view of the transaction.

All documentation must be retained (together with relevant correspondence) where required for possible inspection by tax, customs or other authorities, in line with the requirements of the Group Records Management Procedure and any applicable local laws.


Cooperating with external auditors

We must cooperate fully with the Group’s external and internal auditors and ensure that all information held by them which is relevant to the audit of any Group company (relevant audit information) is made available to that company’s external auditors.

Our obligation to cooperate fully with external auditors is subject to legal constraints, for example, in the case of legally privileged documents.

Otherwise, we should respond promptly to any request by external auditors and allow them full and unrestricted access to relevant staff and documents.

Under no circumstances should we provide information to external or internal auditors which we know (or ought reasonably to know) is misleading, incomplete or inaccurate.


Following accounting standards

Financial data (e.g. books, records and accounts) must conform both to generally accepted accounting principles and to the Group’s accounting and reporting policies and procedures.

Group Companies’ financial data must be maintained in line with the generally accepted accounting principles applying in their country of domicile.

For Group reporting, data must be in line with the Group’s accounting policies (IFRS) and procedures.


All data that we create, whether financial or non-financial, must accurately reflect the transactions and events covered.


Who to talk to

  • Your line manager
  • Higher management
  • Your local LEX Counsel
  • Head of Compliance: