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Compliance

We continue to develop our compliance system and to raise awareness of it among our employees. The Executive Committee is responsible for identifying areas of compliance that are ‘key’ or ‘high risk’. Where these exist, formal centralized compliance monitoring and reporting must be implemented. The Audit Committee independently monitors the overall program of compliance activity and the reported level of compliance, assisted by Group Legal and Group Internal Audit.

The program of compliance across the Group includes self-assessments and independent audits conducted by the relevant Group functions and by Group Internal Audit. Reporting of Concerns procedures allow employees to report, in confidence, any concerns they may have on compliance.

We are committed to free and open competition and will compete vigorously but with integrity and honesty. Competition Compliance issues are managed by the Group Competition Compliance Officer. Compliance activities have included a training program for people in ‘key roles’, seen as those most likely to face competition compliance issues in their work, which is in operation Group-wide.