Audits, Feedback & Control Mechanisms
External Audits - Control mechanisms at the management level: Periodically, internal financial reporting audits are themselves audited to ensure they are effective. These high-level audits are signed off by ICL’s management and the auditor. \
Internal Audits, Feedback and Control Mechanisms
ICL maintains a Global Internal Audit (“IA”) unit which is responsible for performing internal audits in ICL’s companies worldwide. The IA unit operates according to acceptable internal audit standards and works according to a multiyear audit plan, that is updated annually based on a global risk assessment. The plan includes auditing compliance, operations, IT, HR, finance and other strategic projects at ICL. The IA unit reports to the Chairman of the Board of Directors and to the Audit and Accounting Committee. All of the reports prepared by the IA unit are transmitted to the committee where fundamental issues are discussed.
ICL also provides a “Hotline” through which employees can contact the SVP, Global IA and compliance officers directly to report issues or events that they consider improper, problematic or deviating from the provisions of the law, procedures or the Code of Ethics.
Complaints can be submitted anonymously so that employees and contractors feel free to identify problematic issues. ICL’s Hotline is operated under the auspices of the internal audit and compliance office and operates at ICL companies worldwide.
In 2017, the Company addressed 74 complaints. The complaints were addressed by different units in the Company, including its Security, Compliance and IA units, and the data was consolidated by ICL’s Internal Audits unit.
- 68 of the 74 complaints were resolved by the end of 2017.
- 75% complaints were filed by Company employees;
- 25% were filed by contracted employees;
Nature of complaints (of the 74 received):
- 53% of the complaints concerned alleged issues regarding ethics;
- 27% concerned allegedly HR related issues these were mainly addressed by the HR department;
- 7% of the complaints concerned alleged actions taken in regards to environmental, safety and health issues;
- 13% concerned alleged non-compliance of ICL’s policies;
- Of the 68 complaints resolved, about 60% were found to be substantiated or partially substantiated.
Internal Enforcement
ICL maintains compliance programs to ensure that employees follow the provisions of the laws in the locations in which the Company operates, and in accordance with the Company’s policies and procedures.
These programs include antitrust, securities, ecology, occupational health and safety, labor, anti-harassment (including sexual harassment), trade compliance, data privacy, building and construction, anti-bribery and corruption, anti-money laundering and fraud risk management. Employees are also expected to act according to ICL’s Code of Ethics.
Compliance programs are presented to ICL managers and employees on an ongoing basis. In some cases, there is a periodic assessment by external and internal entities to ensure that the programs are being implemented. An officer is in charge of each program, and the Boards of Directors of ICL and each ICL unit receive reports regarding their implementation throughout the Company.
