This excerpt taken from the VOD 20-F filed Jun 14, 2007.
This excerpt taken from the VOD 20-F filed Jun 14, 2006.
The Company has established a Disclosure Committee with responsibility for reviewing and approving controls and procedures over the public disclosure of financial and related information, and other procedures necessary to enable the Chief Executive and Chief Financial Officer to provide their Certifications of the Annual Report on Form 20-F that is filed with the SEC.
Section 404 of the Sarbanes-Oxley Act of 2002 (US) requires the Company to annually assess and make public statements about the quality and effectiveness of its internal controls over financial reporting. As a non-US company, Vodafone is first required to report on its compliance with section 404 for the year ended 31 March 2007. Managements report must describe conclusions about the effectiveness of the Companys internal control over financial reporting based on managements evaluation as of the end of the Companys most recent fiscal year.
The Company has established a Steering Committee to provide strategic direction to the Companys section 404 compliance efforts and a Programme Management Office which monitors progress and provides detailed guidance to the compliance teams that have been set up in the Groups subsidiaries and central functions. The Companys Audit Committee also plays an active role in monitoring these efforts. The Audit Committee receives progress updates at each of its meetings as well as a bi-annual status presentation from the Programme Management Office. The Companys external auditors have been consulted throughout the project and will continue to be involved as the Company finalises its review.
The Company has reviewed the structure and operation of its entity level control environment: the overarching structure of review and monitoring essential to the management of its business.
Each of the Companys subsidiaries and central functions has ensured that the relevant processes and controls are documented to appropriate standards, taking into account the guidance provided by the US Public Company Accounting Oversight Boards Auditing Standard No. 2 and subsequent SEC Staff Questions and Answers related to the standard. The approach taken has been to identify the key financial reporting processes so that, in aggregate, the Company has reasonable assurance regarding the reliability of its financial reporting and the preparation of financial statements.
The Company is making satisfactory progress on the work required to enable it to report on its compliance with section 404 at 31 March 2007.
The Company has also adopted a corporate Code of Ethics for senior executive, financial and accounting officers, separate from and additional to its Business Principles, described below. A copy of this code is available on the Groups website at www.vodafone.com.
from New York Stock Exchange corporate governance practices