Group le v els to support benchmarkin g within and bet w een divisions. Each reportin g unit is responsible for actin g on an y de viations, includin g writ ten action plans to address the de viations and a dead- line for when the actions mus t be in place . The Group closely monitor s the progress as of the fr s t and second quarterly business re views. An y priori - tiz ed areas for impro v ement are also addressed in the business plans. All reports are subsequently a v ailable to Divisional M ana g ement , Group M an- a g ement and the Audit Commit tee . Risk and control dia gnos tic s The Group per forms risk and control dia gnos tic s in functional areas which, b y nature , ha v e a hig h de gree of inherent risk. These dia gnos tic s are per formed in addition to the recurrin g areas in the self -assessment ques - tionnaire . In 2012, the focus on new countries in the Group continued, since the y ha v e been assessed as a risk area in terms of inte gr ation from a fnancial reportin g and control s t andpoint . The dia gnos tic ent ails a kit co v erin g IFRS reportin g compliance , as w ell as k e y controls within fnancial reportin g processes, contr act mana g ement and IT securit y . These re views are usually conducted within the fr s t y ear from the acquisition date and a follo w -up is per formed durin g the second y ear , pro vided that signifcant areas for impro v ement ha v e been identifed. Another area that w as subject to specifc dia g - nos tic s in 2012 w as the contr act mana g ement k e y risk area (refer to the t able on pa g e 42) and compliance with Group policies in this area. These re views are conducted on a rot ational basis for all countries. In 2012, w e also re view ed g o v ernance of pen - sion funds in selected countries where defned beneft plans e xis ts. Financial reportin g R e gular analyses of the fnan - cial results at the v arious le v els of the or ganization usin g the Financial M odel ensure that fnancial information maint ains hig h qualit y . Controller s at all le v els hold a k e y role in terms of inte grit y , pro- fessionalism and the abilit y to w ork in teams in or der to create the en vironment that is needed to achie v e tr ansparent , rele v ant and timely fnancial information. Local controller s are responsible for ensurin g compliance with the appro v ed set of poli- cies and fr amew orks, and for ensurin g that internal controls pert ainin g to fnancial reportin g processes are implemented. The Controller is also responsible for reportin g fnancial information that is correct , complete and timely . The Controller receiv es continuous feedback from the Group re gar din g reportin g qualit y , which is an efectiv e tool for enhanced reportin g. In addition, each division has a divisional controller with corre- spondin g responsibilities at the divisional le v el. Let ter of represent ation The Group has a repre- sent ation process in which oper atin g unit Presidents and Controller s sign a let ter of represent ation in connection with the y ear -end report , s t atin g their opinion on whether or not the internal control o v er fnancial reportin g and the reportin g pack a g es g iv e a true and fair view of the fnancial position. Information and communication Our channels for information and communication are cons t antly de v eloped to ensure that all s t af are g iv en clear objectiv es and are made a w are of the par ameter s that cons titute accept able business pr actices, as w ell as the e xpect ations of the Boar d in mana g in g risks. This pro vides a clear defnition of the Group ’ s purpose and g oals, account abilities and the scope of permit ted activities of emplo y ees. S ys tems and procedures ha v e been imple- mented that support complete , accur ate and timely fnancial reportin g and pro vide mana g ement with the necessar y reports on business per formance relativ e to the es t ablished objectiv es. The Group reportin g department re gularly issues guidance on reportin g mat ter s. R eportin g units re gularly prepare fnancial and mana g ement reports that are discussed at re view meetin g s at diferent le v els. These include an analysis of fnancial per formance and risks. 45 Securit as Annual R eport 2012 G o v ernance and mana g ement Boar d of Director s ’ report on corpor ate g o v ernance and internal control