An e-learning module is currently available in English, Spanish and German and is mandatory for all employees at the time of the local launch. In addition, it is mandatory for all newcomers since the local launch.
In some subsidiaries, employees are also required to read and sign a copy of the Code of Professional Behaviour document which has been translated into the local language where this is not English, Spanish, German or French.
A Compliance Committee ensures compliance with the Group's Code of Professional Behaviour and to address any concerns that our employees may have and simultaneously assist in the implementation of the Code throughout the Group.
The Compliance matters at our company are a key objective. We have been focusing on activities directed at avoiding, preventing and investigating illegal acts and behaviours such as fraud, bribery or corruption.
For the main sites, we have the ICFR testing (Internal controls over financial reporting) through which we audit the risk of fraudulent financial reporting among other things. During 2011 key controls including fraud related controls have been tested for the three main sites. Also, Group Internal Audit includes this type of verifications in their scope when performing audits in the rest of the company as well as in the other relevant areas, such as procurement.
During 2011, 14 entities out of a total of 85 - which represents 17% - have been audited with this scope. This corresponds to a total of 85% of the assets, volume of purchasing, employees and transactions.
Finally, as Amadeus Group began trading on the stock market 29 April 2010, it became necessary to distribute and apply an Internal Code of Conduct (Internal rules of conduct relating to the securities market) within the company.
The internal code regulates our employees' responsibilities and proce¬dures regarding the following areas, as they have access to information pertaining to the company's share trading:
The Internal rules of conduct relating to the securities market are available on the CNMV and the Company's web page (www.investors.amadeus.com) and are known and accepted by our key executives who may access sensitive information within their area of responsibility.