Financial Compliance

Financial Policy

 

1. Introduction

We think of ourselves as local citizens and financial compliance with rules and regulations is part of who we are. We pay our taxes locally, where we engage in business. We pay all local licenses and fees required to engage in business locally. We do not transfer funds through licenses (or other means and constructs) in order to evade local taxes or fees. We do not knowingly engage in business with companies that obviously offend either of these policies, including our financial governance. We do our own, thorough accounting. We employ third party chartered accountants to check our results. Plus these engage supervising certified auditors, to double check our accounting and testify compliance of our year end statements with local requirements and our own highest standards.

 

2. Scope of application

The Financial Compliance Policy applies to all companies, that we hold a majority, controlling ownership interest in. This controlling interest gives us the power to enforce our standards of financial compliance.

 

3. Commitment to Financial Compliance

For all its ocmpanies, RICHARD BEHR & CO. requires compliance with all legal provisions in the area of financial reporting and taxation. Our guidelines are:

  • We follow all local financial legislation and regulation. We work with professional partners who support and audit our performance.
  • Financial Compliance is a quickly evolving field, with always new demanding regulations, restrictions, and compliance requirements.
  • Being able to record and manage the interactions of our organization in this industry ensures adherence to regulatory compliance.
  • This also mitigates risk by providing records for verification and liability.

We are committed to consistent and transparent accounting and reporting standards for all of our company interests.

RICHARD BEHR & CO. pursues the goal to maintain these standards in a world where the financial requirements keep evolving. Furthermore, our suppliers are obliged to comply with minimum financial compliance standards. RICHARD BEHR & CO. has its own accounting divisions, we work with external chartered accountants to prepare our annual reports, and their findings are audited through third parties.

 

4. Requirements and implementation

We actively promote compliance with Quality standards and for this purpose, we have already taken precise measures, amongst others, in the following areas:

Client financial compliance standards
Our clients are among the strongest drivers and champions of industrial level convergence of our industry toward financial compliance standards throughout the industry. We work with our clients to help them formulate their standards, goals, and monitor progress toward achieving the goals. We follow our highest client standards.

Requirements for our companies
RICHARD BEHR & CO. with all its companies around the world works according to these policies and local standards and/or is certified accordingly. This enables us to avoid potential risks of non-compliance with local or international accounting standards. Our internal accounting is supported with relevant, professional third party software and accounting systems, and professional accountants. Our business processes ensure the proper administration of these systems and processes.

Third party audits
RICHARD BEHR & CO. uses the following third party audited standards to monitor compliance with these guidelines:
RICHARD BEHR & CO. cooperates with independent chartered accountants to prepare and file year end reports and tax filings
RICHARD BEHR & CO. Peer reviews of our chartered accountant findings and reports
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5. Active Implementation

At RICHARD BEHR & CO., we implement our financial compliance requirements in close cooperation with our partners. The implementation of our internal requirements will be conducted by the accounting departments with the support of the responsible drivers of Corporate Governance. Specific requirements, goals and measures will also be implemented in close cooperation. We monitor the implementation among companies in which we hold a majority, controlling interest and we conduct risk-oriented evaluations. We reserve us the right to have the requirements of our financial compliance policy verified by internal and/or external audits, if necessary. Moreover, we ensure that all personnel responsible for the handling of financial data, or of processes with financial impact on business results and stock, are effectively trained to carry out routine practices in a way that ensures a true and fair financial picture of the companies at all times, and, where necessary, is qualified to promote good standards of financial compliance within their areas of responsibility. The present Financial Compliance Policy is part of our terms and conditions. Where instances of non-compliance with our policies are detected, all people involved are expected to provide corrective action plans that clearly demonstrate how relevant violations will be resolved within a specific timeframe. The Managing Directors are informed on the status of implementation on a regular basis.

We aspire to comply with financial regulations at all times, in an evolving financial environment. In this context, we always consider our banks' wishes and the market environment.

Since we aim to offer financial compliance, an exchange with external partners is indispensable. Therefore, we are in close contact with chartered accountants, and auditors that perform their peer review.

Specific measures
RICHARD BEHR & CO. is actively implementing financial compliance practices in all companies that are majority owned. These are specifically:

  • Richard Behr & Co. UK / The Surrey Down Company, audited through Larkin Gowen
  • Hanseatic Bedding Products audited through Rehmann Robson
  • Hanseatic Hanseatic Realty audited through Rehmann Robson
  • Richard Behr & Co Germany audited through RFHC
  • Hanse Textilvertrieb audited through RFHC
  • Habertag-Behr audited through RFHC
  • Dr. Behr Beteiligung audited through RFHC

We commit to keeping these measures and audits in place, comply with local accounting, filing and tax regulations and standards. We commit to NOT shift earnings away through license fees or other constructs, but be a good local corporate citizen with each entity.

Regular assessments
Each year, the current Financial Compliance Policy is assessed and, if required, adjusted. In the long-term, this is the only way to guarantee consistent and locally compliant accounting, reporting, filing and taxation standards. In addition, based on this policy, we formulate goals and evaluate the extent to which these goals have been achieved on an annual basis.

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