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All internal control weaknesses noted during the year were discussed with Management and Audit
Committee with proposed corrective actions. Material internal control deficiencies noted and discussed
during the year were in relation to delays in finalizing project contracts, problems in setting up of
overseas branches, high inventory, adequacy of insurance policy, reducing margins and/or losses from
projects and its impact on the profitability of the organization, and security and backup of various IT
applications.
6.3. Risk Management
Living in a world of uncertainties, increasing stakeholder mandates, and focus on project performance
with no waste or error, has increased the need to better understand and implement risk management.
Our aim to be better and to grow, triggers a ‘risk and opportunity’ based thinking at every level within
the organization.
This focus starts with management’s forward-thinking approach, and cascades to support departments
identifying, monitoring and mitigating risks in their own sphere of work on a continuous basis. At
projects, assessment of risks and opportunities starts at the initial phase, and is continuously monitored
and managed during execution.
6.4. Ethics and Compliance
Ethics and Compliance Function is part of Internal Control Department. The role of the Ethics and
Compliance Officer is to investigate and address any suspected wrongdoings as identified from the
whistle blowing system, and to verify compliance by the Company and its officers and employees with
the applicable legal and regulatory requirements (including the resolutions issued by SCA and ADX),
the Company’s internal policies and procedures, and commitments made to third parties (including the
Company’s lenders and counterparties).
The Company, in 2014, has developed and implemented policies and procedures on Fraud Control,
Whistle Blowing and Investigation. These policies have been formulated to provide employees an
opportunity to report in good faith in case they observe any unethical or improper practices in the
Company. Responsibility for overseeing and implementing the policy has been delegated to the Ethics
and Compliance Manager. The Company’s management also has specific responsibility for facilitating
operation of the policy. Communication sessions are held to spread awareness on fraud control and
whistle blowing system to the employees of the Company. Incidents reported during the year through
the whistle blowing system were adequately investigated and appropriately resolved. HR function of the
organization has also included such awareness in the new employee induction program.
6.5. Quality, Health, Safety and Environment
NMDC management strives for excellence in all we do and recognizes the impact that our activities
may have on people and the environment. Furthermore, the value added to our clients, Product and
performance Quality.
The Safety, health and protection of the environment are the prime concerns of our operation. Therefore,
one of the main focuses is to give care of our manpower resources;
More attention is directed to the continuous education and training of staff, and implementation of
134 2020 Integrated Annual Report