Monitoring, Verification and Mitigation
The responsibility for monitoring, verification and mitigation of issues of governance is shared by the appropriate corporate committees and individuals as follows.
Enterprise Risk Management
Kodak conducts an annual enterprise level risk assessment led by the General Counsel and the Chief Compliance Officer. Risks are assessed and monitored across business, functions and regions. These assessments also serve to evaluate compliance risks such as anti-corruption (including anti-bribery), labor and human rights. Results are presented to the Risk Management and Compliance Committee, which is responsible for ensuring the most significant risks to the Company are monitored and managed appropriately. The Audit and Finance Committee of the Board of Directors receives reports on the Company's enterprise risk management activities. The Company provides a disclosure of risk factors in its Form 10K Annual Report and periodically in Form 10Q Quarterly Reports and other SEC filings.
Kodak maintains an internal control system to ensure reasonable assurance that the Company conducts operations in a manner that is efficient and effective, safeguards Kodak assets, assures reliability of information for external reporting and assures compliance with company policies and procedures, laws and regulations and contractual obligations. The Corporate Auditing Department is responsible for conducting independent evaluations of internal controls and for making recommendations for improvement, which are reported periodically to senior management and annually to the Board of Directors.
Health, Safety and Environment Performance
Kodak has defined HSE best practices within the HSE Performance Standards, a set of performance criteria applicable to all Kodak activities worldwide. Operations, including subsidiaries, are routinely audited to verify compliance with the Standards, policies, procedures, and the laws and regulations of applicable governing entities. Kodak also has a Performance Standard for its suppliers and utilizes supplier self-assessments, on-site audits and material declarations to verify a supplier's conformance with the Standard and applicable product specifications. The Director of HSE and Sustainability reports results regularly to the affected businesses and annually to the Board of Directors.