Declaration
Ahold
Annual Report 2010
Group at a glance
Performance
Fi nancials
How we manage risk continued
Our key controls are documented in Ahold Control Memoranda (ACMs). Compliance with the
ACMs is mandatory for all of Ahold's fully-owned entities. The ACMs cover controls relating to
financial reporting and various other business processes. They include the requirement for
management to assess the operating effectiveness of all key controls.
Code of Conduct
Our Global Code of Professional Conduct and Ethics is based on Ahold's core values. It is
intended to help each employee understand and follow relevant compliance and integrity rules,
and know when and where to ask for advice. The code applies to Ahold, its operating companies
and all management-level employees, as well as to third parties hired by or acting for and on
behalf of Ahold. It co-exists with the local codes of conduct at each of our operating companies.
The code is available in the corporate governance section of Ahold's public website at
wwwahold.com.
Monitoring
We use a comprehensive business planning and performance review process to monitor our
performance. This process covers the adoption of strategy, budgeting, and the reporting of
current and projected results. We assess business performance according to both financial and
non-financial targets and have a Group-wide management certification process in place to meet
business needs and the requirements of the Dutch Corporate Governance Code. Each quarter,
executive management of each reporting entity send letters of representation to the Corporate
Executive Board confirming whether they comply with Ahold's Global Code of Professional
Conduct and Ethics, policies on fraud prevention and detection, accounting and internal control
standards, and disclosure requirements. Compliance with Ahold's corporate responsibility
standards is confirmed through bi-annual letters of representation. Our Internal Audit function
helps to ensure that we maintain and improve the integrity and effectiveness of our system of risk
management and internal control by undertaking regular risk-based, objective, and critical audits.
Internal Audit also monitors the effectiveness of corrective actions undertaken by management
and has specific procedures in place for following up on significant audit findings.
Governance Risk and Compliance Committee
The Governance, Risk and Compliance (GRC) Committee oversees governance, risk and
compliance activities within the Ahold Group and reviews relevant reports that are submitted to
the Corporate Executive Board, the Supervisory Board and the Audit Committee. The GRC
Committee meets quarterly. Ahold's Chief Corporate Governance Counsel (chair) and Chief
Financial Officer sit on the GRC Committee, as do other members of management responsible
for key governance, risk and compliance functions.
Annual declaration on risk management and control systems regarding financial
reporting risks
Ahold supports the Dutch Corporate Governance Code and makes the following declaration in
accordance with best practice provision II.1.5:
The Corporate Executive Board is responsible for establishing and maintaining adequate internal
risk management and control systems. Such systems are designed to manage rather than
eliminate the risk of failure to achieve important business objectives, and can only provide
reasonable and not absolute assurance against material misstatement or loss.
With respect to financial reporting, management has assessed whether the risk management and
control systems provide reasonable assurance that the 2010 financial statements do not contain
any material misstatements. This assessment was based on the criteria set out in COSO: Internal
Control - Integrated Framework. It included tests of the design and operating effectiveness of
entity level controls, transactional controls at significant locations, and relevant general computer
controls. Any control weaknesses not fully remediated at year-end were evaluated. Based on this
assessment, management determined that the Company's financial reporting systems are
adequately designed and operated effectively in 2010.
More about Code of Conduct online:
www.ahold.com
