The integrity of our financial records is critical to the successful operation of our business and to the reputation and trust of our employees and our shareholders. By demonstrating integrity in our financial records and reports, we generate trust with all of our stakeholders and enhance our reputation.
Internal Reporting and Controls
Arch complies with U.S. Generally Accepted Accounting Principles (GAAP) and Financial Accounting Standards Board Regulations. In addition, the Company maintains a system of internal controls to assure appropriate authorization, recording and accountability of assets. Employees share the responsibility for maintaining and complying with these controls and must never intentionally circumvent them.
Arch's finance and accounting officers and managers have a special fiduciary responsibility to ensure that finance and accounting practices support the full, fair, accurate, timely and understandable disclosure of the Company's financial results and condition. The use of alternative accounting treatment possible under U.S. GAAP must be properly justified and approved by Arch management.
It is unlawful for company officers, directors or any employee acting under their direction to improperly influence Arch's public accountants in the issuance of Company financial statements. The types of conduct that may be construed as improper influence include the following:
Your Role in Assuring Accurate Company Records
Most Arch employees are involved with documents and reports of some kind, including preparing time sheets, expense reports, operating reports or inventory reports, approving invoices or signing for the receipt of materials. While we may not all be familiar with formal accounting procedures, each of us must make sure that all of our business records are complete, accurate and reliable.
All Company transactions must be supported in reasonable detail, in the proper account and in the proper accounting period. Cash or other assets must not be maintained in any unrecorded or "off-the-books" fund for any purpose. You must never make a false entry in any Company record or mislead, hide or disguise any financial or non-financial transaction for any reason. Falsifying business records or intentionally misclassifying transactions is a serious offense that may result in criminal prosecution and disciplinary action, including termination of your employment.
Records Management
Employees at all levels are responsible for the integrity and accuracy of Company records. These records serve as a basis for managing our business and are important in meeting our obligations to suppliers, distributors, government regulators, investors, creditors and our customers.
Company records must be retained in accordance with the law and our records policy. Company records include business documents in any format, including paper documents, voice mail, computer-based information such as e-mail, PDAs such as Palm or Blackberry, daily planners, computer files on disk or tape and any other medium that contains information about our organization and its business activities.
Understanding what documents to keep - and for how long - is important. Records that are subject to retention must not be discarded prior to the dates specified in our records retention schedule. In addition, you must never destroy or alter any document or record if you believe that it may be subject to a tax review, pending investigation, legal proceeding or audit. It is a serious violation of Company policy and our Code of Conduct to alter or falsify information on any record or document. Failing to comply with Company records policies, even innocently, can result in serious business or legal repercussions. Records that have been intentionally altered, destroyed or falsified in order to conceal wrongdoing or impede, obstruct or influence a government investigation may result in penalties including fines, imprisonment of up to 20 years or both.
If you have questions about records management requirements, you should contact your supervisor or manager.
Complaints Regarding Accounting, Controls and Auditing Matters
Complaints related to accounting, internal control and auditing matters may be reported to Arch's General Counsel, the Arch Ethics Officer or the Arch Help-Line. Anonymous complaints may be made by letter (without return address or signature) or by calling the Arch Help-Line. The investigation of a complaint is significantly enhanced when callers choose to identify themselves. A few non-U.S. countries, such as France, prefer that callers identify themselves.All complaints received about accounting matters will be forwarded promptly to the Audit Committee of the Board of Directors for investigation and resolution.
Consistent with our policies, no one at Arch, including any director, officer or employee may retaliate against any employee or any other individual who in good faith makes a complaint about or helps in the investigation of an Arch accounting, control or auditing matter. In addition, Arch will not tolerate any effort on the part of any party to identify any person who makes a report anonymously.
Examples of accounting, control or auditing concerns include:
Investigations, Inspections and Inquiries
If you are asked to respond to requests by internal auditors, legal staff, independent accountants, and special counsel, your responses must be complete and truthful. You must include all relevant information, even if the request does not specifically ask that you do so.
« Previous Page ¦ Next Page »
