Ensuring Accurate Accounts, Records and Disclosures

We observe the most stringent standards in the keeping of our accounts and records. Accurate accounts and disclosures are essential to our companies and compliance with laws on accounting, taxation, filings, public disclosures and other important obligations.

Accurate accounts, records and disclosures

Our Company is subject to extensive and complex accounting and reporting requirements. Our companies must comply both with applicable accounting and financial reporting rules and regulations of the jurisdictions in which they operate, and with any international rules and regulations which may apply as a result of being part of the Liberty Global Group.

All of our books, records, accounts and financial statements must be maintained in reasonable detail, appropriately reflect our Company’s transactions and conform both to applicable legal requirements and to the Liberty Global plc system of internal controls. Our filings with the U.S. Securities and Exchange Commission, as well as other public disclosures by or on behalf of our Company, must be timely, understandable, fair, accurate and complete in all material respects.

Accounting and financial reporting practices must comply with applicable generally accepted accounting principles and other criteria, such as local statutory reporting and tax requirements. Furthermore, financial reporting for Liberty Global Group purposes must be compliant with the Liberty Global Accounting Policy Manual. You may obtain a copy of the Accounting Policy Manual from your Chief Financial Officer or Compliance Officer.

Our internal controls must enable us to demonstrate that entries in our financial records are accurate and complete and made in accordance with applicable regulations.

No officer, director, employee or other person acting on behalf of our Company may take any action intended to influence our Company's auditors in an improper manner or to influence the conduct of an audit of our Company's financial statements.

Employees involved in our Company’s disclosure process must be familiar, and must comply, with Liberty Global plc’s disclosure controls and procedures, including internal controls over financial reporting, so that the reports and other documents filed by Liberty Global plc with the U.S. Securities and Exchange Commission or SEC comply in all material respects with applicable laws and SEC rules. Disclosures must be made in a timely fashion and, when made, must be accurate and complete in all material respects.

Examples of financial practices that are prohibited and must be reported:

  • Approving or making any payment if you know that any part of that payment is to be used for any purpose other than that described by the supporting documents, or if such approval exceeds your authority.
  • Fraud in preparing, evaluating, reviewing or auditing any financial statement, such as concealing or falsifying data given to internal or external auditors or making false representations in the quarterly letter/certification process.
  • Fraud in recording and maintaining Company financial records, such as intentionally recording revenue or expenses in the wrong period, capitalizing items that should be expensed or recording personal expenses as business expenses.
  • Noncompliance with Liberty Global’s Accounting Policy Manual or internal controls processes.
  • Misrepresenting to a senior officer or to the Company's internal or external auditors or accountants a matter contained in the Company's financial records, financial reports or audit reports.
  • Intentionally failing to comply with local statutory or fiscal requirements.

Find out more: Contact your Compliance Officer or Chief Financial Officer.

Proper authorization and approvals

Ensuring that proper authorization is obtained for any transaction is an essential business practice. Authority to approve a transaction does not mean you have authority to also sign the related contract or document which binds the Company. The list of approved signatories for a particular company is generally small. It is your responsibility to ensure that appropriate approvals, signatories and execution procedures are followed in connection with any transaction in which you are involved and that you abide by your personal authorization limits. If you have any questions about your company's authorization requirements or limits, please contact the controller's group for your business unit or division or your Compliance Officer.