Corporate Governance report

UK Corporate Governance Code

The Board has prepared this report with reference to the UK Corporate Governance Code issued by the Financial Reporting Council in June 2010.

During the year, the Group reviewed, under the auspices of the Board's Corporate Compliance and Responsibility Committee, and revised its Corporate Governance Compliance Statement. The statement which sets out how the Group complies with each of the provisions of the UK Corporate Governance Code (the 'Code') was approved by the Board. That document also sets out the statement of the division of responsibilities between the Chairman and the Chief Executive Officer, the list of matters reserved to the Board, the membership of the Board and of the various Board Committees together with the terms of reference of the various standing Board Committees. This document is available in the Investor Relations section of the Group's website, www.morrisons.co.uk/corporate

The Board

a) Membership

On 30 January 2011, the Board comprised a Non-Executive Chairman, three Executive Directors and six Non-Executive Directors.

There is a clear division of responsibilities between the Non-Executive Chairman and the Chief Executive (CEO), which has been set out in writing and agreed by the Board.

Marc Bolland resigned from the Board on 1 February 2010 and, on the same day, Johanna Waterous joined the Board as a Non-Executive Director. Dalton Philips joined the Board on 29 March 2010. On 9 September 2010, Martyn Jones stepped down from the Board. On 9 March 2011, Paul Manduca stepped down from the Board. On 31 January 2011, the Company announced that, with effect from the Company's AGM on 9 June 2011, Mark Gunter will step down from the Board. On 9 March 2011, Brian Flanagan informed the Board that he will step down from the Board, again with effect from the Company's 2011 AGM. Throughout the period, the majority of the Board consisted of independent Non-Executive Directors. Details of appointments, roles and backgrounds of the Directors are set out here.

b) Performance evaluation and training

The performance of the Board, its committees and its Directors are assessed and appraised regularly. The Chairman is responsible for monitoring the performance of the Chief Executive, who in turn is responsible for monitoring the performance of the Executive Directors.

During the year, a review of the effectiveness of the Board's four principal standing Committees (Audit, Nomination, Remuneration and Corporate Compliance and Responsibility) was completed by an external agency, Independent Audit Limited. That review resulted in a formal report which was presented to the full Board in October 2010 and the principal findings of that review work were considered specifically by the chairs of each of those Committees. Whilst minor improvements to the workings of the individual Committees were recommended and have been, or are being, implemented, the review process disclosed no material matters of concern.

A full independent external review of the Board and the individual Directors will be carried out before the end of the 2011/12 financial year and any major findings will be reported upon in the Corporate governance report for the period ending in January 2012. As reported in the 2010 Annual report, this review was deferred until the current financial year because of the change of Chief Executive during 2009/10.

The Board is satisfied that the arrangements for review and appraisal of the performance of the Board, its Committees and individual Directors are appropriate. The Board is also confident that the initiatives which have been implemented already or which are in progress will enable the Group to satisfy the best practice recommendations of the Code in relation to Board evaluation.

During the course of the 2010/11 financial year, the Group has continued with its series of Board training sessions, presented by the Group's external advisers, on various key issues of importance to the Group. This training was designed to address matters of specific relevance to the Group and covered a range of topics including:

  • Directors' duties; and
  • Developments in the audit process and key audit issues of judgement.

The training programme was established in the 2009/10 financial year and will be refreshed and updated so that regular updates are provided to the Board on key governance, corporate practice and legal/accounting issues.

c) Senior Independent Director

Paul Manduca, the Senior Independent Director (SID) until 9 March 2011, has been available to shareholders throughout the period as an alternative to the Chairman, CEO and the Group Finance Director. The SID ensures that he is available to meet shareholders during the year and reports any relevant findings to the Board or Chairman. With effect from 10 March 2011, Nigel Robertson will assume the role of SID and will be similarly available to shareholders.

d) Non-Executive Directors

The Non-Executive Directors provide a varied range of skills and experience to the Group. The Board is satisfied that all Non-Executive Directors, including the Non-Executive Chairman, remain independent according to the definition contained in the Combined Code. No Non-Executive Director:

  • has previously been employed by the Group within the last five years;
  • has had a material business relationship with the Group within the last three years;
  • receives remuneration other than Director's fees;
  • has close family ties with any of the Group's advisers, Directors or senior employees;
  • holds cross-directorships or has significant links with other directors through involvement in other companies or bodies;
  • represents a significant shareholder; or
  • has served on the Board for more than nine years.

All Directors are provided with a comprehensive, formal and tailored induction to the business. The minimum time commitment expected of the Non-Executive Directors is one day per month attendance at meetings, together with attendance at the Annual General Meeting, Board away days and site visits, plus adequate preparation time. The Board is satisfied that each of the Non-Executive Directors commits sufficient time to the business of the Group and contributes to the governance and operations of the Group.

e) Board responsibilities

The Board is responsible for setting and approving the strategy and key policies of the Group, and for monitoring the progress towards achieving these objectives. It monitors financial performance, critical operational issues and risks. The Board also approves all circulars, listing particulars, resolutions and correspondence to shareholders including the Annual report, half yearly financial report and interim management statements.

The formal schedule of matters reserved for the Board remains unaltered and further details are available in the Corporate Governance Compliance Statement set out in the 'Investor Relations' section of the Group's website www.morrisons.co.uk/corporate

The Company Secretary organises the appropriate level of insurance cover for Directors to defend themselves against legal claims and civil actions. The level of cover is currently £60m in aggregate.

Management Board

The Management Board is made up of representatives of the senior management of the Group and is chaired by the Chief Executive. It has detailed terms of reference and has responsibility for the day-to-day operations of the Group. This includes development and implementation of strategy (subject to overall supervision by the Board), financial performance, reporting and control, risk management, operational improvement programmes, the entry by the Group into major contracts and commitments, the development of corporate policies and procedures and the ongoing review and supervision of the operational activities of the business of the Group. It reviews and makes recommendations to the Board in respect of budgets and long term planning and dividend levels as well as reviewing proposed announcements, whether financial or related to ad hoc events. It also keeps under supervision the Group's senior management talent, capabilities and succession plans.

Committees of the Board

The principal committees of the Board are the Audit, Remuneration, Nomination and Corporate Compliance and Responsibility (CCR) Committees.

The Company Secretary organises the appropriate level of insurance cover for Directors to defend themselves against legal claims and civil actions. The level of cover is currently £60m in aggregate.

Full terms of reference of the Committees are available on request and in the Corporate Governance Compliance Statement set out in the Investor Relations section of the Group's website www.morrisons.co.uk/corporate

a) Nomination Committee

During the year the activities of the Committee were focused on advice to the executive management on the establishment and composition of the Management Board and on senior management succession planning. The Committee has engaged an executive search agency, MWM Consulting, to assist in the process of identification of potential candidates to join the Board as and when appropriate.

b) Remuneration Committee

The objective of the Group's remuneration policy is to encourage a strong performance culture and an emphasis on long term shareholder value creation. The intention is to position remuneration arrangements competitively against the market, with a clear reward structure to enable the Group to attract, retain and motivate the best talent who are key to the Group's recent and future success.

The Group HR Director has advised the Group on all remuneration related matters, including pensions and Executive Directors' contracts. Where necessary this advice was supplemented by external advisers.

The committee also receives advice from its appointed advisers Hewitt New Bridge Street on remuneration matters, Pension Capital Strategies Limited (a member of the Jardine Lloyd Thompson Group) in respect of pensions, and Ashurst LLP in respect of Executive Directors' contracts.

The activities of the Remuneration Committee during the year are set out in more detail in the Directors' remuneration report

c) Audit Committee

The Board has delegated to the Audit Committee the responsibility for reviewing on its behalf and making recommendations to the Board as to:

  • the integrity of financial reports;
  • the effectiveness of the Group's internal control and risk management system; and
  • the independence of the external auditors.

The Audit Committee's responsibilities have not changed during the year.

The Audit Committee regularly considers the professional development needs of its members, and whether adequate technical information is being provided. Where necessary, it will seek independent external advice at the Group's expense, with such arrangements made through the Company Secretary.

The Audit Committee is chaired by Philip Cox who has the requisite recent and relevant financial experience. The Chairman, the CEO, the Group Finance Director, the Head of Risk and Internal Audit and other finance department representatives have attended meetings by invitation.

During the year, the membership of those Committees was: Committee membership
Name Nomination Remuneration Audit CCR
Sir Ian Gibson •*  
Dalton Philips    
Philip Cox •*  
Brian Flanagan  
Penny Hughes  
Martyn Jones  
Paul Manduca •*  
Nigel Robertson •*
Johanna Waterous

* Chair of the Committee

 

The Directors attended the following number of Board and Committee meetings: Committee membership
Number of meetings Board Nomination Remuneration Audit CCR
Sir Ian Gibson 11/11 6/6 13/13   4/4
Dalton Philips 9/9 5/5 12/13   3/3
Richard Pennycook 10/11        
Mark Gunter 10/11        
Philip Cox 10/11 6/6 12/13 6/6  
Brian Flanagan 10/11 5/6 12/13 6/6  
Penny Hughes 9/11 6/6 9/13 5/6  
Martyn Jones 8/8       3/3
Paul Manduca 11/11 5/6 13/13    
Nigel Robertson 10/11 6/6 13/13 2/2 4/4
Johanna Waterous 10/11 6/6 10/13 6/6 3/4

 

(i) Overview of actions taken by the Audit Committee in discharging its duties

The Committee has received and reviewed reports and presentations from senior management to fulfil its terms of reference. To meet its responsibilities in this respect, the Committee considered:

  • interim and preliminary announcements, together with any other formal announcements relating to financial performance;
  • the accounting principles, policies and procedures adopted in the Group's financial statements, including, where necessary, challenging the judgements made; and
  • the potential effects of tax and pensions accounting and other significant judgemental and complex accounting issues dealt with in the accounts.

The Audit Committee oversees the Group's relationship with the external auditors. Private meetings are held with the external auditors, without management present. The purpose of these meetings is to understand their views on the control and governance environment and management's effectiveness within it. To fulfil its responsibilities in respect of the independence and effectiveness of the external auditors, the Committee reviewed:

  • the terms, areas of responsibility, duties and scope of work of the external auditors as set out in the engagement letter;
  • the external auditors' work plan for the Group;
  • the detailed findings of the audit, including a discussion of any major issues that arose during the audit;
  • the letter from KPMG Audit Plc confirming its independence and objectivity; and
  • the audit fee and the extent of non-audit services provided by the external auditors.

In this period, the external auditors have continued to provide a significant level of non-audit work, primarily to provide the Board with independent assurance in respect of IT systems replacement. The Board believes that this activity is a reasonable extension of their statutory audit work and that there are safeguards in place to avoid a threat to their independence or objectivity. The Board has a policy on the engagement of the external auditors to supply non-audit services and the Committee has reviewed the scope of non-audit services provided by the external auditors to ensure that there was no impairment of objectivity. A copy of that non-audit services policy is available in the Corporate Governance Compliance Statement set out in the 'Investor Relations' section of the Group's website at www.morrisons.co.uk/corporate. This non-audit services policy is designed to assist the Company and each of its subsidiaries in ensuring that the engagement of the external auditors to provide non-audit services:

  • is only carried out in appropriate circumstances;
  • is transparent; and
  • does not impair the judgement or independence of the external auditors.

When assessing the non-audit services for approval the Audit Committee will take the following into consideration:

  • whether the skills and experience of the audit firm make it the most suitable supplier of the non-audit service;
  • whether there are safeguards in place to ensure that there is no threat to the objectivity or independence in the conduct of the audit resulting from the provision of such services by the external auditor;
  • the nature of the non-audit services, the related fee levels and the fee levels individually and in aggregate relative to the audit fee; and
  • the criteria which govern the compensation of the individuals performing the audit.

KPMG also follows its own ethical guidelines and continually reviews its audit team to ensure that its independence is not compromised.

The Audit Committee has determined that it will review not less than annually whether the incumbent auditors should remain in place or whether an auditor selection process should be initiated.

(ii) Internal control

The Board is responsible for setting a system of internal controls for the Group and reviewing its effectiveness. Executive management is responsible for implementing and maintaining the system of controls. This system is intended to manage rather than eliminate the risk of not meeting the Group's strategic objectives, whilst recognising that certain inherent risks may be outside the Group's control. The Board recognises that any system of internal control can only seek to provide reasonable, not absolute, assurance against material misstatement or loss.

The Board delegates to the Audit Committee the review of the effectiveness of the Group's internal controls and risk management systems. During the year, the Committee discharged this responsibility by:

  • receiving and considering regular reports from the internal audit function on the status of internal control and risk management systems across the Group. The Committee also reviewed the department's findings, annual plan and the resources available to it to perform its work;
  • reviewing the external auditor's management letters on internal financial control;
  • seeking reports from senior management on the effectiveness of the management of key risk areas; and
  • monitoring the adequacy and timeliness of management's response to identified audit issues.

The Audit Committee receives regular reports from the Head of Risk and Internal Audit on any whistle-blowing activity in respect of concerns expressed by colleagues about possible malpractice or wrongdoing. Whilst there were no significant concerns raised by colleagues, all actions required were discussed and agreed with the Committee.

The Board is satisfied that a continual process for identifying, evaluating and managing significant risks has been in place for the financial year and up to the date of this Annual report. To date, no material financial problems have been identified that would affect the results reported in these financial statements. The Board confirms that if significant weaknesses had been identified during this review the Board would have taken the necessary steps to remedy them.

d) Corporate Compliance and Responsibility Committee (CCR)

The CCR Committee, chaired by a Non-Executive Director, Nigel Robertson, reviews and oversees the development and implementation of policy in relation to health and safety, environmental, competitive and ethical compliance, corporate social responsibility (CSR), including the Group's engagement with community organisations and charitable bodies, and governance and other reputational management issues. With effect from 10 March 2011 Penny Hughes has been appointed as chair of the CCR Committee.

The Committee's remit does not cover operational matters but it performs an oversight, monitoring and advisory role in relation to these key areas in the Company's governance and development.

The Committee, which reports to the Board, was set up and met four times during the financial year and, as well as reviewing its terms of reference, it received presentations on the Group's CSR, health and safety and competition compliance policies and procedures.

Shareholder relations

The CEO and the Group Finance Director meet regularly with analysts and institutional shareholders. The Investor Relations Director also maintains a programme of work that reports to the Board the requirements and information needs of institutional and major investors. This is part of the regular contact that the Group maintains with its institutional shareholders.

All Directors, Executive and Non-Executive, attend the AGM unless unavoidably unable to do so.

The Chairs of the Audit, Nomination, Remuneration and CCR Committees are available to answer any questions.

Additionally, the Group's brokers sought independent feedback from investors following the annual and interim results in 2010. This feedback was reported to the Board.

Code compliance

The Board has been kept fully up to date by the Company Secretary and the Head of Risk and Internal Audit as to the developments in corporate governance following the Walker Review and the Financial Reporting Council's revision of the UK Corporate Governance Code.

The Board is confident that its corporate governance policies and procedures are appropriate and that the Company is fully compliant with the Code. Notably, although not yet required to do so, the Board has resolved that it will comply with the best practice recommendation set out in Code Principle B.7.1 such that all directors will be submitted for re-election at its AGM.

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