65 / Maven Renovar VCT PLC
of the effectiveness of the internal control environment
and the review of the risk management systems that
allow the Company to identify, measure, manage and
monitor all risks on a continuous basis. The Directors
have confirmed that there is an ongoing process for
identifying, evaluating and managing the principal and
emerging risks faced by the Company, which has been in
place up to the date of approval of this Annual Report.
This process is reviewed regularly by the Board and
accords with internal control guidance issued by the FRC.
The Board reviews the effectiveness, at least bi-annually,
of the system of internal control and, in particular, it has
reviewed the process for identifying and evaluating the
principal and emerging risks affecting the Company and
the policies and procedures by which these risks are
managed. The Directors have delegated the
management of the Company’s assets to the Manager
and this embraces implementation of the system of
internal control, including financial, operational and
compliance controls and risk management. Internal
control systems are monitored and supported by the
compliance function of the Manager, which undertakes
periodic examination of business processes, including
compliance with the terms of the Investment
Management and Administration Deed, and ensures that
recommendations to improve controls are implemented.
Risks are identified through the Company’s risk
management framework by each function within the
Manager’s activities. Risk is considered in the context of
the guidance issued by the FRC and includes financial,
regulatory, market, operational and reputational risk.
This helps the Manager’s risk model identify those
functions most appropriate for review.
Any errors or weaknesses identified are reported to the
Company and timetables are agreed for implementing
improvements to systems. The implementation of any
remedial action required is monitored and feedback
provided to the Board.
The key components designed to provide effective
internal control for the year under review and up to the
date of this report are:
• the Manager prepares forecasts and management
accounts that allow the Board to assess the
Company’s activities and review its investment
performance;
• the Board and Manager have agreed clearly defined
investment criteria, specified levels of authority and
exposure limits. Reports on these areas, including
performance statistics and investment valuations, are
submitted regularly to the Board;
• the Manager’s evaluation procedure and financial
analysis of the companies concerned include detailed
appraisal and due diligence;
• the compliance function of the Manager reviews the
Manager’s operations, systems and controls on a
regular basis;
• written agreements are in place which specifically
define the roles and responsibilities of the Manager
and other third party service providers;
• clearly documented contractual arrangements exist in
respect of any activities that have been delegated to
external professional organisations;
• the Board carries out a bi-annual assessment of
internal controls by considering reports from the
Manager, including oversight of Maven’s
whistleblowing policy, its internal control and
compliance functions; and taking account of events
since the relevant period end; and
• the compliance function of the Manager reports bi-
annually to the Board and has direct access to the
Directors at any time.
The internal control systems are intended to meet the
Company’s particular needs and the risks to which it is
exposed. Accordingly, these systems are designed to
manage, rather than eliminate, the risk of failure to
achieve business goals and, by their nature, can provide
reasonable, but not absolute, assurance against material
misstatement or loss.
Assessment of Risks
In terms of the assessment of the risks facing the
Company, it is recognised that the investment portfolio
forms a significant element of its assets and a key issue
that requires the particular attention of the Committee is
that unlisted holdings are recognised and measured in
line with the Company’s stated accounting policy.
Another risk is that the Company does not recognise
income in line with its stated policy on revenue
recognition and/or incorrectly allocates dividend income
between capital and revenue. The maintenance of the
VCT status is another risk that the Company has to
address and the approach to address each of these risks
is set out below.
Valuation, existence and ownership of the
investment portfolio - how the risk was
addressed
The Company uses the services of an independent
custodian (The Bank of New York Mellon SA/NV) to hold
the quoted investment assets of the Company. An
annual internal control report is received from the
Custodian, which provides details of the Custodian’s
control environment. The investment portfolio is
reconciled regularly by the Manager. The portfolio is
reviewed and verified by the Manager on a regular basis
and management accounts, including a full portfolio
listing, are prepared quarterly and considered at the
quarterly meetings of the Board.