Internal Financial Controls

Our Key Controls

Key Controls Consist of:

• The preparation of comprehensive monthly financial accounts, forecasts and reviews comparing performance to budget with a summary submitted to and discussed with the Directors at regular Board meetings;

• An Accounting Manual and Authority Manual incorporating clearly defined operating guidelines and procedures with authorization limits set at appropriate levels requiring proper, consistent and legally compliant financial management at all levels;

• Regular performance reviews with divisional management carried out by the Chief Executive Officer and the Chief Financial Officer at site;

• An on-going annual program to assess the design, implementation and operational effectiveness of the internal controls structure and procedures for financial reporting based on the criteria set out by the Committee of Sponsoring Organisations of the Treadway Commission in Internal Control – Integrated Frameworks (“COSO”), to satisfy management’s attestation under section 404 of the Sarbanes- Oxley Act;

• Under the supervision of the internal audit function, periodic internal audits carried out by Luxfer finance staff and internal audit co-sourcing, targeting pre-defined specific areas of financial reporting in any year on a rotational basis;

• Self-certification divisional management on adequacy and of compliance with financial controls.

As the company's shares are quoted on the New York Stock Exchange in the form of Ordinary Shares, the Chief Executive Officer and the Chief Financial Officer have carried out certain evaluations and assessments of the design and operation of our disclosure controls and procedures and the effectiveness of internal control over financial reporting as at our financial year-end. To learn more, please refer to our annual Form 10-K.

Treasury and Financial Risk - Luxfer operates a central treasury function that controls all borrowing facilities, investment of surplus funds and management of financial risks.