Internal control statement (SEC Requirement)

The United States Securities and Exchange Commission (SEC) guidelines are to disclose in the annual report as follows:

1. A statement of management’s responsibility for establishing and maintaining adequate internal control over financial reporting for the company. This will always include the nature and extent of involvement by the chairman and chief executive, but may also specify the other members of the board involved in the internal controls over financial reporting. The purpose is for shareholders to be clear about who is accountable for the controls.

2. A statement identifying the framework used by management to evaluate the effectiveness of this internal control. This will usually involve a description of the key metrics, measurement methods (e.g. rates of compliance, fair value measures, etc) and tolerances allowed within these. Within a rules-based environment, these are likely to be underpinned by law.

3. Management’s assessment of the effectiveness of this internal control as at the end of the company’s most recent fiscal year. This may involve reporting on rates of compliance, failures, costs, resources committed and outputs (if measurable) achieved.

4. A statement that its auditor has issued an attestation report on management’s assessment. Any qualification to the attestation should be reported in this statement.