Dell 2007 Annual Report Download - page 100

Table of Contents
assets, (b) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in
accordance with GAAP, (c) provide reasonable assurance that receipts and expenditures are being made only in accordance with
appropriate authorization of management and the board of directors, and (d) provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use, or disposition of assets that could have a material effect on the financial statements.
In connection with the preparation of this Report, our management, under the supervision and with the participation of our Chief
Executive Officer and Chief Financial Officer, conducted an evaluation of the effectiveness of our internal control over financial
reporting as of February 1, 2008 based on the criteria established in Internal Control — Integrated Framework issued by the Committee
of Sponsoring Organizations of the Treadway Commission ("COSO"). As a result of that evaluation, management has concluded that our
internal control over financial reporting was effective as of February 1, 2008. The effectiveness of our internal control over financial
reporting as of February 1, 2008 has also been audited by PricewaterhouseCoopers LLP, our independent registered public accounting
firm, as stated in their report, which is included in "Part II — Item 8 — Financial Statements and Supplementary Data."
Changes in Internal Control Over Financial Reporting
During Fiscal 2008, our management was actively engaged in the implementation of remediation efforts to address the material
weaknesses that were identified as of February 2, 2007. Those remediation efforts were designed both to address the identified material
weaknesses and to enhance our overall financial control environment. The plan to remediate those material weaknesses was described in
detail in our Annual Report on Form 10-K for Fiscal 2007, and our efforts to implement that plan are summarized below:
• Our senior management renewed its commitment to achieving and maintaining a strong control environment, high ethical standards, and
financial reporting integrity. This commitment has been communicated to and reinforced with every Dell employee and to external
stakeholders. In this regard:
– We developed, adopted, and communicated an accounting code of conduct to serve as a set of guiding principles emphasizing our
commitment to accounting and financial reporting integrity, as well as transparency and robust and complete communications with,
and disclosures to, internal and external auditors.
– We reemphasized and invigorated our communications to all employees regarding the availability of our Ethics Hotline, as well as
other reporting avenues or forums, through which employees at all levels can submit information or express concerns regarding
accounting, financial reporting, or other irregularities they have become aware of or have observed.
– We effected various personnel actions in our accounting and financial reporting functions. These actions included terminations,
reassignments, reprimands, increased supervision, training, and imposition of financial penalties in the form of compensation
adjustments.
– We implemented personnel resource plans, as well as training and retention programs, designed to ensure that we have sufficient
personnel with knowledge, experience, and training in the application of GAAP commensurate with our financial reporting
requirements. We developed and implemented comprehensive training programs for finance personnel globally covering
fundamental accounting and financial reporting matters, including accounting policies, financial reporting requirements, income
statement classification, revenue recognition, vendor funding, accounting for reserves and accrued liabilities, and account
reconciliation and documentation requirements. As of March 31, 2008, we have delivered that training to a majority of the
accounting organization worldwide.
• We reorganized the Finance Department, segregating accounting and financial reporting responsibility from other finance functions,
with a renewed commitment to accounting and financial reporting integrity. We appointed a new Chief Accounting Officer in May 2007
and strengthened that position, making it directly responsible for all accounting and financial reporting functions worldwide. Under the
supervision and oversight of the Chief Accounting Officer:
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