Ingram Micro 2013 Annual Report Download - page 70

Table of Contents
ITEM 9. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND FINANCIAL DISCLOSURE
There have been no changes in our independent accountants or disagreements with such accountants on accounting principles or practices or financial
statement disclosures.
ITEM 9A. CONTROLS AND PROCEDURES
 We maintain “disclosure controls and procedures,” as such term is defined in Rule 13a-15(e)
under the Securities Exchange Act of 1934 (the “Exchange Act”), that are designed to ensure that information required to be disclosed by us in reports that we
file or submit under the Exchange Act is recorded, processed, summarized, and reported within the time periods specified in Securities and Exchange
Commission rules and forms, and that such information is accumulated and communicated to our management, including our Chief Executive Officer and
Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosure. In designing and evaluating our disclosure controls and
procedures, management recognized that disclosure controls and procedures, no matter how well conceived and operated, can provide only reasonable, not
absolute, assurance that the objectives of the disclosure controls and procedures are met. Additionally, in designing disclosure controls and procedures, our
management necessarily was required to apply judgment in evaluating the cost-benefit relationship of those disclosure controls and procedures. The design of
any disclosure controls and procedures also is based in part upon certain assumptions about the likelihood of future events, and there can be no assurance
that any design will succeed in achieving its stated goals under all potential future conditions.
Based on their evaluation as of the end of the period covered by this Annual Report on Form 10-K, our Chief Executive Officer and Chief Financial
Officer have concluded that our disclosure controls and procedures were effective in providing reasonable assurance that the objectives of the disclosure
controls and procedures are met.
 Our management is responsible for establishing and maintaining adequate
internal control over financial reporting as defined in Rule 13a-15(f) of the Securities Exchange Act of 1934. Because of its inherent limitations, internal control
over financial reporting may not prevent or detect all misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk
that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.
We assessed the effectiveness of the Company’s internal control over financial reporting as of December 28, 2013. In making this assessment, we used
the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) in 
(1992). Based on our assessment using those criteria, we concluded that our internal control over financial reporting was effective as of December 28, 2013.
The effectiveness of our internal control over financial reporting as of December 28, 2013 has been audited by PricewaterhouseCoopers LLP, an
independent registered public accounting firm, as stated in their report which appears in this Form 10-K.
 There was no change in our internal control over financial reporting that occurred during the
quarterly period ended December 28, 2013 that has materially affected, or is reasonably likely to materially affect, our internal control over financial reporting.
We are in the process of upgrading our computer systems used for operations in certain of our subsidiaries. Implementation of these systems has
necessitated changes in operating policies and procedures and the related internal controls and their method of application. However, there have been no
changes in our internal control over financial reporting that occurred during the last fiscal year covered by this report that materially affected, or are reasonably
likely to materially affect, our internal control over financial reporting.
ITEM 9B. OTHER INFORMATION
None.
PART III
Information regarding executive officers required by Item 401 of Regulation S-K is furnished in a separate disclosure in Part I of this report, under the
caption “Executive Officers of the Company,” because we will not furnish such information in our definitive Proxy Statement prepared in accordance with
Schedule 14A.
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