Kraft 2010 Annual Report Download - page 105
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Item 9. Changes in and Disagreements with Accountants on Accounting and Financial Disclosure.
None.
Item 9A. Controls and Procedures.
Evaluation of Disclosure Controls and Procedures
Management, together with our CEO and CFO, evaluated the effectiveness of our disclosure controls and procedures (as defined in Securities Exchange Act
of 1934 Rule 13a-15(e)) as of the end of the period covered by this report. We acquired Cadbury Limited (formerly, Cadbury plc) ("Cadbury") in the first
quarter of 2010, and it represented approximately 32% of our total assets as of December 31, 2010. As the acquisition occurred in the first quarter of 2010, the
scope of our assessment of the effectiveness of internal control over financial reporting does not include Cadbury. This exclusion is in accordance with the
SEC's general guidance that an assessment of a recently acquired business may be omitted from our scope in the year of acquisition. Based upon that
evaluation, the CEO and CFO concluded that our disclosure controls and procedures were effective.
Changes in Internal Control Over Financial Reporting
Management, together with our CEO and CFO, evaluated the changes in our internal control over financial reporting during the quarter ended December 31,
2010, and noted the following significant changes.
• In 2008, we began implementing "Catalyst," a business initiative to simplify and harmonize our systems processes. This multi-year program
includes the delivery of SAP enterprise software applications and business solutions. During the quarter ended December 31, 2010, we
transitioned some of our processes and procedures into the SAP control environment within Kraft Foods North America and Kraft Foods
Developing Markets. As we migrate to the SAP environment, our management ensures that our key controls are mapped to applicable SAP
controls, tests transition controls prior to the migration date of those controls, and as appropriate, maintains and evaluates controls over the flow
of information to and from SAP. We expect the transition period to be completed in 2011.
We determined that there were no other changes in our internal control over financial reporting during the quarter ended December 31, 2010, that have
materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
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