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Table of Contents
Item 9A. Controls and Procedures
Evaluation of Disclosure Controls and Procedures
As of the end of the period covered by this Annual Report on Form 10-K, we carried out an evaluation under
the supervision and with the participation of our Disclosure Committee and our management, including the
Chief Executive Officer and the Chief Financial Officer, of the effectiveness of the design and operation of
our disclosure controls and procedures pursuant to Exchange Act Rules 13a-15(e) and 15d-15(e). Disclosure
controls are procedures that are designed to ensure that information required to be disclosed in our reports
filed under the Securities Exchange Act of 1934, or the Exchange Act, such as this Annual Report on
Form 10-K, is recorded, processed, summarized and reported within the time periods specified by the
Securities and Exchange Commission. Disclosure controls are also designed to ensure 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. Our quarterly
evaluation of disclosure controls includes an evaluation of some components of our internal control over
financial reporting. We also perform a separate annual evaluation of internal control over financial reporting
for the purpose of providing the management report below.
The evaluation of our disclosure controls included a review of their objectives and design, our implementation
of the controls and the effect of the controls on the information generated for use in this Annual Report on
Form 10-K. In the course of the controls evaluation, we reviewed data errors or control problems identified
and sought to confirm that appropriate corrective actions, including process improvements, were being
undertaken. This type of evaluation is performed on a quarterly basis so that the conclusions of management,
including our Chief Executive Officer and Chief Financial Officer, concerning the effectiveness of the
disclosure controls can be reported in our periodic reports on Form 10-Q and Form 10-K. Many of the
components of our disclosure controls are also evaluated on an ongoing basis by both our internal audit and
finance organizations. The overall goals of these various evaluation activities are to monitor our disclosure
controls and to modify them as necessary. We intend to maintain the disclosure controls as dynamic systems
that we adjust as circumstances merit.
Based upon that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that our
disclosure controls and procedures were effective as of the end of the period covered by this report.
Management’s Report on Internal Control over Financial Reporting
Our management is responsible for establishing and maintaining adequate internal control over financial
reporting, as such term is defined in Exchange Act Rules 13a-15(f) and 15d-15(f). Under the supervision and
with the participation of our management, including our Chief Executive Officer and Chief Financial Officer,
we conducted an evaluation of the effectiveness of our internal control over financial reporting as of May 31,
2007 based on the guidelines established in Internal Control—Integrated Framework issued by the Committee
of Sponsoring Organizations of the Treadway Commission (COSO). Our internal control over financial
reporting includes policies and procedures that provide reasonable assurance regarding the reliability of
financial reporting and the preparation of financial statements for external reporting purposes in accordance
with U.S. generally accepted accounting principles.
Based on the results of our evaluation, our management concluded that our internal control over financial
reporting was effective as of May 31, 2007. We reviewed the results of management’s assessment with our
Finance and Audit Committee.
Management’s assessment of the effectiveness of our internal control over financial reporting as of May 31,
2007 has been audited by Ernst & Young LLP, an independent registered public accounting firm, as stated in
their report which is included in Part IV, Item 15 of this Annual Report on Form 10-K.
Changes in Internal Control over Financial Reporting
There were no changes in our internal control over financial reporting identified in connection with the
evaluation required by paragraph (d) of Exchange Act Rules 13a-15 or 15d-15 that occurred during our last
fiscal quarter that have materially affected, or are reasonably likely to materially affect, our internal control
over financial reporting.
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Source: ORACLE CORP, 10-K, June 29, 2007 Powered by Morningstar® Document Research