Starwood 2004 Annual Report Download - page 45

Item 9. Changes In and Disagreements with Accountants on Accounting and Financial Disclosure
Not applicable.
Item 9A. Controls and Procedures
Evaluation of Disclosure Controls and Procedures.
Our management conducted an evaluation, under the supervision and with the participation of our Chief
Executive OÇcer and Chief Financial OÇcer, of the eÅectiveness of the design and operation of our disclosure
controls and procedures as of December 31, 2004. Based on this evaluation, the Chief Executive OÇcer and
Chief Financial OÇcer concluded that our disclosure controls and procedures are eÅective in alerting them in
a timely manner to material information required to be included in our Securities and Exchange Commission
reports. There has been no change in our internal control over Ñnancial reporting that occurred during the
period covered by this report that has materially aÅected, or is reasonably likely to materially aÅect, our
internal control over Ñnancial reporting.
Management's Report on Internal Control over Financial Reporting.
Management of Starwood Hotels & Resorts Worldwide Inc. and its subsidiaries and Starwood Hotels &
Resorts and its subsidiaries (""the Company'') is responsible for establishing and maintaining adequate
internal control over Ñnancial reporting, as such term is deÑned in Exchange Act Rule 13a-15(f) or
15(d)-15(f). Those rules deÑne internal control over Ñnancial reporting as a process designed to provide
reasonable assurance regarding the reliability of Ñnancial reporting and the preparation of Ñnancial statements
for external purposes in accordance with generally accepted accounting principles (""GAAP'') and includes
those policies and procedures that:
¬Pertain to the maintenance of records that in reasonable detail accurately and fairly reÖect the
transactions and dispositions of the assets of the Company;
¬Provide reasonable assurance that the transactions are recorded as necessary to permit the preparation
of Ñnancial statements in accordance with GAAP, and the receipts and expenditures of the Company
are being made only in accordance with authorizations of management and directors of the
Company; and
¬Provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use
or disposition of the Company's assets that could have a material eÅect on the Ñnancial statements.
Because of its inherent limitations, internal control over Ñnancial reporting may not prevent or detect
misstatements. Projections of any evaluation of eÅectiveness 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
policies or procedures may deteriorate.
The Company's management assessed the eÅectiveness of the Company's internal controls over Ñnancial
reporting as of December 31, 2004. In making this assessment, the Company's management used the criteria
established in Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations
of the Treadway Commission (COSO). Based on our assessment and those criteria, management believes
that, as of December 31, 2004, the Company's internal control over Ñnancial reporting is eÅective.
Management has engaged Ernst & Young LLP, the independent registered public accounting Ñrm that
audited the Ñnancial statements included in this Annual Report on Form 10-K, to attest to and report on
management's evaluation of the Company's internal control over Ñnancial reporting. Its report is included
herein.
37