Travelers 2013 Annual Report Download - page 270

Item 9. CHANGES IN AND DISAGREEMENTS WITH ACCOUNTANTS ON ACCOUNTING AND
FINANCIAL DISCLOSURE
Not Applicable.
Item 9A. CONTROLS AND PROCEDURES
The Company maintains disclosure controls and procedures (as that term is defined in
Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (Exchange
Act)) that are designed to ensure that information required to be disclosed in the Company’s reports
under the Exchange Act is recorded, processed, summarized and reported within the time periods
specified in the Securities and Exchange Commission’s rules and forms, and that such information is
accumulated and communicated to the Company’s management, including its Chief Executive Officer
and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosures.
Any controls and procedures, no matter how well designed and operated, can provide only reasonable
assurance of achieving the desired control objectives. The Company’s management, with the
participation of the Company’s Chief Executive Officer and Chief Financial Officer, has evaluated the
effectiveness of the design and operation of the Company’s disclosure controls and procedures as of
December 31, 2013. Consistent with guidance issued by the Securities and Exchange Commission that
an assessment of a recently acquired business may be omitted from management’s evaluation of
disclosure controls and procedures in the year of acquisition, management excluded an assessment of
the effectiveness of the Company’s disclosure controls and procedures related to Dominion. The
Company acquired all of the issued and outstanding shares of Dominion on November 1, 2013.
Dominion represented less than 4% of the Company’s consolidated total assets and less than 1% of
each of the Company’s consolidated total revenues and net income as of and for the year ended
December 31, 2013. Based upon that evaluation and subject to the foregoing, the Company’s Chief
Executive Officer and Chief Financial Officer concluded that, as of December 31, 2013, the design and
operation of the Company’s disclosure controls and procedures were effective to accomplish their
objectives at the reasonable assurance level.
In addition, there was no change in the Company’s internal control over financial reporting (as
that term is defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) that occurred during the
quarter ended December 31, 2013 that has materially affected, or is reasonably likely to materially
affect, the Company’s internal control over financial reporting. As mentioned above, the Company
acquired Dominion on November 1, 2013. The Company is in the process of reviewing the internal
control structure of Dominion and, if necessary, will make appropriate changes as it integrates
Dominion into the Company’s overall internal control over financial reporting process.
260