Travelers 2015 Annual Report Download - page 257

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, 2015. Based upon that evaluation, the Company’s Chief Executive Officer and Chief
Financial Officer concluded that, as of December 31, 2015, 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, 2015 that has materially affected, or is reasonably likely to materially
affect, the Company’s internal control over financial reporting.
The Company regularly seeks to identify, develop and implement improvements to its technology
systems and business processes, some of which may affect its internal control over financial reporting.
These changes may include such activities as implementing new, more efficient systems, updating
existing systems or platforms, or automating manual processes. These systems changes are often phased
in over multiple periods in order to limit the implementation risk in any one period, and as each
change is implemented the Company monitors its effectiveness as part of its internal control over
financial reporting.
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