Washington Post 2007 Annual Report Download - page 52

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Consolidated Financial Statements titled “Summary of Quarterly Operating Results and Comprehensive Income
(Unaudited),” which are included in this Annual Report on Form 10-K and listed in the index to financial information
on page 39 hereof.
Item 9. Changes in and Disagreements With Accountants on Accounting and Financial Disclosure.
Not applicable.
Item 9A. Controls and Procedures.
Disclosure Controls and Procedures
An evaluation was performed by the Company’s management, with the participation of the Company’s Chief Executive
Officer (the Company’s principal executive officer) and the Companys Vice President Finance (the Company’s
principal financial officer), of the effectiveness of the Company’s disclosure controls and procedures (as defined in
Exchange Act Rules 13a-15(e) and 15d-15(e)), as of December 30, 2007. Based on that evaluation, the Company’s
Chief Executive Officer and Vice President – Finance have concluded that the Company’s disclosure controls and
procedures, as designed and implemented, are effective in ensuring that information required to be disclosed by the
Company in the reports that it files or submits 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 is
accumulated and communicated to management, including the Chief Executive Officer and Vice President – Finance,
in a manner that allows timely decisions regarding required disclosure.
Management’s Report on Internal Control Over Financial Reporting
The Company’s management is responsible for establishing and maintaining adequate internal control over financial
reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)). The Company’s internal control over financial
reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the
preparation of financial statements for external purposes in accordance with accounting principles generally accepted
in the United States of America.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.
Also, projections of any evaluation of effectiveness 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 the policies or procedures may
deteriorate.
Our management assessed the effectiveness of our internal control over financial reporting as of December 30, 2007.
In making this assessment, our management used the criteria set forth by the Committee of Sponsoring Organizations of
the Treadway Commission (“COSO”) in Internal Control – Integrated Framework. Our management has concluded
that, as of December 30, 2007, our internal control over financial reporting is effective based on these criteria. The
effectiveness of our internal control over financial reporting as of December 30, 2007 has been audited by
PricewaterhouseCoopers LLP, an independent registered public accounting firm, as stated in their report included
herein.
Changes in Internal Control Over Financial Reporting
Effective October 1, 2007, the Company implemented a new system for advertising and billing for the majority of the
newspaper publishing segment that has materially affected the segment’s internal control over financial reporting. This
system has upgraded information system capabilities, improved business processes and expanded customer service
opportunities. The Company has taken the appropriate steps to ensure the internal controls around advertising and
billing for the newspaper publishing segment are designed and operating effectively in all material respects at the
reporting date.
No other changes in the Company’s internal control over financial reporting during the quarter ended December 30,
2007 have materially affected, or are reasonably likely to materially affect, the Company’s internal control over
financial reporting.
Item 9B. Other Information.
Not applicable.
36 THE WASHINGTON POST COMPANY