International Paper 2015 Annual Report Download - page 102

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ITEM 9. CHANGES IN AND DISAGREEMENTS
WITH ACCOUNTANTS ON ACCOUNTING AND
FINANCIAL DISCLOSURE
None.
ITEM 9A. CONTROLS AND PROCEDURES
EVALUATION OF DISCLOSURE CONTROLS AND
PROCEDURES
We maintain disclosure controls and procedures that
are designed to ensure that information required to be
disclosed by us in the reports we file or submit under
the Securities and Exchange Act of 1934, as amended
(the “Exchange Act”), is recorded, processed,
summarized and reported within the time periods
specified in the SEC’s rules and forms, and that such
information is accumulated and communicated to
management, including our principal executive officer
and principal financial officer, as appropriate, to allow
timely decisions regarding required disclosure. As of
December 31, 2015, an evaluation was carried out
under the supervision and with the participation of the
Company’s management, including our principal
executive officer and principal financial officer, of the
effectiveness of our disclosure controls and
procedures, as defined by Rule 13a-15 under the
Exchange Act. Based upon this evaluation, our principal
executive officer and principal financial officer have
concluded that the Company’s disclosure controls and
procedures were effective as of December 31, 2015.
MANAGEMENT’S REPORT ON INTERNAL CONTROL OVER
FINANCIAL REPORTING
Our management is responsible for establishing and
maintaining adequate internal control over our financial
reporting. Internal control over financial reporting is the
process designed by, or under the supervision of, our
principal executive officer and principal financial officer,
and effected by our Board of Directors, management
and other personnel, 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 (GAAP). Our
internal control over financial reporting includes those
policies and procedures that:
• pertain to the maintenance of records that, in
reasonable detail, accurately and fairly reflect the
transactions and dispositions of our assets;
• provide reasonable assurance that transactions
are recorded as necessary to allow for the
preparation of financial statements in accordance
with GAAP, and that our receipts and expenditures
are being made only in accordance with
authorizations of our management and directors;
• provide reasonable assurance regarding
prevention or timely detection of unauthorized
acquisition, use or disposition of our assets that
could have a material effect on our consolidated
financial statements; and
• provide reasonable assurance as to the detection
of fraud.
All internal control systems have inherent limitations,
including the possibility of circumvention and overriding
of controls, and therefore can provide only reasonable
assurance of achieving the designed control objectives.
The Company’s internal control system is supported by
written policies and procedures, contains self-
monitoring mechanisms, and is audited by the internal
audit function. Appropriate actions are taken by
management to correct deficiencies as they are
identified.
As of December 31, 2015, management has assessed
the effectiveness of the Company’s internal control over
financial reporting. In a report included on pages 40 and
41, management concluded that the Company’s
internal control over financial reporting was effective as
of December 31, 2015.
In making this assessment, we used the criteria
described in “Internal Control – Integrated Framework
(2013)” issued by the Committee of Sponsoring
Organizations of the Treadway Commission.
Our independent registered public accounting firm,
Deloitte & Touche LLP, with direct access to our Board
of Directors through our Audit and Finance Committee,
has audited the consolidated financial statements
prepared by us. Deloitte & Touche LLP has also issued
an attestation report on our internal control over
financial reporting. Their report on the consolidated
financial statements and attestation report are included
in Part II, Item 8 of this Annual Report under the heading
“Financial Statements and Supplementary Data.”
MANAGEMENT’S PROCESS TO ASSESS THE
EFFECTIVENESS OF INTERNAL CONTROL OVER FINANCIAL
REPORTING
To comply with the requirements of Section 404 of the
Sarbanes-Oxley Act of 2002, we followed a
comprehensive compliance process across the
enterprise to evaluate our internal control over financial
reporting, engaging employees at all levels of the
organization. Our internal control environment includes
an enterprise-wide attitude of integrity and control
consciousness that establishes a positive “tone at the
top.” This is exemplified by our ethics program that
includes long-standing principles and policies on ethical
business conduct that require employees to maintain
the highest ethical and legal standards in the conduct
of our business, which have been distributed to all
employees; a toll-free telephone helpline whereby any