Mondelez 2014 Annual Report Download - page 111

Table of Contents
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 have established disclosure controls and procedures that are designed to ensure that information required to be disclosed in
our reports filed or submitted under the Exchange Act is recorded, processed, summarized and reported within the time periods
specified in the rules and forms of the SEC, and such information is accumulated and communicated to our management, including
our Chief Executive Officer (“CEO”) and Chief Financial Officer (“CFO”), as appropriate to allow timely decisions regarding required
disclosure. Management, together with our CEO and CFO, evaluated the effectiveness of the Company’s disclosure controls and
procedures as of December 31, 2014. Based on this evaluation, the CEO and CFO concluded that, due to a continued material
weakness in our internal control over financial reporting related to the accounting for income taxes, our disclosure controls and
procedures were not effective as of December 31, 2014. In light of this material weakness, prior to filing this Annual Report on Form
10-K, we undertook additional substantive procedures related to our disclosure controls, including validating the completeness and
accuracy of the underlying data used for accounting for income taxes.
These additional procedures have allowed us to conclude that, notwithstanding the material weakness in our internal control over
financial reporting, the consolidated financial statements included in this report fairly present, in all material respects, our financial
position, results of operations and cash flows for the periods presented in conformity with GAAP.
Status of Remediation
Through December 31, 2014, we made substantial progress toward remediating the material weakness in the internal control
including:
While significant improvement in the internal controls was made through December 31, 2014, we continue to evaluate the
effectiveness of the new internal controls to confirm that a sustainable, controlled process is fully in place. As we utilized outside tax
advisors and resources during 2014 to execute many of the new processes and controls, we hired and continue to hire additional
tax personnel across the Company. We have put in place processes to help ensure, and we continue to confirm, that sufficient
knowledge transfer has occurred and that relevant personnel and processes have been in operation for a sustained period of time.
We and our Board of Directors are committed to maintaining a strong and sustainable internal control environment. We believe that
the remediation work completed to date has significantly improved our internal control over the accounting for income taxes. We
believe it is important to confirm that the new processes and controls that we put in place as part of the remediation are fully
operational for a sufficient period of time in order to provide the Company with adequate assurance of a sustainable and reliable
control environment related to income tax accounting.
Report of Management on Internal Control Over Financial Reporting
Management is responsible for establishing and maintaining adequate internal control over financial reporting as defined in
Rules 13a-15(f) and 15d-15(f) under the Exchange Act. Our internal control over financial reporting is a process designed by, or
under the supervision of, our CEO and CFO, or persons performing similar functions, and effected by the Company’s 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 generally accepted
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revising and formalizing numerous income tax review processes,
• redesigning and executing a new, more robust internal control set related to income tax accounting,
• defining and clearly communicating roles and responsibilities for income tax accounting to local and regional personnel,
• implementing new industry-standard technology tools utilized in the accounting for income taxes,
• conducting extensive training on the accounting and control processes involving income tax accounting, and
• hiring additional personnel with specific tax accounting expertise.