True Value 2010 Annual Report Download - page 32

Financial Report 2010 11
MANAGEMENT’S REPORT
on Internal Control Over Financial Reporting
Although True Value is not an SEC registrant, True Value’s man-
agement has elected to assess the effectiveness of its internal
control over financial reporting as of January 1, 2011 and report,
based on that assessment, whether True Value’s internal controls
over financial reporting are effective.
True Value’s management isfollowing the guidance under Section
404 of The Sarbanes-Oxley Act of 2002, and as defined in Rules
13a-15(f) and 15d-15(f) under the Securities Exchange Act of 1934
that it is responsible for establishing and maintaining adequate
internal control over financial reporting. True Value’s internal con-
trol over reporting is designed to provide reasonable assurance
regarding the reliability of True Value’s financial reporting and
the preparation of financial statements for external purposes
in accordance with generally accepted accounting principles.
True Value’s internal control over financial reporting includes
those policies and procedures that: (i) pertain to the mainte-
nance of records that, in reasonable detail, accurately and fairly
reflect the acquisition, disposition and other transactions regarding
the assets of True Value; (ii) provide reasonable assurance that
transactions are recorded as necessary to permit preparation
of financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of True
Value are being made only in accordance with authorizations
of management and directors of True Value; and (iii) provide
reasonable assurance regarding prevention or timely detection of
unauthorized acquisition, use or disposition of True Value’s assets
that could have a material effect on the financial statements.
Internal control over financial reporting, because of its inherent
limitations, 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.
True Value’s management has assessed the effectiveness of its
internal control over financial reporting as of January 1, 2011. In
making this assessment, True Value’s management used the criteria
established by the Committee of Sponsoring Organizations of
the Treadway Commission (COSO) in Internal Control-Integrated
Framework. These criteria are in the areas of control environment,
risk assessment, control activities, information and communication,
and monitoring. True Value’s management assessment included
documenting, evaluating and testing of the design and operating
effectiveness of its internal control over financial reporting. True
Value’s management reviewed the results of its assessment with
the Audit Committee of our Board of Directors.
True Value’s management, based on their assessment, has con-
cluded that, as of January 1, 2011, True Value’s internal control
over financial reporting was effective.
TRUE VALUE COMPANY
Lyle G. Heidemann David A. Shadduck
President and Senior Vice President and
Chief Executive Officer Chief Financial Officer
Date: March 14, 2011