entire - Deutsche Bank Annual Report 2012

Deutsche Bank 01 – Management Report 119
Financial Report 2010 Internal Control over Financial Reporting
However, any internal control system, including ICOFR, no matter how well conceived and operated, can provide
only reasonable, not absolute, assurance that the objectives of that control system are met. As such, disclosure
controls and procedures or systems for ICOFR may not prevent all error and all fraud. Further, the design of a
control system must reflect the fact that there are resource constraints, and the benefits of controls must be
considered relative to their costs.
Organization of Internal Control System
Functions involved in the system of internal control over financial reporting
As the books and records form the basis of the financial statements, controls within the system of ICOFR are
performed by all business functions and the respective infrastructure functions with an involvement in assuring
the reliability of those books and records. As a result, the operation of ICOFR involves a large number of staff
based mainly in the following functions: Finance, Group Technology and Operations, Legal, Risk & Capital
and Tax.
Finance is responsible for the periodic preparation of the financial statements and operates independently from
the businesses. Within Finance, different departments have control responsibilities which contribute to the overall
preparation process:
— Finance specialists for businesses or entities – responsible for assuring the quality of financial data by performing
validation and control. They are in close contact with business, infrastructure and legal entity management
and employ their specific knowledge to address financial reporting issues arising on products and
transactions, as well as validating reserving and other judgmental adjustments. They also provide oversight
of the performance of controls over individual transactions and balances. Entity and business related specialists
add the perspective of legal entities to the business view and sign-off on the financial reporting of
their entities.
— Finance-Group – responsible for Group-wide activities which include the preparation of group financial and
management information, forecasting and planning, risk reporting. Finance-Group set the reporting timetables,
perform the consolidation and aggregation processes, effect the elimination entries for inter and intra
group activities, control the access and adjustment processes, compile the Group financial statements, consider
and incorporate comments as to content and presentation made by senior management, SOx and
Disclosure Steering Committee members and external advisors.
— Accounting Policy and Advisory Group (“APAG”) – responsible for developing the Group’s interpretation of
international accounting standards and their consistent application within the Group. APAG provides accounting
advice and consulting services to Finance and the wider business, and ensures the timely resolution
of corporate and transaction-specific accounting issues.
— Global Valuation Oversight Group (“GVO”) and business aligned valuation specialists – responsible for
developing policies and minimum standards for valuation, and provides related implementation guidance
when undertaking valuation control work. This is in addition to challenging and validating valuation control
results, and acting as the single point of contact for valuation topics with external third parties (such as regulators
and auditors).