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COMMERZBANK AKTIENGESELLSCHAFT

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28<br />

Commerzbank AG<br />

Group Audit promptly prepares a written report on each audit; the responsible members of<br />

the Board of Managing Directors are among the recipients of the report. On the basis of these<br />

audit reports, Group Audit oversees and documents the steps taken to remedy the deficiencies<br />

identified within the specified time. If such deficiencies are ignored, an escalation process<br />

comes into effect. In addition, Group Audit prepares an annual report on the audits that it<br />

has carried out during the course of the financial year, the material deficiencies identified<br />

and the measures taken, and presents this report to the Board of Managing Directors.<br />

The financial reporting process<br />

The financial reporting procedures at Commerzbank are supported by various IT systems<br />

integrated into each process. As part of the input process for financial reporting, all information<br />

relevant for drawing up the financial statements of Commerzbank Group under IFRS and<br />

Commerzbank Aktiengesellschaft under the German Commercial Code is submitted to head<br />

office by the reporting units (Commerzbank Aktiengesellschaft Germany, subsidiaries and<br />

foreign branches). Data is transmitted via a separate online system directly into SAP EC-CS<br />

consolidation software, which has been adapted to meet the Bank’s requirements. Subsidiaries<br />

generally submit IFRS data, German and foreign branches also submit data under the German<br />

Commercial Code. Data is automatically checked for consistency before transmission to head<br />

office. Once the plausibility checks have been successfully completed, individual reports can<br />

be finalised. Further plausibility checks are carried out using this data in head office. After<br />

these controls have been successfully completed, all the necessary steps are taken to produce<br />

the consolidated Commerzbank Group financial statements under IFRS and Commerzbank<br />

Aktiengesellschaft single-company financial statements under the German Commercial<br />

Code. Drawing up the Group financial statements involves various individual steps (e.g. consolidating<br />

equity, liabilities, income and expenses), currency translation and the elimination of<br />

intra-Group profits.<br />

Segment reporting is done on a separate IT system. This involves reconciliation with the<br />

data from accounting.<br />

Measures to further enhance the ICS as regards financial reporting<br />

The ICS has been adapted to meet the needs of the Commerzbank Group as regards financial<br />

reporting, and it is further enhanced on an ongoing basis. To this end, the internal Control<br />

Environment Initiative (CEI) has been permanently implemented at GM-F. The aim of CEI is<br />

to manage all risk-related processes by applying a uniform method to report and assess risk.<br />

In addition, it seeks to strengthen the ICS in the area of financial reporting by a regular assessment<br />

of the effectiveness and efficiency of controls and by regularly checking how controls<br />

are implemented.<br />

The CEI is based on a refined version of the GMF “process map”, which is a top-down representation<br />

of all key processes with descriptions of procedures. For this, risks affecting the<br />

reliability of financial reporting are identified using the COSO framework. The Bank also follows<br />

the recommendations of ISA 315. This involves checking whether a risk can be assigned<br />

to one of the following three categories and their various aspects:<br />

• Statements on types of business transaction: their occurrence, completeness, accuracy,<br />

allocation to the correct period and the correct account.<br />

• Statements on account balances at the reporting date: availability, rights and obligations,<br />

completeness, measurement and allocation.

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