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Transocean Proxy Statement and 2010 Annual Report

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Item 9. Changes in <strong>and</strong> Disagreements with Accountants on Accounting <strong>and</strong> Financial Disclosure<br />

We have not had a change in or disagreement with our accountants within 24 months prior to the date of our most recent<br />

financial statements or in any period subsequent to such date.<br />

Item 9A. Controls <strong>and</strong> Procedures<br />

Disclosure controls <strong>and</strong> procedures—We carried out an evaluation, under the supervision <strong>and</strong> with the participation of<br />

management, including our Chief Executive Officer <strong>and</strong> Chief Financial Officer, of the effectiveness of our disclosure controls <strong>and</strong><br />

procedures as of the end of the period covered by this report. Based on that evaluation, our Chief Executive Officer <strong>and</strong> Chief Financial<br />

Officer concluded that our disclosure controls <strong>and</strong> procedures, as defined in Exchange Act Rules 13a-15(e) <strong>and</strong> 15d-15(e), were effective<br />

as of December 31, <strong>2010</strong> <strong>and</strong> provide reasonable assurance that information required to be disclosed in our reports filed or submitted<br />

under the Exchange Act is (1) accumulated <strong>and</strong> communicated to our management, including our Chief Executive Officer <strong>and</strong> our Chief<br />

Financial Officer, to allow timely decisions regarding required disclosure <strong>and</strong> (2) recorded, processed, summarized <strong>and</strong> reported within<br />

the time periods specified in the Securities <strong>and</strong> Exchange Commission’s rules <strong>and</strong> forms.<br />

Internal controls over financial reporting—There were no changes in these internal controls during the quarter ended<br />

December 31, <strong>2010</strong> that have materially affected, or are reasonably likely to materially affect, our internal controls over financial reporting.<br />

Other matters—In April <strong>2010</strong>, we implemented a new global Enterprise Resource Planning (“ERP”) system, a fully integrated<br />

software environment, designed to optimize <strong>and</strong> st<strong>and</strong>ardize processes in treasury, accounting, supply chain management, asset<br />

management <strong>and</strong> information technology. Although we have updated our internal controls that have been affected by the ERP<br />

implementation, we do not believe that the ERP implementation has had an adverse effect on our internal controls over financial<br />

reporting.<br />

See “Management’s <strong>Report</strong> on Internal Control Over Financial <strong>Report</strong>ing” <strong>and</strong> “<strong>Report</strong> of Independent Registered Public<br />

Accounting Firm” included in Item 8 of this <strong>Annual</strong> <strong>Report</strong>.<br />

Item 9B. Other Information<br />

None.<br />

AR-120

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