47 Global Finance & Administration personnel; and to instruct each unit leader regarding the need to seek support at the Global Finance & Accounting level when accounting issues arise. • The Company's Global Controller individually contacted the Chief Financial Of ficer of each ROW business unit to discuss the changes in reporting lines, the year -end close process and other procedures to be instituted in connection with financial statement preparation. • The principal ROW Human Resources Of ficer has conducted an assessment of the ethical environment in ROW , based on, among other things, anonymous survey responses and employee focus groups, and will provide recommendations for measures designed to promote the values and behaviors addressed in the Company's Code of Ethics . 9. As part of a multi-region ef fort principally focused on ROW business units, the Company's Global Finance & Accounting personnel conducted a process to reconfirm reported balances of assets and liabilities as of September and October of 2012, and obtained additional information regarding accounting by each business unit within ROW . This process included: • balance sheet review procedures that were more formalized than those performed previously by each business unit Chief Financial Of ficer . The review procedures covered a variety of matters, including, among other things, • reviewing accounts for material period to period fluctuations, unexpected credit or debit balances or lack of activity , and providing explanations for significant variances to identify possible errors and inconsistencies, • reviewing accounts that require management judgment to ensure a proper analysis has been performed to support recorded balances on items such as obsolete inventory , • confirmation of proper reconciliation of sub-ledgers to the general ledger , and • completion by each ROW business unit Chief Financial Of ficer of a comprehensive accounting questionnaire, seeking information regarding accounting for , and issues involving, among other things, revenues, expenses, cash flows, inventory and other balance sheet items, and internal controls. 10. The Company's Global Finance & Accounting personnel performed a global assessment of the Company's financial capabilities and controls, with a view towards enhancing accounting and disclosure controls and procedures. The assessment was utilized for the Company's 2013 internal audit plan and will be utilized for other corporate initiatives. 1 1. The Company designed a new global sub-certification process that underscores individual responsibility and encourages direct communication to the Global Internal Audit department and Global Finance & Accounting. 12. User access administration has been revised so that only IT personnel at ROW headquarters will have the authority to grant user access to the inventory and other modules in the Business Planning and Control System (“BPCS”) in Brazil and all other ROW business units that use the BPCS system (the Company does not use the BPCS system outside of ROW). In addition, the Company is assessing the BPCS configuration to determine the appropriate level of local business unit access. Among items to be implemented is the imposition of restrictions on the local business units' ability to decouple transactions from the general ledger . T able of Contents