Symantec 2012 Annual Report Download - page 132

Item 9A. Controls and Procedures
a) Evaluation of Disclosure Controls and Procedures
The SEC defines the term “disclosure controls and procedures” to mean a company’s controls and other
procedures that are designed to ensure that information required to be disclosed in the reports that it files or
submits under the Exchange Act is recorded, processed, summarized, and reported, within the time periods
specified in the SEC’s rules and forms. “Disclosure controls and procedures” include, without limitation, controls
and procedures designed to ensure that information required to be disclosed by an issuer in the reports that it files
or submits under the Exchange Act is accumulated and communicated to the issuer’s management, including its
principal executive and principal financial officers, or persons performing similar functions, as appropriate to
allow timely decisions regarding required disclosure. Our disclosure controls and procedures are designed to
provide reasonable assurance that such information is accumulated and communicated to our management. Our
Chief Executive Officer and our Chief Financial Officer have concluded, based on an evaluation of the
effectiveness of our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) of the
Exchange Act) by our management, with the participation of our Chief Executive Officer and our Chief Financial
Officer, that our disclosure controls and procedures were effective at the reasonable assurance level as of the end
of the period covered by this report.
b) Management’s Report on Internal Control over Financial Reporting
Our management is responsible for establishing and maintaining adequate internal control over financial
reporting (as defined in Rules 13a-15(f) and 15d-15(f) of the Exchange Act) for Symantec. Our management,
with the participation of our Chief Executive Officer and our Chief Financial Officer, has conducted an
evaluation of the effectiveness of our internal control over financial reporting as of March 30, 2012, based on
criteria established in Internal Control — Integrated Framework issued by the Committee of Sponsoring
Organizations of the Treadway Commission (“COSO”). We have excluded from our evaluation the internal
control over financial reporting of Clearwell Systems Inc. (“Clearwell”), acquired on June 24, 2011, and
LiveOffice LLC (“LiveOffice”), acquired on January 13, 2012, as discussed in Note 3 of the Notes to
Consolidated Financial Statements in this annual report. As of March 30, 2012, total tangible assets subject to
these acquisitions’ internal control over financial reporting represented $84 million or less than 1% of our
consolidated total assets. Total net revenue subject to these acquisitions’ internal control over financial reporting
represented $51 million, or less than 1%, of our consolidated total net revenue for the fiscal year ended
March 30, 2012. As noted below, our internal control over financial reporting, subsequent to the dates of
acquisition, includes certain additional internal controls relating to these acquisitions, in addition to these
acquisitions’ internal control over financial reporting.
Our management has concluded that, as of March 30, 2012, our internal control over financial reporting was
effective based on these criteria.
The Company’s independent registered public accounting firm has issued an attestation report regarding its
assessment of the Company’s internal control over financial reporting as of March 30, 2012, which is included in
Part IV, Item 15 of this annual report.
c) Changes in Internal Control over Financial Reporting
There were no changes in our internal control over financial reporting during the quarter ended March 30,
2012 which have materially affected, or are reasonably likely to materially affect, our internal control over
financial reporting.
d) Limitations on Effectiveness of Controls
Our management, including our Chief Executive Officer and Chief Financial Officer, does not expect that
our disclosure controls and procedures or our internal controls will prevent all errors and all fraud. A control
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