Change Report: Disclosure Controls and Internal Controls Over Financial Reporting (ICFR)
The ICFR framework remained consistently effective across all reporting periods analyzed, with no material weaknesses or significant deficiencies identified. Overall control procedures were stable from 2021 through 2025, with the primary shifts involving changes to the scope of the internal control assessment due to corporate acquisitions.
2021-12-31 to 2022-12-31:
The ICFR status remained unchanged; management concluded that controls were effective under the COSO (2013) framework, and no changes to internal controls or material weaknesses were noted in either period.
2023-12-31:
A strategic change occurred involving corporate scope: Denbury Inc., a wholly owned subsidiary acquired during 2023, was explicitly excluded from the ICFR assessment due to its determined immaterial financial impact. Controls remained effective otherwise.
2024-12-31:
The pattern of acquisition and subsequent scope exclusion continued. Pioneer, which was acquired by the Corporation during 2024, was explicitly excluded from the internal control assessment for the same reason (immateriality).
2025-12-31:
The ICFR status remained stable and effective, consistent with prior periods, and no changes to controls or scope were reported.