Summary of Disclosure and Internal Controls Over Financial Reporting (ICFR)
Management's Assessment of Control Effectiveness
The Company, APA Corp, has concluded that its disclosure controls and procedures were effective as of December 31, 2024. This conclusion was made by both the Chief Executive Officer and the President and Chief Financial Officer.
Key Strengths
- Effectiveness Confirmed: Management affirmed that the existing disclosure controls provide "effective means to ensure that the information the Company is required to disclose... is recorded, processed, summarized, and reported within the time periods specified in the Commission's rules and forms."
- Proactive Review: The Company maintains a process of periodically reviewing the design and effectiveness of its disclosure controls, including compliance with applicable laws both domestically and internationally.
Deficiencies and Weaknesses
- The provided text does not identify any material weaknesses or significant deficiencies in the Company's internal controls over financial reporting.
- Management noted that while they make modifications to improve control design if deficiencies are identified, no such specific deficiency was reported during this period.
Changes and Remediation Efforts
Noteworthy Changes Introduced
- Acquisition-Related Controls (NEW): The most significant change in ICFR occurred following the Callon acquisition on April 1, 2024. This event necessitated the inclusion of "certain additional internal controls relating to Callon" into the Company's overall ICFR framework.
- No other changes were reported during the quarter ended December 31, 2024, that materially affected or are reasonably likely to materially affect the Company’s internal control over financial reporting.
Remediation and Ongoing Procedures
- The Company maintains a commitment to corrective action; it stated that it "may take other corrective action" if its periodic reviews identify weaknesses in its controls.
- Management's formal report on ICFR (Item 308(a)) and the independent auditor’s attestation report (Item 308(b)) are incorporated by reference, providing detailed documentation of these procedures.