●  ONEOK INC /NEW/ · FY 2023 

Controls & Procedures

Management has concluded that its disclosure controls and internal financial reporting systems were effective as of December 31, 2023, indicating a strong foundational posture regarding corporate governance. However, this effectiveness assessment explicitly excluded the Magellan Acquisition due to ongoing operational integration, representing a temporary scope limitation in the ICFR evaluation. This highlights how significant corporate expansion can influence the immediate boundaries of internal control reviews.

OKE L1 Synthesis
●  SYMBOLOGY.ONLINE l1 SYNTHESIS 

Oneok Inc /new Controls & Procedures Synthesis

Internal Controls and Procedures Assessment Summary

Management's Conclusions on Control Effectiveness

Management has concluded that both disclosure controls and internal controls over financial reporting (ICFR) were effective as of December 31, 2023.

Disclosure Controls and Procedures
  • Strength: The Chief Executive Officer and Chief Financial Officer formally concluded that the company’s disclosure controls and procedures were effective during the reporting period.
Internal Control Over Financial Reporting (ICFR)
  • Strength: Management determined that ICFR was effective as of December 31, 2023, based on evaluation using the Internal Control-Integrated Framework (2013).
  • Noteworthy Caveat (Acquisition Exclusion): The effectiveness assessment explicitly excluded the Magellan Acquisition. This exclusion is permitted under SEC guidance for the first year post-acquisition while operations are being integrated, though it represents a scope limitation in the current ICFR evaluation.

Identified Deficiencies and Weaknesses

The company did not disclose any specific material weaknesses or significant deficiencies in its internal controls over financial reporting during this period. However, management noted inherent limitations to the control system:

  • Limitation: Management acknowledged that due to "inherent limitations," internal control over financial reporting may not be capable of preventing or detecting all misstatements.

Changes and Remediation Efforts

Changes in Internal Controls
  • Strength/Stability: There were no material changes identified in the company's internal controls over financial reporting during the quarter ended December 31, 2023, that were reasonably likely to materially affect the control environment.
Remediation Efforts and New Procedures
  • No specific remediation efforts for weaknesses or noteworthy new controls/procedures were mentioned in the provided text.

Balanced Assessment Summary

The company demonstrates a strong foundational posture regarding its internal controls, as management has concluded both disclosure controls and ICFR are effective. The system is supported by an external audit conducted by PricewaterhouseCoopers LLP. However, the assessment must be viewed with two key caveats: first, the temporary exclusion of the Magellan Acquisition from the scope of the ICFR evaluation; and second, the acknowledgment of inherent limitations in any control framework.